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12 I EUROPEAN SEED I EUROPEAN-SEED.COM EU FFC PARTNERS VIEWS The FFC coalition has clear views on how the EUs GMO system should be strictly science-based predictable and timely and in line with legislation already in force. The FFC partners have gathered substantial evidence and rely on solid arguments to support their views that the GM opt-out proposal is very far from meeting the needs of the EU agri-food chain in view of maintaining if not enhancing its competitiveness. It is the opinion of the FFC coalition that if adopted the GM opt- out proposal would result in substantial commercial and legal risks for operators condemning those to overly high costs and undue trade disruptions. The agri-food chain is the largest employer in Europe today providing 44 million jobs. Threatening its competitiveness would be openly running against the EUs political priorities of jobs and growth and better and smart regulation. From a procedural standpoint the FFC partners regret that neither stakeholder consultation nor impact assessment was conducted. They note that the proposed system would create a dangerous precedent to lawfully contravene the founding principles of the EU whenever expedient in the future. Dismantling the internal market would also destabilise the commodities market in the EU and have a negative impact on the EU budget and its economy. To better assess the possible implications of the proposal selected members of the FFC coalition conducted an Economic Impact Assessment to analyse the potential adverse effects that look poised to arise in the event that four Member States opted-out within the terms of the proposal. COCERAL FEDIOL and FEFACs analysis describes a scenario where France Germany Hungary and Poland deliberately opt-out from GM authorisations for soybeans. Given that these countries represent around 30 per cent of the European soybean demand and that the vast majority approximately 90 per cent of soybeans and its derived products used for feed in the EU are GM this worst-case scenario would no doubt have severe implications. The Economic Impact Assessment takes stock of the fact that from a global viewpoint the EU is highly dependent on imports of protein-rich raw materials and products thereof for crushing and feed purposes mainly but not limited tooilseeds and meals. These protein-rich agricultural commodities are mostly GM-derived a feature that brings no added value per seat least in most cases. The nutritional characteristics of such GM crops are equivalent to those of their conventional counterparts. However enjoying unrestricted access to a protein-rich supply on the global market is absolutely crucial to ensure the viability and competitiveness of the EU agri-food industryas the EU does not and for a number of reasons cannot domestically produce sufficient protein crops to supply the demand. THE WAY FORWARD Despite the FFC partners opposition to the proposal the impact analysis of its potential implications has proven a rather useful exercise for the EU agri- food chain to speak with one voice and demand that efforts and resources be put at the service of the single most important goal making current EU deci- sion-making work. As gathered at the FFC coalition the concerned industries agree that the solution to the GMO authorisation problems can only be found in a timely and accurate implementation of the current EU ruleswhich keep scientific considerations at the heart of the authorisation system and take into account the views of democratically-elected governments. The members of the FFC coalition are convinced that it is critically important to preserve the core values of the EU the single market and free circulation of goods also in GMO decision-making. Authorisations must be strictly science-based and be granted in cases where they are in line with EFSAs independent risk assessment. GMO approvals need to comply with the EUs international trade commitments in order to secure the smooth function- ing of global trade relations with commodity-exporting countries essential to ensure the present and future competitiveness of the EU agri-food industry. As net importers of agricultural commodities EU operators along the food and feed supply chain must be able to compete internationally. Last but not least the legislative and regulatory environment in the EU needs to provide the much-needed legal certainty for economic operators. Clearly that is the only way forward to secure the economic viability of key industry sectors attract investment and create growth and jobs in Europe. In light of the need for a clear and consistent harmonised system ensuring availability of agricultural commodities at affordable costs in the EU and legal certainty for EU business operators the EU food and feed chain partners jointly call for an accurate and correct application of existing EU legislation on GMOs away from creative schemes that risk undermining core European values. FINELY CRAFTED SEEDS EXPERTS. Put your trust in our industry leading experts in wholesale seed and contract seed production. We are an open pollinated vegetable herb and flower seed company that offers you the knowledge resources and creativity to create quality beautiful and terrific tasting results. We serve the globe ask about our extensive inventory. Albany Oregon U.S.A. 541.928.7100