Genetically modified (GM) crops: European and transatlantic divisions



‘It seems doubtful to me whether this idea (i.e. transformation) is ever going to be practicable’. These words were included in a report prepared by Ralph Riley (Director of the Plant Breeding Institute in Cambridge) following a Rockefeller Foundation conference that took place in the Villa Sebelloni, Bellagio, Italy, in May 1969. The conference was entitled, ‘Crop Improvement through Techniques of Plant Cell and Tissue Culture’, and its declared aim was ‘to evaluate the present status of cell and tissue culture methods in plants, and to consider what prospects these procedures offer for crop improvement’. Of the 14 international participants, Lou Nickell from the USA was apparently the only one who, at that time, was conducting serious experiments to investigate the possibility of gene transfer to higher plants. However, the philosophy and pace of research changed dramatically during the subsequent decade and, by January 1983, four groups were able to announce at the Miami Winter Symposium that they had successfully used molecular techniques to transfer a gene into a plant (Downey et al., 1983). Thirty years later, it is instructive to look back at the application of such technology and, in particular, to assess the present and future commercial status of genetically modified (GM) crops. This brief review pays special attention to the dichotomy of experiences, attitudes and opportunities represented on the two sides of the Atlantic.

Commercial Experiences

In 2012, 69.5 million hectares of GM crops were grown in the USA, with maize (corn) and soybean representing the majority of this total. The adoption rate for these two crops in the USA is now 90% for maize and ∼95% for soybean. In contrast, the total area of GM Bt maize grown in Europe in 2012 was only 119 000 hectares, with 90% of this total in Spain, and smaller amounts in Portugal and the Czech Republic. Five years ago, such Bt maize was also grown in France, Germany and Romania, but these countries no longer do so, principally as a consequence of political policy driven, in part, by small-scale but concerted public opposition often involving ‘direct action’. For example, a recent analysis identified at least 80 acts of vandalism against public sector GM field trials in Europe (Kuntz, 2012). These were mainly in France, Germany, the UK and Switzerland, and included the destruction of a trial of GM vines at the INRA centre in Colmar with damage estimated at €1.2 million.

Despite this apparent rejection of the cultivation of GM crops in many areas of Europe, the European Union (EU) is a major livestock producer, has a structural shortage of feed protein and is a major importer of agricultural products derived from transgenic crops, mainly for use in feeds. Most of these GM products are soybean, with about 70% of soybean meal consumed in the EU being imported; 80% of this meal is produced from GM soybeans. It has been estimated [United States Department of Agriculture (USDA), 2013] that, on average, EU imports of soybean meal and soybeans from Brazil, Argentina and the USA amount to $9 billion and $6.5 billion per year, respectively. There is therefore the paradoxical position of many EU states rejecting GM cultivation within their own countries, but accepting the need to maintain the livestock industry, something that depends to a significant degree on imports of GM feed (Masip et al., 2013). This contradictory view is not widely acknowledged.

Political Attitudes within Europe

Many commentators consider that GM crops represent a vital contribution to food security both at present and also in the future, when population growth (Dunwell, 2013a) and other social and economic trends will require an approximate doubling of food production by 2050. In the words of the G20 Agriculture Vice-Ministers and Deputies Report from 2012 ‘Increasing production and productivity on a sustainable basis in economic, social and environmental terms, while considering the diversity of agricultural conditions, is one of the most important challenges that the world faces today’ ( The UK Secretary of State for the Department for the Environment, Food and Rural Affairs made a major speech on 20 June 2013 about the role of GM in the future of agriculture (, and the European Academies Science Advisory Council (EASAC) has recently published a detailed report on the opportunities of using GM technologies in sustainable agriculture [European Academies Science Advisory Council (EASAC), 2013].

The view of the disparate attitudes within the EU, from the perspective of the US government, is also relevant. In a recent report (USDA, 2013), it is stated that ‘EU and Member State (MS) authorities have developed a complex and lengthy policy framework, driven by well-orchestrated anti-biotech actions by non-governmental organizations (NGOs). As a consequence, research, development, and commercial production and imports of biotech products into the EU have been slowed and limited.’ This external analysis of Europe divides the region into three groups, based on their attitudes to GM crops. The first group, including Spain, Portugal, Czech Republic, Slovakia and Romania, are classified as ‘Adopters’, namely countries producing GM corn (see above), and those such as the UK, the Netherlands and several Scandinavian countries, who could be producers of GM crops if the range of crops approved for cultivation in the EU were wider and included those with traits of interest for their farmers, industry and/or consumers. Second, the ‘Conflicted’ group include countries such as France, Germany and Poland, where forces willing to adopt the technology (mainly the science community, farmers and the feed industry) are counterbalanced and usually out-matched by forces rejecting it (consumers and governments, under the influence of active green parties and NGOs). Third, the ‘Opposed’ group consists of countries such as Austria, Croatia, Greece, Hungary, Italy and Slovenia, where most stakeholders and policy makers reject the technology. Organic products and those with geographical indications represent a significant part of food production in this group of countries.

With some slight exceptions, the greatest opposition to GM technology within Europe is in those countries that lie to the east of Churchill's ‘Iron Curtain’, which stretched from ‘Stettin in the Baltic to Trieste in the Adriatic’. Whether the present European barrier will remain in place for as long as its historic Cold War equivalent (1945–1991) is a matter for debate. The consequences of this situation are discussed below.

Commercial Response in Europe

As the recent USDA GAIN report on agricultural biotechnology in the EU (USDA, 2013) states: ‘In the European Union (EU), governments, the media, non-governmental organizations, consumer groups, and industry associations remain conflicted about the use of agricultural biotechnology. Acceptance varies greatly among adopters, the conflicted, and opposed Member States (MS). EU and MS authorities have developed a complex and lengthy policy framework for plant and animal biotechnology that slows down and limits research, development, production, and imports.’ ‘The growing adoption of the technology by leading agricultural producer countries makes it increasingly difficult and expensive for EU companies to source non-biotech products and ingredients for food products that are labeled as “non-GMO”.’

It is pertinent to consider the background to this comment. All GM crops on the market in the USA have achieved a deregulated status. This procedure is limited to the USA and involves an application that requests that a specific GM product is equivalent to the non-GM version and therefore should no longer be regulated and therefore not labelled. There have been 96 approvals for deregulation from 1990 to date; these comprise examples from alfalfa, canola, corn, cotton, flax, rose, papaya, plum, potato, rice, soybean, squash, sugar beet, tobacco and tomato. It is likely that the subject of those approvals not already on the market will proceed to full commercial development. There are also 18 applications pending decision; these include alfalfa (1), apple (1) (non-browning, see, canola (1), corn (3), cotton (1), creeping bentgrass (1), eucalyptus (1) (cold tolerance), potato (1) and soybean (8). In contrast, all products containing GM constituents must be labelled if sold in the EU. The potential deterrent effect of such labelling is now the subject of much discussion in the USA at a time when proposals to label have been rejected in California and New York, but passed in Connecticut and Vermont, and are being considered by 26 states, including Maine, New Hampshire and Washington State. In the words of Maine Representative Lance Harvell ‘If you want to make the American people potentially a lab experiment, at least let them know what's going on.’ The US Senate in May 2013 rejected by 71 votes to 27 an amendment that would allow states to require the labelling of GM food. The potential commercial significance attributed to this issue can be judged by the published estimate that the biotech industry spent nearly US$45 million on advertising that opposed the Californian proposal, which was rejected in a referendum by 53% to 47%.

Such variations in regulatory approaches to GM between the USA and EU have played a major role in determining the future direction of commercial research investment. In the 1980s and 1990s, there were numerous commercial GM research centres in Europe, but that number has been drastically reduced with all major companies now relocating their research expertise. For example, in 2012, the German biotech producer BASF halted the development of genetically modified crops in Europe and moved all of its European GMO research operations to the USA. Similarly, during 2013, Syngenta opened a new US$72 million advanced crop laboratory in North Carolina and announced an associated US$94 million investment in an ‘Innovation Centre’ with an additional 150 R&D jobs. Syngenta has also moved investment to developing countries in the form of research centres in Goa, India (employing 500), Beijing, China and Brazil. They also have plans to build a US$85 million hybrid seed and crop protection centre in Russia. Such decisions are demonstrative of the commercial reality that Europe is not an attractive area for investment in comparison with India and China, who will account for 40% of total food demand by 2025.

In a related move, in July 2013, Monsanto announced that it would no longer be seeking approvals for GM crops now under review in the EU. A corporate spokesman said that the company is making it clear that it will only pursue market penetration of biotech crops in areas that provide broad support. ‘We're going to sell the GM seeds only where they enjoy broad farmer support, broad political support and a functioning regulatory system. As far as we're convinced this only applies to a few countries in Europe today, primarily Spain and Portugal.’ A company spokesman in England stated, ‘It's clear there isn't a path to market and commercialize GM products for cultivation in Europe. We need to focus our limited resources where we can get the best return.’ This announcement was welcomed by organizations, such as Friends of the Earth, with the words, ‘However, Monsanto's toxic presence in Europe has not gone away. They still plan to grow their main GM crop in Europe, seek to widen their control over conventional seeds and increase their sales of chemicals that pollute the countryside and our bodies.’

Public Attitudes

This is a very complex area, and there have been many published surveys on consumer attitudes to GM (Dunwell, 2013b). Some of these surveys are international in scope, with one of the most comprehensive being a systematic review and meta-analysis to assess research relevant to understanding consumer and societal attitudes to GM applied to agri-food production (Frewer et al., 2013). The objective of this survey was to compare attitudes in different global regions, at different times and between applications. Among issues considered in such surveys are questions relating to basic knowledge of science, ethics, human rights, affects on the developing world, the need for choice, labelling and coexistence with organic agriculture. An analysis of 70 articles found that plant-related or ‘general’ applications were more acceptable than animal-related applications. Risk perceptions were shown to be greater in Europe than in North America and Asia, with the reverse being true for the perceptions of benefit. Concerns based on moral considerations were higher in North America and Asia than in Europe.

Novel Breeding Techniques

The first GM plants were produced using either Agrobacterium-based or direct gene transfer techniques, such as particle bombardment. At that time, all the focus was on the introduction of novel genes into the nuclear genome of the recipient plant. However, much emphasis has shifted towards more precise methods of genome editing that allow the targeting or modification of specific genes. In addition, it is possible to employ GM methods that modify the processes of recombination, but such techniques then leave no ‘fingerprint’ in the eventual product and therefore cannot be detected. These novel breeding technologies and how they should be considered in a regulatory context have been the subject of many assessments in recent years. There is developing agreement that the present regulatory legislation, particularly in the EU, is no longer fit for purpose. This present system is based on an assessment of the process by which GM crops are produced, and the suggestion is that a more scientifically logical and future proof system would be to base any regulation on the characteristics (or phenotype) of the product. This proposal has been included in recent reports from EASAC (EASAC, 2013) and the UK Advisory Committee for Releases to the Environment ( A review of some of these issues from the perspective of the USDA has been published recently (Ledford, 2013). Among the seemingly illogical conclusions is that the introduction of plant gene(s) (cisgenic) into a recipient crop should not be regulated if direct gene transfer methods are employed, but should be regulated if Agrobacterium methods are used. Such anomalous conclusions can only lead to more confusion in terms of the incompatibility of US and EU definitions and their impact on the international trade in ‘GM’ products.


This brief summary has explored some of the areas of inconsistency and variation in the public, political and commercial approaches to GM technologies within and between the USA and Europe. It has demonstrated that 30 years of experience has not simplified or eased these international divisions. Because of the EU impasse in the approval system (Fresco, 2013), generated in part by political expediency, commercial decisions have been made by the major companies to withdraw from Europe and focus investment in the developing world where future demand is more certain. To follow the sentiment of Ralph Riley more than 40 years ago, ‘It seems doubtful whether this situation will ever be reversed’.