The Stories We Trust : Regulating Genome Edited Organisms

In ongoing discussions about the regulation of genome edited organisms in the UK and the EU, existing regulation to prevent harm to human and planetary health is often portrayed as the ‘bad guy’ trying to curb progress. What if we look at GMO-regulation in a different way? How to think of and design policy frameworks of care that support people- and earth-centred or agroecological processes of change? Unpacking the narratives that underpin corporate campaigns to deregulate new technologies of genetic engineering, Barbara Van Dyck contributes with this article to our column, Agroecology in Motion: Nourishing Transformation

Daunting terms and simple solutions

Precision breeding, new genome techniques, new GMOs, hidden GMOs, new breeding techniques, CRISPR/Cas9, mutagenesis … The debate on the regulation of genetic engineering is daunting with terms. The complexity of the science behind these techniques is intimidating. Zinc-finger nucleases, meganucleases techniques, prime editing, cisgenesis, intragenesis or transgenesis, oligonucleotide directed mutagenesis, epigenetic techniques, Agrobacterium mediated techniques…where to start? Meanwhile, the unexplored possibilities of the techniques to intervene in the genetic material of plants, animals and other living organisms appeal to the imagination. One can imagine plants made to guarantee crop yields, even in extreme weather conditions. A few simple interventions in plant crops would make cholesterol-lowering food widely available. Or imagine that plants’ ability to cope with diseases could directly be built into their hereditary material, thanks to targeted genomic interventions. 

The fact that these examples sound very familiar is no coincidence. The NGO Corporate Europe Observatory recently revealed how they are the result of a well-crafted and often repeated story as part of a sustained lobby campaign that has succeeded in shaping much of the thinking about new GMOs. A narrative that has been designed to win hearts and minds after the failure of older generations of GMOs to deliver on their claimed benefits, such as effective control of weeds and pests, resistance against diseases, drought tolerance, enhanced nutritious value and intrinsic yield gains. 

Fear, villains and heroes

The crafting of stories that make products sellable is a profession. Good sales men and women succeed in making potential customers believe that they really want or need a product. The deeper psyche is exploited here. The great art of sales consists in developing anxiety, even fear, in the receiver of their message by constantly projecting the darkest images of the future if they do not entrust in the great project that is for sale. Marketing specialist Jonathan Sach illustrates this deficiency approach as follows. How to sell lipstick? “You are not attractive enough to be loved, this lipstick will make you irresistible.

This simple message plays on deeper fears (you are unattractive), offers a solution (lipstick) and gives the recipient of the message an active role in solving the problem (buy the lipstick). A similar storyline is underpinning many of the most popular sci-fi films: create an enemy to be feared, connect with foundational beliefs,  come up with a savior and solution. A biological weapon gets out of control, the scientists created the problem and science and technology are also the only hope for salvation.

The narrative for touting GMOs follows a similar pattern: A whole series of dark images of the future are projected including hunger, land scarcity, pests and toxic pesticides and connected to the potential of new biotechniques in alleviating these doomsday scenarios. Customised messages about bringing extinct animals back to life or freeing up land by ‘tweaking’ genes are also designed to convince nature lovers of the need for GMOs. Everything may not be all right, but better times lay ahead, scientists are working on the solution. In the further interest of manufacturing public trust for new GMOs, larger systemic root causes of hunger, public health issues and environmental destruction, as well as uncertainties and worrying studies about unintended effects of the use of these biotechnologies are skillfully ignored.   

Special messages are designed for policy makers in the UK and the EU: Scientists have solutions to some of the major concerns of our time, but cannot realise the potential of their work because of GMO regulations (the villain). These regulations are holding back progress and put the competitiveness of your region at stake. But you, the decision-maker, can play a role in the solution (the hero). Get those pesky regulations out of the way!

Changing the rules

A key step in the strategy to exempt new GMOs from regulation in Europe and the UK, as explains Michael Keller secretary general of the industrial lobby group ISF (International Seed Federation) in an interview with EuropeanSeed in 2018 , is for governments to align on the criteria “to determine whether a product falls within or outside the scope of existing biotechnology/GMO regulations”. There is a lot at stake, because an answer to this question will help determine which procedures must be followed to ensure health and environment safety, which labelling is required, and even the extent to which public debate must be facilitated. It is therefore in the interest of GMO developers and producers to exempt as many products as possible from the GMO-regulations. 

The morale must have been high in the boardrooms of the International Seed Federation (ISF), and other companies when, only a few days after Brexit, on January 7 at the 2021 Oxford Farming conference, Secretary of State George Eustice stated that having left the European Union, the UK would now be free of regulations which previously it had “no choice but to slavishly adopt […] however irrational and flawed they might be.” During that speech the secretary announced a public consultation “on proposed changes to English law” to stop certain gene edited products being regulated as GMOs. According to the Secretary of State this was needed to “unlock substantial benefits to nature and the environment, helping farmers produce more resilient crops and to produce healthier, more nutritious food”. The proposal to exempt a number of gene edited products in agriculture from the GMO regulation came a few months after a failed attempt to change the definition of GMOs in the Agriculture Bill. 

Corporate Europe Observatory exposes lobbying tactics to deregulate GMOs in its report “Derailing EU rules on new GMOs” (picture courtesey CEO)

Meanwhile in late April, and openly cheered by some scientists and industry, the European Commission published an opinion study regarding the regulation of new GMOs. The outcome of the study seeks to justify the EC’s intentions to break open the European Union’s rules. This move comes after the European Court of Justice’s decision that gene edited products are indeed GMOs and thus have to be regulated as such. With this judgment in 2018, the court clarified that products with new names were not, in fact, new products. Ever since, gene editing proponents have been lobbying to then change the law instead. It is said that the European Court of Justice’s ruling “denies scientific facts and deprives Europe of a technology that enables the development of environmentally friendly, sustainable agriculture and a bio-based economy”. The Commission’s opinion study reports on the negative impacts of the current GMO- regulations on public and private research on new genomic techniques. They also link the need for changing GMO rules because of the potential of gene edited products to “the objectives of the EU’s Green Deal and in particular to the ‘farm to fork’ and biodiversity strategies and the United Nations’ sustainable development goals (SDGs) for a more resilient and sustainable agri-food system.” Examples given include plants more resistant to diseases and environmental conditions or climate change effects in general, improved agronomic or nutritional traits, reduced use of pesticides. 

A number of prominent EU and UK decision-makers embody their roles in the industry’s imagined story line particularly well. They have taken up their role in combating regulation, justifying their decisions by replicating the unfounded idea that organisms that are genetically modified using the latest advances in science do “carry the same level of risk as conventional breeding techniques” and have high potential for sustainability. Words that are remarkably close to the criteria the seed industry imagined a few years earlier. In 2018, ISF secretary Keller clarifies that the underlying principle for determining whether a product should be included or excluded from gmo regulations is that “Plant varieties developed through the latest breeding methods should not be differentially regulated if they are similar or indistinguishable from varieties that could have been produced through earlier breeding methods.”

It is clear who will reap immediate benefits from deregulation; but there is a remarkable lack of clarity as to who will take responsibility for any unintended consequences. The list of scientific publications pointing to unexpected effects of interventions with gene editing techniques is growing rapidly. The proclaimed precision of the gene editing tools does indeed not say anything on the outcomes of their use in plants. Scientists have argued that gene editing techniques are definitely not safe-by-design,  as is claimed by some GMO developers. The many risks and uncertainties coming with the new generation of genetic engineering tools are only beginning to be understood and help to reveal how human control of nature is a fallacy. Based on a review of the existent evidence, the European Network of Scientists for Social and Environmental Responsibility and of Critical Scientists Switzerland concludes that regulations must be strengthened rather than weakened. 

Furthermore,  researchers, peasant organizations, environmental and social justice groups are extremely worried about the disproportionate attention paid to an unproven technology that will drive speculation and investment in short-term, technology-oriented and profit-driven solutions, while many other proven and emerging systemic solutions are marginalized. From groundwater depletion to soil erosion and agricultural biodiversity decline, history has shown the shortcomings of pursuing ‘single-track’ modernising development in agriculture. Research and civil society voices alike increasingly stress the urgency for systemic transformations, including the recognition of plural and diverse innovation pathways.
Peasant organizations, environmental and social justice groups are worried about the pressure to deregulate new GMOs in Europe

Technological bluff

In repeating industry narratives, decision-makers (and the media) pave the ground for a handful of corporations to advance false solutions that serve their encroachment of food systems. To help clarify valid claims from technological bluff, we recommend institutions, regulators and funders to carry out a ‘hype test’ by asking: What makes gene editing superior to other, more systemic options including agroecology, that makes it successful in producing healthier plants, animals and crops and healthier food? Could it be that while gene editing may appear to have benefits, they may actually have been overstated and/or keep an unsustainable production system in place and foreclose more promising futures?

More compelling stories would be careful in evaluating new GMOs on the level of their contribution to the sustainability of food systems and consider that the costs of remediating adverse effects can quickly annulate any proclaimed benefits. This includes, but is not limited to, the narrow evaluation of environmental and health risks. Instead broader anti-social or negative environmental outcomes would be part of the conversation. How does the deregulation of new GMOs benefit a subset of users and negatively affect others? What will be the impact of UK and European decisions for the most vulnerable communities and environments in Europe as well as in other regions in the world? How will farmer and farm worker livelihoods be impacted? Is the deregulation of gene edited products likely to disrupt the  monopolies in food and agriculture? How may such a decision impact on agricultural biodiversity or soil health? How does the regulation of GMOs connect to the investment in agroecological or other innovation trajectories? More compelling stories would be humble in their claims of potentialities and assess the new technologies in relation to others. Beyond any doubt, regulatory frameworks based on stories geared towards the thriving of peasant farming and the care for public and environmental health will be more complex. If anything, complexity, humbleness and care may well be better building blocks for trustworthy GMO-regulation than the hubris of science fiction and corporate greed.