Mr. Dermot Ryan:

I thank the committee for the invitation to update it on the proposal outlined. This proposal is to allow each member state decide if they wish to permit or ban the import and use of GM food and feed in their territory. The proposal states that such prohibitions or restrictions must be reasoned and based on compelling grounds and must not conflict with the EFSA risk assessment.

Genetic modification is a science-based technology which, in the case of plants, alters the gene structure in a way that does not occur naturally through fertilisation or natural recombination. This modification confers certain traits on the plant that can be advantageous to agriculture and food-feed production. However the application of the technology has proven to be controversial. Current EU legislation defines a GMO as "an organism, with the exception of human beings, in which the genetic material has been altered in a way that does not occur naturally by mating and/or natural recombination".

According to the International Service for the Acquisition of Agri-Biotech Applications, 18 million farmers in 28 countries planted more than 181 million ha of GM crops in 2014. Cultivation is concentrated in five countries with 90% planted in the USA, Brazil, Argentina, India and Canada. The main GM crops cultivated are maize, soya bean, cotton and oilseed rape. While herbicide-tolerance and insect resistance are the predominant traits of the commercialised GM crops, there is an increasing spectrum of traits emerging, which include drought and salinity tolerance, yield enhancement through more efficient use of nutrients, disease resistance, improved nutrition content and improved food safety profile.

The cultivation and marketing of GM crops within the EU is strictly controlled by EU-wide legislation which has been jointly adopted by the European Parliament and the Council of Ministers. In the past 15 years the European Union has introduced a suite of regulations governing the safety, labelling, marketing and traceability of GM crops, food and feed. Central to these regulations are four main legislative acts, namely: directive (2001/18/EC), which outlines the conditions for the deliberate release of GMOs into the environment and sets out aspects of the risk assessment required prior to their release; Regulation 1829/2003 which sets out the conditions for authorisation, supervision and marketing of GMOs for food and feed use; Regulation 1830/2003 establishes the conditions for labelling and traceability of GM food and feed; and the contained use directive (2009/41/EC), which lays down measures for the contained use of genetically modified micro-organisms.

The main aim of the legislation is to give the consumer a clear choice, through labelling, between GM and non-GM products and the confidence that all GM products placed on the EU market are safe for human and animal consumption and to the environment and can be traced back to source.

The authorisation procedure is that GM crops, food and feed are subject to a comprehensive risk assessment by the European Food Safety Authority before they are authorised for use in the EU. The risk assessment is designed to ensure GM crops and GM food and feed do not pose a risk to human health, animal health and the environment. Preparation of an application to have a new GM crop cultivated in the EU or to have a new GM food or feed derived from a GM crop authorised for import and use in the EU is the responsibility of the breeder. The application must be prepared according to standard guidelines established by EFSA and the OECD. Experts in EFSA then carry out a risk assessment of the data presented in the application to ensure the GM crop, food and feed are safe for human health, animal health and the environment.

Following a favourable opinion from the EFSA, the European Commission presents a draft proposal to the EU regulatory committee on GMOs, that is, the Standing Committee on Plants, Animals, Food and Feed, SCoPAFF, for vote on approval or rejection of the application for authorisation in the EU. If no qualified majority is achieved for or against the application, the proposal is submitted to the higher level appeals committee. If no majority is achieved at the appeals committee, the proposal reverts to the Commission for final decision.

To date, no application to authorise a GM crop for cultivation or for food and feed use has received a qualified majority at standing committee level. In general, votes have been split approximately 12 in favour, 12 against and three or four abstentions. The decision then reverts to the Commission which has generally approved the applications in line with standard EU policy. Once a GM product is approved, the authorisation is valid for ten years. To date, 57 GMOs have been approved for food and feed use in the EU. However, only one of these, namely, MON810, an insect resistant maize, has been approved for cultivation. Of the 57 approved, 30 are maize, 12 soya bean, ten cotton, four oilseed rape and one sugar beet.

The GM maize, MON810, is cultivated in five EU member states, namely, Spain, Portugal, the Czech Republic, Romania and Slovakia. The total GM maize plantings in the EU in 2014 amounted to 143,000 hectares, with over 90% of this cultivated in Spain. All applications for authorisation by the EU to place food and feed products consisting of or containing genetically modified ingredients in the EU market are considered individually following a comprehensive evaluation of the GMO by the EFSA. In line with Government policy of adopting a positive but precautionary approach on biotechnology, a common voting position is adopted by Ireland for food and feed on the basis of a favourable opinion from the EFSA and the Food Safety Authority of Ireland.

The comprehensive risk evaluation procedure adopted by the EU has given rise to a time lag between the EU and third country authorisations, thus leading to trade difficulties between the EU and the main global exporting countries of GM crops, namely, the USA, Brazil, Argentina and Canada. New GM crops that are authorised and cultivated in North and South America are generally not authorised for a period of one to two years later in the EU, leading to rejection of unauthorised shipments of maize and soya bean at EU ports. Rejection of these shipments occurs due to the zero tolerance in the EU of unauthorised GM crops. This disparity in authorisation timing, known as asynchronous authorisation, has given rise to considerable difficulties for the Irish and EU trade, and alteration to the EU authorisation process as suggested in the current proposal is likely to give rise to similar difficulties in the shipment of feed materials to Ireland.

Regulation of GM crops in Ireland is shared between the Department of the Environment, Community and Local Government, the Department of Agriculture, Food and the Marine and the Department of Health. The Department of the Environment, Community and Local Government has primary responsibility for the deliberate release of GMOs into the environment as governed by Directive 2001/18/EC.

The Department is also responsible for the authorisation of GMO trials, both field and contained-use, including genetically modified micro-organisms. The EPA assists the Department of the Environment, Community and Local Government in risk assessment and the setting of conditions for the conduct of the trials, as well as conditions for deliberate release. The Department of Health has responsibility for the use of GMOs as regards food. The Department of Agriculture, Food and the Marine has responsibility for the import and use of GM feed, as well as control measures for cultivation post-commercialisation, should that arise.

The European Union is only 35% self-sufficient in protein supplies for animal feed. Soybean is the most favoured vegetable protein because of its nutritional efficacy and competitive cost. In Ireland up to 80% of animal feed for ruminants is provided by grass, hay and silage, complemented, where appropriate, by compound feeds. In the case of pigs and poultry, virtually all of their nutrition is derived from compound feeds. The Irish cereal harvest is generally in the region of 2.2 millions tonnes per annum, of which approximately 1.7 million tonnes are used for animal feed, with the remainder being used in the food and drinks sector.

On average, Ireland imports 3 million tonnes of animal feed materials per annum. In addition, approximately 1.7 million tonnes of home-grown cereals are used in the production of feed, bringing the total usage of feed materials to approximately 4.7 million tonnes. Some 66% of these feed materials is used for ruminant feed - 16% for pigs, 12% for poultry and 6% for other animals. Of the 3 million tonnes imported, approximately 55% is sourced from third countries outside the European Union, mainly Argentina, the United States, Ukraine, Canada and Brazil. More than 1.2 million tonnes of soy and maize GM products were imported into Ireland for animal feed in 2014, constituting 40% of total feed imports. The main commodities imported are maize and maize by-products, soya bean meal and soy hulls and rapeseed meal. Up to 90% of the soya bean and maize products imported from Argentina, Brazil and the United States is derived from genetically modified crops. Significant quantities of non-GM maize and oilseed rape meal are imported from continental Europe, including Ukraine.

Ireland is especially dependent on feed imports relative to other EU member states in that approximately two thirds of the feed materials marketed here are imported, compared with, for instance, 37% in the United Kingdom, 27% in France and 26% in Germany. The pig and poultry sectors which employ almost 10,000 personnel in production and processing are particularly impacted on, as soya bean is an essential ingredient in the formulation of these feed rations.

The Food and Feed Chain Coalition, FFC, which represents ten EU member organisations from different parts of the food and feed chain has expressed its opposition to the proposal from the European Commission, as has the Irish Grain and Feed Association, IGFA. The animal feed industry in Ireland considers the import of significant quantities of soya bean and maize from North and South America where GMO cultivation is widespread as essential to satisfy the protein fraction in animal nutrition. Trading difficulties have arisen in the past owing to zero tolerance of unauthorised GM crops. Further difficulties with such imports are likely to be exacerbated in the future as an increasing number of GM crop varieties are cultivated in North and South America in advance of authorisations being achieved in the European Union. In previous years the United States has delayed the cultivation of new GM varieties to ensure compatibility with EU authorisations, but this practice is increasingly difficult to implement owing to the widespread adoption of stacked or multiple GM traits in GM crops.

I thank members for their attention and will be happy to answer questions they may have.