.Letter from Swedish beekeepers to Advocate General
Dear Mr Yves Bot
We wish to thank you for the excellent report you have written concerning GMO and pollen. As beekeepers we are very concerned about the situation in which we now find ourselves and therefore greatly appreciate that these issues are been dealt with so thoroughly.
We do however wish to call your attention to certain points:
– None of the existing approvals for any GMOs in food and feed include an approval for placing pollen on the market. Nor have any food/feed safety or environmental risk assessments of pollen been carried out.
– With respect to renewed approvals, for example of Bt 11 (decision 2010/419/EU), MON 88017+MON810 (decision 2010/419/EU) and 1507+59122 (decision 2010/432/EU), the approvals have been renewed in accordance with the earlier decision and also extended to include all food/feed products made from these crops. This approval has been given without having carried out a risk assessment and approved placement on the market all the various products – for example honey or pollen as a food supplement
These renewed approvals are not in line with EUs GMO Regulations because the initial approvals did not include pollen. Pollen in honey and raw pollen as a food supplement have never been assessed for risks nor approved for placement on the market. Also EFSA’s Scientific Opinion does not take these aspects into consideration. For example, the risk for horizontal gene transfer from pollen mixed with the lactic acid bacteria from the bees honeystomach has not even been considered. Due to the graveness of the risks involved the Precautionary Principle must be applied.
– In the recently (2010) approved Mir604 no risk assessment of its pollen has been carried out and no specific request for the placement of pollen on the market has been made. The approval covers all food and feed containing, consisting of or produced from this genetically modified maize. It also covers products over than food and feed containing or consisting of this maize for the same uses as any other maize with the exception of cultivation.
It is of great urgen[cy] that the renewed approvals as well as the recently approved MIR604 be challenged based on the fact that no risk assessment of pollen has been carried out. The risks that GMOs carry for bees and beekeeping need to be taken seriously. We need both support and research. Beekeeping is threatened if beekeepers are thrown out into a legal ‘limbo’ where we alone shall bear the responsibility that our products follow food regulations concerning GMO content while at the same time no risk assessment has been carried out, no approval given for release on the market and no labelling rules are applicable.
Syngenta has recently applied for authorization of Event MIR604 maize cultivation in the EU. If this and other applications for cultivation of GMO crops in the EU are approved the result will be widespread contamination of bees and bee products with GMO pollen. This will occur without any serious attempt to asses the risks involved for bees, beekeeping and consumers of bee products. Traceability and consumer information, two of the cornerstones of EUs GMO policy, will be undermined. If the EU regulations are to be of any value to beekeepers and consumers then GMO pollen must also be included in the approval for market release after a thorough risk assessment has been made. All regulations governing GMOs must also rigorously apply to our products. Anything less is completely unacceptable.
Beekeepers in Sweden