Low Level Presence (LLP) Overview
Since comingling of grain cannot be completely avoided in agricultural production and transport, new plant biotechnology products approved in the country of cultivation may be unintentionally present in small amounts in shipments to countries that have not yet approved them. This is known as “low level presence” (LLP): the unintentional, low level presence of an agricultural biotech product approved in one or more countries, but not yet approved in the importing country.
Even the most sophisticated infrastructure cannot prevent different crops or crop varieties — biotech and conventional — from potentially coming into contact with one another.
Because the product has already undergone a full and rigorous safety assessment, found to be safe and has been authorised for unrestricted use in food, feed, and derived products by the competent government authority in at least one country, low level presence of that product should not be thought of as a food or feed safety issue for other countries. Rather, it is an issue of noncompliance with the importing country’s regulations.
While there is a complex infrastructure dedicated to the bulk handling and movement of grain and seed from farms to consumers around the world, even the most sophisticated infrastructure cannot prevent different crops or crop varieties — biotech and conventional — from potentially coming into contact with one another. Therefore, despite the robustness of our production and grain trading systems and careful stewardship of all shipments from field to shelf, LLP may occur.
LLP of Stacks
Several biotech products now available have more than one technology, or event, incorporated, or stacked, into the same crop plant. These are sometimes known as ‘stacks,’ and the same LLP principles apply as long risk assessments are established for each event in the stack. The increasing number of stacked events makes the need for a global LLP policy even more critical. Today there are approximately 30 approved stacked events in the marketplace.
LLP in Seed
Global trade in seed, including for purposes of seed and grain production, testing and breeding, is significant and continues to increase. The seed industry has many practices, processes and systems to manage seed product integrity, with the specific goal of facilitating international seed trade. With growing adoption and use of biotech varieties; however, seed lots may sometimes contain LLP of seed products approved for cultivation in the country of export but not approved in the country of import. Therefore, seed movement is vulnerable to costly impediments and restrictions related to LLP policies. In some instances, these policies have resulted in destruction of crops in the field and seed shortages at critical planting times.
Impacts of Insufficient LLP Policies
Failure to proactively develop a proactive, transparent LLP policy could lead to cancellation of contracts, demurrage charges, risk premiums and supply shortages for the country of import. This can cause significant issues across the value chain – from farmers to consumers. Several studies in recent years have shown:
- Maize and soy trade disruptions in the European Union from LLP issues could cost EU consumers as much as €10.5 billion annually.
- Another analysis found soybean prices in the EU would rise as high as 220% following a major trade disruption with nations exporting biotech crops.
- In Latin America, disruption from LLP could cause 2-8% price increases for smaller importers and 9-20% increases for larger importers.
Implementation of transparent and proactive LLP policies that ensure the smooth flow of trade can help prevent possible issues and ensure farmers, retailers and consumers continue to benefit from an interconnected, global agricultural value chain.