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Open Letter of Inquiry Regarding the COVID-19 Vaccine

To: Tamura Norihisa, Minister of Health

From: Consumers Union of Japan

14 January 2021

Open Letter of Inquiry Regarding the COVID-19 Vaccine

On 8 September 2020, Consumers Union of japan (CUJ) sent an open letter of inquiry to your ministry regarding the new coronavirus vaccine. Since we did not receive a response after the deadline of 23 September, we contacted you twice to request a response. You replied that you were “working on it,” but we have yet to receive a response. Therefore, we are now sending you another letter of inquiry as follows.

Your Ministry has reached an agreement with Pfizer Inc. of the United States, AstraZeneca of the United Kingdom, and Moderna of the United States to supply a vaccine (a new type of biovaccine) as a countermeasure against COVID-19 infection, and has already announced that you hope to start vaccination in February. This vaccine is a completely new type of vaccine that has never been used before, and it will be administered on a large scale at a stage when its efficacy, sustainability and safety are not well understood.

Vaccines have been causing health problems, especially in children, due to adverse reactions. Vaccines, unlike drugs, are given to healthy people. We need to be more cautious than ever. Moreover, this time, large-scale vaccination is being considered. In particular, we have strong concerns about the possibility of increased adverse reactions among medical professionals, the elderly, and those working in facilities for the elderly, who will be effectively forced to be vaccinated. For this reason, we would like to ask the following questions.

We apologize for any inconvenience this may cause you, but we would appreciate your response in writing by 29 January 2021. The answers will be shared within and outside our organization.


1. Unlike conventional vaccines, the vaccine for COVID-19 infection (the new biovaccine) is a human genetic recombination in which genes are introduced into the body. Moreover, the effectiveness and sustainability of the vaccine have hardly been confirmed, and the harmfulness of the vaccine is not well understood. This is clearly a human experiment. Please tell us why you are in such a hurry to conduct this kind of human experiment.

2. The current vaccination program is effectively forcing medical personnel, the elderly, and people working in facilities for the elderly to be vaccinated. This is causing a lot of concern among people working in hospitals and facilities and their families. The new biotech vaccine is still at the stage of human experimentation, and we believe that de facto compulsory vaccination is a human rights violation.

3. The human immune system is complex, and if the new biotech vaccine, which works in a way that has never been experienced before, interferes with this complex system, there is a risk that it will cause allergies, hypersensitivity, and autoimmune diseases. There is also a risk of antibody-dependent enhancement of infection (ADE), which is an increase in viral infection, and vaccine-related respiratory disease (ERD). What do you think about this point?

4. The real picture of COVID-19 is still unknown, and problems such as the rapid decline of immune response in infected people have been pointed out. In addition, mutant viruses are appearing one after another. Even if the new biovaccine is effective, there are concerns that it will soon lose its effectiveness, and that vaccination may lead to more mutated viruses. What do you think about the need for drastic measures from a long-term perspective rather than vaccination?

Protest Against Genome Edited “GABA” Tomato in Tokyo, Japan

In what may have been the world’s first protest against a genome edited GMO food product, the GABA tomato, activists from Consumers Union of Japan and the No! GMO Campaign gathered outside Sanatech’s offices in central Tokyo, Japan on 23 December 2020.








Letter sent to Sanatech:

To: Sanatech Seed                                                                             14 December 2020

From: Consumers Union of Japan, No! GMO Campaign

Open Letter of Inquiry on Genome Edited High GABA* Tomatoes

We are a consumer organization that is working for food safety.

It has been reported that your company is distributing free of charge high GABA tomatoes produced with genome editing technology for home gardening. We believe that genome editing technology, like genetic modification technology, is potentially risky as it can cause unintentional genetic mutations and create unexpected harmful substances in crops. We are concerned that it is a big problem that genetically engineered foods, whose safety has not been fully confirmed, are being used for food.

We have some doubts about the explanatory materials that your company submitted to the Ministry of Health, Labor and Welfare (MHLW) and posted on the MHLW website, and we believe that the act of free distribution for home gardening, as announced by your company on your website, is tantamount to human experimentation.

We would like to ask you a few questions about your explanatory materials and your thinking. We will publish your response on our website.

The biggest concern about GM crops is the production of unexpected harmful substances due to unintentional genetic mutations that occur in the process of genetic engineering. In relation to this, we would like to ask the following questions:

(1) In the explanatory materials, you say that you searched for off-target candidates using two methods and investigated mutations in areas common to both methods.

(2) Instead of narrowing down the off-target candidates, you should check all the genes to see if there are any off-target cases.

(3) In the description of the allergen confirmation, there is a phrase “where mutations were identified in the target sequence and off-targets,” which contradicts the explanation in the previous section that there were no off-targets.

(4) Allergen identification was performed only for the locations where mutations were identified in the target sequences and off-targets.

(5) Tomatin was analyzed and it is stated that “Since tomatin did not increase, it is assumed that the analogues of tomatin and other alkaloids did not increase as well.”

(6) Please disclose which substances were analyzed for changes in composition compared to the pre-genetically engineered crop, and what the results were.

2. We believe that the “substantial equivalence” assessment of genetically modified crops is not a guarantee of safety because it does not confirm the production of the unexpected harmful substances mentioned above. Genome edited crops are not subjected to “substantial equivalence” review, but it is tantamount to human experimentation to use them for food without any confirmation of safety. In relation to this, we would like to ask the following questions:

(1) An antibiotic resistance gene is used as a marker gene, and a cauliflower mosaic virus gene is used as a promoter gene. What kind of research has been conducted on the effects of these genes, which may lead to unexpected genetic mutations?

(2) Do you have any plans to conduct animal experiments to confirm the safety of the product?

(3) In the explanatory materials, it is stated that the recommended intake amount will be indicated when the product is put on the market, but how do you think it will affect pregnant women, people with underlying diseases, and infants with an underdeveloped blood-brain barrier?

(4) Do you think that consumers who apply for the free distribution of genome edited crops for home and garden use will do so after learning about the risks pointed out by consumer groups? Or will they only apply based on your explanation of safety?

(5) How do you plan to understand the health effects of high GABA tomatoes?

This genome edited tomato was developed as a national project. Since the taxpayers’ money has been invested in this project, there should be social responsibility based on this. We would like to ask a few questions regarding this point:

(1) How much funding was provided by the government?

(2) Why are you rushing to market before you have a social consensus?

(3) How much of your budget is used to acquire intellectual property rights?

(4) Please stop the free distribution of high GABA tomatoes without sufficient safety confirmation.

* GABA = Gamma-AminoButyric Acid

Read more about the GABA tomato over at Citizen’s Biotechnology Information Center Japan’s first genome-edited food item, a tomato, gets green light for distribution

New Booklet: Food Additives

Processed foods are an indispensable part of most consumers’ daily diet. They are convenient, but in fact, they contain many food additives. There are many problems with additives, such as concerns about their safety, or the fact that they are used in Japan even though they are banned in other countries. The booklet consists of two parts: “Basics” which introduces the actual situation of food additives, and “Individual Foods” which summarizes what is used and what are the problems in individual foods. Please keep this booklet at hand and take the first step toward a diet that reduces additives. It is also an ideal textbook for study groups.

Language: Japanese

Price: 500 Yen

64 Pages

Order here (PDF)


Japan Resources – 179

Please click here for our latest English newsletter: CUJ JR 179

We hope you will continue to stay updated with CUJ’s activities and news on our English website, and support our campaigns!


From the Editors: Staying Safe, and More

Open Letter of Inquiry Regarding the Handling of Genome-Edited Foods

New Booklet: Glyphosate

Wild-Growing Canola Still a Problem

Questionnaire Regarding Vaccination Against COVID-19


Report: Current status of New & Emerging GM Technologies in Japan and Consumer Reactions

This is a brief report on the current status of new and emerging GM technologies, including genome editing, in Japan. We also want to highlight the debate and protests that are ongoing regarding such technologies. Consumers Union of Japan has concluded that we do not want to be unknowingly exposed to food artificially created in this way, and that we do not need such genome-edited food.

Click here to down load the report (PDF): 20201202 Report Genome Editing in Japan