On February 21, 2019, Consumers Union of Japan submitted the following public comment in response to the Japanese government’s GM Food, etc. Investigative Panel of the Pharmaceutical Affairs and Food Sanitation Council, Ministry of Health, Labour and Welfare (MHLW) regarding the handling of food modified by genome editing.
Consumers Union of Japan is working for a sound and healthy future for all. This is why we are active in protecting our surrounding environment and the safety of our daily food. We believe this is what the Japanese government also wants. However, there are reports that the government has concluded that the Food Sanitation Law will not apply to food obtained through genome editing, thus giving up the important focus to protect the environment while also protecting food safety. CUJ finds this unacceptable. Therefore, we request that you withdraw the report and redo the deliberation from the beginning.
These are our reasons:
- It is not possible to avoid off target influence and mosaic effects through genome editing. There are numerous studies that confirm this. The current conclusion contradicts data about such influences and effects by treating them in an overly optimistic way. After a serious change has occurred it will be too late to take action.
- Through genome editing, epigenetic changes (heritable changes in gene expressions) have been reported to take place, something you hardly mention in your report. We can’t help wondering if you are simply imagining that such a problem cannot happen.
- When inserting genes, and then removing them during the crossing stages, we assume that regulation is required. But even if the introduced genes are removed, there is no guarantee that they have been removed 100%, and that there does not remain any influence. Moreover, we have not heard that any safety studies have been done to make sure that such practices actually work as intended or that safety can be secured. We have big misgivings about the advancement of such technologies while the scientific basis appear to be so weak.
- The process of dealing with this by the Food Sanitation Law was compared to the safety examination of genetically modified food. Genome editing is also a genetic technology, but it differs fundamentally from DNA recombination technologies. Many more and various new vegetable or plant breeding experiments will now take place. New legal restrictions are needed for this. We cannot accept that no effort will be made to maintain the safety of our food supply by the government’s current policy approach.
- The Food Sanitation Law has a huge influence also on how food is labelled. If the labelling requirements are affected by the current conclusion, and no labelling is required, it will remove the consumer’s right to know and choose. This is a large and important responsibility for the Ministry of Health, Labour and Welfare.
Consumers Union of Japan
Nishi Waseda 1-9-19-207