Concepts of GMO-free Environmentally Sensitive Areas


1 "GMO-free area" means a geographical area where no deliberate releases of Genetically Modified Organisms (GMOs) into the environment and no use of GMOs as seeds take place. This does not necessarily include the marketing of foods and feed, as long as these activities do not result in the reproduction of GMOs or as long as there is no known other environmental risk. Thus GMO-free areas are not thought to be an alternative concept in relation to comprehensive environmental risk assessment but an additional concept of risk minimizing and/or risk management. (see HOPPICHLER 1998b, 1999).

2 see LOIBL / STELZER 1997. In February 1999 the European Parliament adopted its position at first reading on the proposal for a European Parliament and Council directive on the deliberate release into the environment of genetically modified organisms and repealing Council Directive 90/220/EEC. The following amendment in connection with the notification for placing on the market was included: "The competent authority, when granting consent, can impose additional conditions for the protection of environmentally sensitive areas. It shall inform the Commission and the other Member States of this immediately, stating the reasons." The recommendations for the second reading (February 2000) did not refer to this amendment any more since the Council's Common Position (EC) No 12/2000 stated in Article 18 (3c) that "the written consent ... shall, in all cases, explicitly specify:…(c) the conditions for the placing on the market of the product, including any specific condition of use, handling and packaging of the GMO(s) as or in products, and conditions for the protection of particular ecosystems/environments and/or geographical areas." There are also some changes in Annex IV, like provisions concerning the "description of the geographical area(s) and types of environment where the product is intended to be used within the Community, including, where possible, estimated scale of use in each area;" and with regard to additional information (in accordance with Article 12), "proposed restrictions in the approved use of the GMO, for example where the product may be used and for what purposes".

3 In February 2000 the European Commission published a Communication on the Precautionary Principle (COM (2000) 1). In this paper the principle is defined more narrowly and as particularly relevant mainly to the management of risk. Although the communication mentions Article 174 as the only explicit reference in the Treaty to the precautionary principle, interestingly it does not cite the full Article including the environmental conditions in the various regions of the Community which, from our point of view, is an important criterion for defining the precautionary principle. Before this the precautionary principle had been introduced in the White Paper on Food Safety (COM (1999) 719) as a guiding principle in risk management, which was criticised recently by the European Economic and Social Committee as "not seeming to resolve the matter entirely", because "it is well known that scientists have to deal with the question of doubt." (OJ C204, 18.7.2000, p. 24).

4 In the German version, the so called "environmental risk assessment" is translated as "Umweltverträglichkeitsprüfung" ("environmental impact assessment").

5 Some efforts to define environmental sensitivity have been made especially in connection with the environmental problems of trans-European road transport. The latest initiative was an announcement by the Commission in May 2000 to submit a "Communication on transport in environmentally sensitive areas (the Alps and the Pyrenees)" by the end of the year (COM (2000) 257).

6 The term "environmentally sensitive areas" may be used for the Less Favoured Areas Scheme as part of EU rural development policy (see FISCHLER 1998).

7 As a recent approach dealing with differences and diversity of ecosystems also see Norway/UN Conference on the Ecosystem Approach for Sustainable Use of Biological Diversity (

8 Surprisingly enough, in environmental risk assessment of GMOs with regard to biodiversity we do not even know all components of the targeted system in question, let alone their meaning.

9 Citing Altieri (1998 - "As long as transgenic crops follow closely the pesticide paradigm, such biotechnological products will do nothing but reinforce the pesticide treadmill in agroecosystems, thus legitimizing the concerns that many scientists have expressed regarding the possible environmental risks of genetically engineered organisms."

10 However, some exceptions are possible. An example: Since HILBECK et al. (1998) pointed out effects of transgenic Bt corn on lacewings and since LOSEY et. al (1999) demonstrated the possible harm of transgenic pollen from Bt corn to some species of butterflies, there has been a lot of discussion on the possible effects of Bt plants on non-target organisms. As HILBECK et al. (2000) summarized, very few studies on insects have been published so far which could serve as a basis for regulatory processes. Especially concerning bees, only two studies are available. In the first study, bee-larvae were fed pure pollen (although larval bees normally cannot digest pure pollen). The second (unpublished) study accounts for this uncertainty; the pollen was therefore provided via worker bees. This study is still in progress in Germany. So there is no scientific evidence till now that Bt pollen cannot affect the biological reproduction of bees.

This question may be crucial under the relatively harsh climatic conditions of the Alpine regions, since in the major Alpine valleys, maize pollen is one of the main sources of larval feed for the reproduction of bees in autumn and spring. Especially the last generation of bees in autumn is quite sensitive with regard to feed and depends on a special hormonal constitution to survive winter time.

11 The (British) Advisory Committee on Novel Foods and Processes (ACNFP Feb. 1999) says with regard to certain antibiotic resistance marker genes in cotton that: "In the production of novel foods or the exploitation of novel processes, we open opportunities for microbial evolution that would not otherwise exist. The production of large numbers of crop plants increases enormously the biomass of resistance genes. We cannot predict what the effect of such amplification will be…"; the question remains what kind of measures we could take to react to this possible new evolution. An area-specific approach to create an overall counterbalance could be one pragmatic answer. Furthermore, we could take into account regionally diverse needs concerning environment and biodiversity (see HASLBERGER 2000).


13 Meanwhile the Cartagena Protocol on Biosafety was negotiated in January 2000 and signed in May 2000 in Nairobi. The Cartagena Protocol on Biosafety provides a framework, based on the precautionary principle, for the safe transfer, handling and use of living modified organisms resulting from modern biotechnology that may have adverse effects on the conservation and sustainable use of biological diversity, taking also into account risks to human health and specifically focussing on transboundary movements. In the preamble the precautionary approach (contained in Principle 15 of the Rio Declaration on Environment and Development) is reaffirmed and the crucial importance to humankind of centres of origin and centres of genetic diversity is recognized. Within the Cartagena Protocol the precautionary principle is specified in Article 1, Article 10.6 and/or Article 11.8 . As for recent discussions on the precautionary principle also see NATURE BIOTECHNOLY 18, 697 (18 July 2000).

14 Sometimes in industrialized countries interpretations of this part of the CBD refer only to indigenous peoples in developing countries and it is implied that there is no relation to demands of local communities in industrialized countries. But this is a very narrow-minded view point.

15 In order to enforce the role of effective public participation in decisions related to our environment the so called Aarhus-Convention (Convention on Access to Information, Public Participation in Decision-Making and Access to Justice in Environmental Matters) was signed by most of European Environmental Ministers in 1998. To meet the special requirements of public participation and information concerning modern biotechnology a special "GMO Task Force" under the lead of Austria was implemented . This aims at analysing the possibilities of a further development of the Convention concerning this issue (see GAUGITSCH 2000).

16 "In-situ conservation" means the conservation of ecosystems and natural habitats and the maintenance and recovery of viable populations of species in their natural surroundings and, in the case of domesticated or cultivated species, in the surroundings where they have developed their distinctive properties.

"On-farm conservation" means the conservation of Plant Genetic Resources through agricultural utilization, in particular the cultivation of species and varieties (e.g. traditional land races) on farms. "On-farm management" goes beyond mere conservation, as Plant Genetic Resources will also be improved and developed.

17 PGR = Plant Genetic Resources; PGRFA = Plant Genetic Resources for Food and Agriculture.

18 A special General Principle of IFOAM (International Federation of Organic Agriculture Movements) defined in 1999: Genetic engineering has no place in organic production and processing - Certification programmes shall set standards and make every effort including relevant documentation to ensure that no genetically engineered organisms or products thereof are used in organic production and processing. It is acknowledged that in exceptional cases, contamination by genetically engineered products can be beyond the control of the certified operator. Therefore organic products shall not be labelled as GE (genetic engineering) or GM (genetic modification) free in order to avoid potentially misleading claims about the end product. Any reference to genetic engineering on product labels shall be limited to the production method.

19 In 1999 this passage was definitively included in Council Regulation (EC) No 1804/1999, supplementing Regulation (EEC) No 2092/91 on organic production.

20 They are nominated by national governments and must meet a minimal set of criteria and adhere to a minimal set of conditions before being admitted into the World Network. Each Biosphere Reserve is intended to fulfil three basic functions: a conservation function (landscapes, ecosystems, species and genetic variation); a development function (to foster economic and human development which is socio-culturally and ecologically sustainable); a logistic function (support for research, monitoring, education and information exchange).

21 Not only will they be a means for the people who live and work within and around them to attain a balanced relationship with the natural world, they will also explore how to meet the needs of society, as a whole, by showing the way to a more sustainable future (as for mountain research see PRICE 1995).

22 In the second, empirical part of the study another appraisal was made by SCHERMER (1999): GMO-free areas as an alternative option of technology development.

23 In Austria most issues concerning agriculture, environment and nature protection (especially protected areas) come under the responsibility of the nine Federal Provinces (Bundesländer).

24 In the course of analysing the resulting data, the target groups had to be restructured a little. As biotechnologists did not fit the profile of other scientists, they had to be separated. The same thing happened with politicians from the Green Party. They showed the same profile as members of environmental NGOs and were therefore integrated into this group.


Browsing Classification: Agriculture: Production Cultures and Plant Genetics

Agriculture: Cultures de Production et Plants génétiques

Agricultura: Cultivos de Producción y Genética vegetal

Citation: Hopplichler, J. 2000. Concepts of GMO-free Environmentally Sensitive Areas. Federal Institute for Less-Favoured and Mountainous Areas, Vienna.

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