Overview
If commodity grain shipments are stopped when LLP is detected, economic consequences can be very significant. These include steep financial costs associated with detaining the shipment (demurrage), financing of goods, costs related to delays while waiting for results of grain analysis, and deterioration in grain quality as the shipment is diverted to other markets, repurposed or destroyed. Trade in a particular commodity can eventually cease if the risks associated with importing that commodity are too high and markets are lost as importers and exporters engage in discussions with inspectors, trade officials, and buyers. Grain supplies and ingredient pipelines can be disrupted, and commodity or food shortages can occur in the importing country, which can impact food prices.
National Policies
To prevent trade disruptions and their potential to impact food supplies, countries must immediately work towards solutions and trade policies that minimize the risk to trade that stems from unresolved LLP situations.
To prevent trade disruptions and their potential to impact food supplies, countries must immediately work towards solutions and trade policies that minimize the risk to trade that stems from unresolved LLP situations.
Recognizing this reality, some countries have implemented policies to promptly review regulatory applications for new biotech products in advance of their entering global trade. Other countries may rely on regulatory safety assessments from another country as reason to allow shipments with certain low level presence, temporarily or permanently.
Threshold levels are commonly used to allow a certain level of ‘off-type’ or non-standard grain to be present within commodity supplies without decreasing the value of the product or requiring additional handling costs associated with grain channeling and quality management. Developed and based on practical global experience with unintentional comingling of conventional grain products, threshold levels could be applied to LLP of biotech products as well. Furthermore, a marketing or ‘de minimis’ threshold may be set by a business in order to market a product with even less or no non-standard (i.e., biotech) content.
However, many other countries are only just beginning to identify mechanisms to address LLP, and many still have de facto zero tolerance policies for unapproved biotech products. This means that within those markets, it is illegal to sell or distribute a product known to contain a biotech product not approved for food, feed or processing use in that country.
Ideally, countries with fully functioning regulatory systems can eliminate LLP situations by achieving synchronized approvals with exporting countries, or for completion of biotech product reviews within 12 months from the date of submission. In this context, countries should recognize (or at least consider) valid risk assessments that have been conducted by an exporting country in accordance with the Codex Plant Guideline as a basis for granting full approval to the event. The use of Codex Guidelines should encourage countries to move away from current zero thresholds and establish practical low-level marketing thresholds.
GAABT Positions
- Principles and Criteria for Proactive Solutions to Address Low Level Presence of Agricultural Biotechnology-derived Plant Products in Food, Feed, and Grain for Processing
- Practical Approach to Address Low Level Presence (LLP) of Agricultural Biotechnology-derived Plant Products in Food, Feed, and Grain for Processing (FFP)