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COMMISSION DIRECTIVE (EU) .../… amending Directive 2001/18/EC of the European Parliament and of the Council as regards the environmental risk assessment of genetically modified organisms
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IFOAM EU (Belgium)
IFOAM EU, the European group of the International Federation of the Organic Agriculture Movements, comments on the draft Commission Directive updating the environmental risk assessment of GMOs 1. Since its adoption in 2001, this is the first time that the Annexes of Directive 2001/18 on Environmental Risk Assessment (ERA) are updated. IFOAM EU welcomes the proposal of the European Commission to update the text on that specific topic but would...
European Network of Scientists for Social and Environmental Responsibility (Germany)
We would like to submit following comments and also refer to our critique of the 2010 EFSA Guidance on ERA for GMPs (http://www.ensser.org/developing-responsible-approaches-to-risk-assessme...) C1 3.b & c The amendment will lead to an exclusion of vast numbers of scientific peer-reviewed studies published by public scientific institutions from future ERA of GMOs in the EU. Many of these studies were funded by the EU and its Member States...
Friends of the Earth Europe (Belgium)
Friends of Earth Europe’s comments on gaps and key requirements for improvements of the ERA of GMO under directive 2001/18: The EC proposal aims to frame a scientifically sound legal base for the ERA of all of GMO for the upcoming years. Politically incomplete: Already in 2008 all environment ministers demanded to strengthen the ERA on specific geographical areas, long-term effects as well the coherence between risk assessments of pesticides...
Based on detailed analysis, Testbiotech rejects the current proposal of the EU Commission in most of its elements and instead make the following recommendations for future environmental risk assessment: Avoid oversimplification: It has to be acknowledged that the absence of observable effects cannot be interpreted as evidence for the safety of the plants. Risk assessment has to be based on a broad range of empirical data and mandatory...
Greenpeace European Unit (Belgium)
For the first time in 15 years, the Commission has proposed an update of Annexes II, III and IV of Directive 2001/18 on the principles for the environmental risk assessment of GMOs and information required from applicants. (1) The Commission proposal comes late. Environment ministers asked for an improvement of the environmental risk assessment of GMOs as early as 2008. (2) The proposal fails to reflect all relevant guidance by EFSA. It only...
Zu Annex IV A (b) 7. (Seite 15 des Änderungsentwurfs) In diesem Absatz sollte durch geeignete Ergänzungen des Textes sichergestellt werden, dass der Antragsteller Material zur Verfügung stellt, das für die Herstellung von zertifiziertem Referenzmaterial geeignet ist. Damit eine gute Verfügbarkeit und eine hohe Qualität des zertifizierten Referenzmaterials gewährleistet ist, sollte außerdem die Vorgabe aufgenommen werden, dass die...