GM Free Cymru

How the American GM soy industry views the world

Comment from GM-Free Cymru: this is a very revealing document, which shows us how the American soybean industry (now entirely GM) sees the world. This view is of course largely supported by the US Administration, and these are the sorts of points made in the diplomatic encounters between American farming industry representatives and their counterparts in Europe. The speech is full of the most extraordinary nonsense -- and it is full of breathtaking arrogance. Note the throwaway references to "the EU's discriminatory policies", the use of the term "enhanced crops" meaning GMO crops, the opposition to GM labelling, the phrase "correcting the EU approval process", the vociferous opposition to " the practice of some EU Member States to prohibit imports of biotech enhanced commodities", the opposition to EU renewable energy policies, and the none-too-subtle attempt to undermine and even remove the EU regulatory process relating to GMOs. We assume that this is the sort of rubbish which is having a profound effect on Environment Secretary Owen Paterson -- so God help us all.

Statement by Richard Wilkins, Vice President American Soybean Association before the EU-US High Level Regulatory Cooperation Forum April 10, 2013

Good afternoon. My name is Richard Wilkins. I am a soybean farmer from Greenwood, Delaware, and I serve as Treasurer of the American Soybean Association. ASA represents U.S. soybean farmers on national and international policy issues. ASA appreciates the opportunity to present our views at this stakeholder session of the Forum.

The European Union has been an important export market for U.S. soybeans and soy products. In 1997, we exported 10.3 million tons of these products to EU Member States. However, by 2012 the volume of exports had fallen by over 81 percent to 1.9 million tons. We believe important causes for this sharp decline are the EU's requirements that food products derived from agricultural biotechnology be labeled and, more recently, the EU's discriminatory policies on biofuel feedstocks under its Renewable Energy Directive (RED).

EU Biotechnology Policies

The EU began requiring labeling of foods containing biotech ingredients in 1999. The EU requires this labeling even though the enhanced crop in question has been determined safe and at least equivalent in nutrition to its non-biotech counterpart. While the EU requires labeling of foods containing biotech crop ingredients, it exempts from labeling requirements biotech yeasts and enzymes commonly used in European-made beer, wine, cheese, and other products. Rather than include a label that could be negatively perceived by consumers, food product manufacturers have reformulated their ingredients to use non-biotech vegetable oils or import non-biotech soybeans and soybean oil from other suppliers. The United States food industry asked the Office of the U.S. Trade Representative to challenge the EU's labeling policy in a letter signed by 24 national trade associations in November 2003. No action was taken. We would like to note areas where EU biotech regulations and policies can be addressed within the scope of the TTIP negotiations. These include correcting the EU approval process for new biotech enhancement traits, which is politicized and hamstrung to the point that the European Food Safety Agency reviews are being greatly delayed. Even after EFSA gives a positive opinion, it still takes months for final EU Commission approval. Approvals need to be subject to deadlines, with decisions based only on scientific criteria.

The EU has adopted a "technical solution" under which only 0.1 percent of an unapproved biotech trait is allowed in a feed shipment, while the tolerance for food shipments remains at zero. Neither of these levels is commercially feasible. The EU should agree to participate in efforts to establish international standards for the Low Level Presence of unapproved biotech traits in commodity shipments.

A third area needing correction is the practice of some EU Member States to prohibit imports of biotech enhanced commodities that have been approved by the EU Commissioners. These restrictions clearly violate EU law, and must be eliminated.


In 2009, the EU enacted the Renewable Energy Directive, RED, which imposes greenhouse gas emission reduction requirements on biofuels used in EU Member States, and requires documentation that the production of biofuel feedstocks meets specific sustainability standards. The greenhouse gas formula for soy-biodiesel is based on production and transportation data for Brazil. This significantly understates the emissions reduction of U.S. biodiesel and thus limits the amount of biodiesel derived from U.S. soybeans that can qualify under RED. The United States soy industry has submitted to EU officials correct greenhouse gas emission data for U.S. soybeans, but the EU has not updated its data for U.S. soy. The RED also contains sustainability requirements that are being interpreted to only mean compliance with onerous and costly procedures, including farm-level audits. The U.S. soy industry has worked with USTR and the U.S. Department of Agriculture to initiate negotiations with the EU on a bilateral agreement under which documented producer compliance with U.S. conservation laws would be deemed to meet the RED's sustainability requirements. This initiative was rejected by DG-Energy in September 2012. As a result, soybean oil from U.S. soybeans crushed in the EU will no longer be eligible for use in biodiesel production. If the U.S. is to maintain even its current limited access to the EU market for soybean exports, the TTIP must guarantee that negotiations on an aggregate bilateral agreement will go forward, as provided for under the RED.

The Proposed EU EFA Program

In February of this year, EU Farm Ministers approved an Ecologically-Focused Areas (EFA) program which would provide incentives for EU production of high-protein commodities, particularly soybeans. While this program has not been affirmed by the Council of Ministers or the EU Parliament, we believe it would nullify and impair U.S. access to the EU market for soybeans and soybean meal and violate the Blair House Agreement reached at the end of the Uruguay Round negotiations. The TTIP negotiations must ensure that the EFA program will not be promulgated into EU law.


We understand that the goal of this Forum and of the EU-US Transatlantic Trade and Investment Partnership negotiations is to identify and work to harmonize areas where our respective regulations and laws currently restrict bilateral trade. However, unless all regulations, laws, and interpretation of laws are addressed, access to the EU market will continue to be impaired, and exports of U.S. soybeans and soy products will remain well below historical levels.

Thank you for the opportunity to appear at this stakeholders meeting of the EU-US High Level Regulatory Cooperation Forum. We sincerely wish to work toward a mutually beneficial agreement on agricultural trade. I will be pleased to respond to any questions you may have.