CIS countries legislation on the issue of genetically modified products
CIS COUNTRIES LEGISLATION ON THE ISSUE OF GENETICALLY MODIFIED PRODUCTS
Prof., Dr. Vugar Mammadov
Head, Bioethics & Medical Law Dept., Institute of Human Rights, Azerbaijan National Academy of Sciences*; Head, Azerbaijan Unit, UNESCO Chair in Bioethics
Dr. Aytan Mustafayeva
Director of the Institute of Human Rights, Azerbaijan National Academy of Sciences
ABSTRACT: Gen engineering is a fast moving research field producing lots of achievements, including genetically modified organisms used during production of food products. Last decades show that scientists, policy makers and general public could not come to the same opinion about benefits and hazards of genetically modified food products. Opinions are so different and both-side well-grounded that it is not easy to define attitude to this scientific achievement. Nevertheless, food security is one of the main objectives of the state, which is responsible for providing in the markets safe food products to own citizens. This is why states are interested in reviewing the scientific achievements in terms of the state’s national interests and security of its citizens. In this article 1/ main advantages and disadvantages of genetically modified products, 2/role of national legislation on control of food security, 3/attitude of CIS countries national legislations to genetically modified products are given. Taking into account these points authors come to conclusion that actual Azerbaijan law is not-responding to changes of world market development and technological conditions of food products production, having place in last decades. This gives the basis to conclude that in actual conditions rights of Azerbaijan citizens for safety of food products are not well-protected. In the end of study authors come to recommendation about necessity of amendments to own legislation towards increasing control on turnover of such products in Azerbaijan.
KEY WORDS: Genetically modified organisms; genetically modified products; food products; food security; national legislation; food legislation
Food safety. Some time ago this term was not used so often as today. Nowadays, it is generally and often used by politicians, scientists, journalists and general people as it is important element for insuring human right for life and health. Thus, it is representing enormous political factor. The Rome Declaration on World Food Security, adopted on the World Food Summit on November 13-17, 1996 refers to the duty of the member state to ensure the right of everyone to have access to safe and nutritious food, in accordance with the right to adequate food and the right to freedom from hunger.
Food security is one of the main objectives of the agrarian and economic policy of a state. In its general form, it generates a motion vector of any national food system to the ideal state. In this sense, the pursuit of food safety is an ongoing process. One of the strategic components of food safety is the safety and quality of food - an integral part of existence, prosperity and quality of life in the country. Due to constant change and development of the global market and technological conditions of food production (the emergence of new food products, dietary ingredients and dietary supplements, the accumulation of pesticides and veterinary drugs, genetically modified technology, etc.), as well as due to various partially undisclosed reasons it is now possible to observe the trend that is developing in the world: the growth of numerous different issues of food safety (food allergies, sensitivity to foods, foodborne illness, intoxication) and the deterioration of their consequences. Following the recent grocery scandals, provoking a massive and extensive reaction of the press (dioxin, Avian Flu, Foot-and-Mouth Disease and other zoonotic diseases), sharply increased the expectations and terms of food safety.
Consumers rightly expect from their governments responsibility for safety of food products sold in the shops and supermarkets, restaurants and fast food places. Consumers have an inalienable right to expect that, as a minimum, all food sold in the markets is safe. Government, in its turn, sets a goal, and should do so, a goal to supply the safest food, and to develop a system by which these objectives will be achieved. A key element in this system is certainly a national legislation on food. “Safety of food products” term is reflected in all CIS laws as relevance of food products to the requirements of state standards, technical conditions, sanitary, veterinary and fitosanitary rules and norms that prevent any harm and danger to human during their usage, to life and health of present and next generations. Each CIS country has relevant law about food products that is key element in national legislation to secure national food safety. In Azerbaijan, the main instrument in this area is the Law of the Azerbaijan Republic on "food" from 18 November 1999with accepted changes from November 23, 2001, 03 December 2002, December 5, 2003, April 17, 2007, 16 and 30 December 2008 year.
Genetically modified organisms (GMO) have become a highly debated issue in current time. Many countries do a lot of research in this area and develop new GMO. A big part of the development is directed on modification of different food products. However, still there is no scientific consensus on whether the GM food is harmless or harmful for humans, animals and/or environment. In other words, GMO becomes an issue of food safety. Without scientific consensus it is therefore hard to say for sure how a state should address this issue. Currently, different states have taken different positions. One have allowed GM products on their markets, others have banded them. There are also countries that still haven’t addressed the issue of GM products at all in their legislations. This article will look into legislations of CIS countries with aim to make comparative analysis of laws about food products of different CIS countries for the subject of their attitude toward genetically modified food products. These countries all had the same legislation some twenty years ago, but have developed in different directions. However, before starting to analyze legislation we would like to stress what is GMO and which advantages/disadvantages it has nowadays by opinion of leading scientists and politicians.
WHAT IS GMO?
GMO is an organism where the genetic material has not been modified through natural mechanisms but through genetic engineering. Individual genes, selected due to their superior qualities according to the choice of the creator are transferred from one organism to another, even between individuals belonging to different species, both animal and vegetable.
Across the world, attempts at regulating the processes and products of recombinant DNA technologies, including genetically modified organisms (GMOs) had their origins in the famous Asilomar Conference in 1975. In this conference, scientists who had been involved in developing these revolutionary technologies gathered to discuss the potential dangers of creating GMOs, and they decided to implement a self-imposed moratorium on such research until more details became available from carefully planned experiments on the potential risks and consequences of the GMO technologies. However, GM foods were first put on the market in the early 1990s, in USA.
Proponents of commercialization of GM products put accent on the fact of world population has topped 6 billion people and is predicted to double in the next 50 years. Ensuring an adequate food supply for this booming population is going to be a major challenge in the years to come. GM foods promise to meet this need in a number of ways. Arguments in favor of GM foods - high crop yields, resistance to diseases, insects and harsh weather, and their low price (they tend to cost 20-30% less than traditional foods). So what are main advantages of GMO?
Some of advantages of GMO
Pestand disease resistance is one of the most important advantages.There are many viruses, fungi and bacteria that cause plant diseases. Farmers typically use annually many tons of pesticides and other chemicals. Run-off of agricultural wastes from the use of pesticides and fertilizers can cause harm to the environment by for example poisoning the water supply. Moreover, consumers usually are against purchase of food that has been treated with chemicals because of potential health hazards. Furthermore, harvest losses from insect pests and diseases can be staggering resulting in vast financial loss for farmers, increase of food prices and starvation in countries which are dependent on agriculture. Therefore, growing GM crops can help eliminate the application of chemical pesticides, reduce the cost of bringing food to market and uphold a good harvest. Similar argument can be used to promote herbicide resistant crops. Often it is not cost-effective to remove weeds by physical means such as tilling; therefore large quantities of different herbicides are spread in order to destroy weeds. Through genetic engineering, plants can be created to be resistant to very powerful herbicide. This resistance reduces not only production costs but also helps prevent environmental damage by limiting the amount of herbicides needed.An antifreeze gene makes plants able to tolerate cold temperatures that normally kill unmodified seedlings. Frost resistant crop increases possibility to get good harvest and enables cultivation through longer period of time during a year. This concerns also plants that are created to withstand long periods of drought or high salt content in soil and groundwater. Such modification of plants can help people to grow crops in formerly inhospitable places, which is very beneficial in a time when the world population grows rapidly and more land is utilized for housing instead of food production.
Gene modification can also be used for the purpose of enrichment of a fruit or vegetable with healthy features. For example, in many countries nutrition consists mainly of a single crop, e. g. rice. However, such crops do not contain adequate amounts of all necessary nutrients to prevent malnutrition. If it would be possible to genetically engineer a crop like rice to contain additional vitamins and minerals, nutrient deficiencies could be alleviated. Moreover, with gene modification it would be possible to develop edible vaccines and medicines in e.g. vegetables. Such vaccines would be much easier to ship, store and administer than traditional injectable vaccines. This would limit costs for the production, storage and distribution and enable better possibilities for vaccination in less developed countries.
Some of disadvantages of GMO
As we have shown above, purpose of genetic modification is to improve quality of food, by e.g. using fewer chemicals; to lower costs of production thereby making food accessible for more people; to protect environment and many more advantages. However, as many new technologies there are risks of unintended potential harm. It is this potential harm that is very important to foresee. For sure, consequences of production of GM food will be known after many years. For example, today we cannot with accuracy predict how GMOs can affect future generations. GM foods are dangerous because they are unpredictable. Scientists do not know what effect they will have on the human body in the long term. Nevertheless, it is important to discuss possible disadvantages of GMO. It is important not only from the scientific point of view, but also in relation to the need for legal regulation on the issue.
Generally, one can discuss three kinds of unintended potential harm from GMOs. First, there is a risk for the health of researchers and workers who are involved in the development and distribution of GMOs and their products. Second, GM products inflict health hazard to humans and animals who are the direct consumers or users. Third, there is possible harm to environment and fauna from the large scale cultivation of GM plants. Moreover, there might be hitherto unknown risks that have not been discussed yet.There is even one more aspect of the downside of the GMO production – an economic one. The question is whether advantages of a GM product production are commensurate with the cost of development of such product.
Environmentalists say that GM foods will not solve the problem of world hunger, but they will bankrupt small farmers. Environmental activists, religious organizations, public interest groups, professional associations and other scientists and government officials have all raised concerns about GM foods, and criticized agribusiness for pursuing profit without concern for potential hazards, and the government for failing to exercise adequate regulatory oversight. Numbers biologists believe that GM foods can have a negative effect on the gene pool and reduce biological diversity. It seems that everyone has a strong opinion about GM foods. Even the Vaticanand the Prince of Waleshave expressed their opinions in media. In 2000, 828 scientists from 84 countries signed an open letter to the world's governments warning them of the hazards of GM foods. Environmental organizations demanded that the UN declare a moratorium on GM products.
Most concerns about GM foods fall into three categories: environmental hazards, human health risks, and economic concerns.
Human health risks
Both first and second kinds of hazard, as we have divided them above, regard human health. However, we consider only the second kind infliction of health hazard to humans who are the direct consumers or users. It is in this aspect that the states responsibility of food safety sets in.
Already many people suffer from life-threatening allergies. There is a possibility that introducing a gene into a plant may create a new allergen or cause an allergic reaction in susceptible individuals. Extensive testing of GM foods may be required to avoid the possibility of harm to consumers with food allergies. Even bigger risk poses a growing concern that introduction of foreign genes into food plants may have an unexpected and negative impact on human health. People can get less resistant to diseases, GM products might make changes in the function of the human body and there is even a risk of change of human genome. Such negative effects might be seen not only on the people who consume GM products, but also on the health of next generations.
One of the leading modifications of food crops is Bacillus thuringiensis (Bt) toxin genes inserted into genetically modified crops. Unfortunately, Bt toxins kill many species of insect larvae indiscriminately; as it seems today, it is not possible to design a Bt toxin that would only kill crop-damaging pests and remain harmless to all other insects. However, this topic is the subject of acrimonious debate, and the potential risk of harm to non-target organisms will need further evaluation.
Another environmental hazard might be reduction of pesticides effectiveness. Just as some populations of mosquitoes developed resistance to the now-banned pesticide DDT, there are concerns that insects will become resistant to Bt or other crops that have been genetically-modified to produce their own pesticides.
One more concern is that introduced genes may cross over into non-modified crops planted next to GM crops. This might result not only in uncontrolled growth of cross-breed crops without the possibility to oversee consequences but also in intellectual property infringement cases in the situations where the GM crop might be protected by a patent. Moreover, crop plants engineered for herbicide tolerance can cross-breed with weeds, resulting in the transfer of the herbicide resistance genes from the crops into the weeds. These “superweeds” would then be herbicide tolerant as well.
A more predictable disadvantage is economical side of the issue. To create a GM crop and to put it on the market is a lengthy and costly process, and of course agri-biotech companies wish to protect their intellectual property rights and ensure a profitable return on their investment. Patent infringement is a big concern of agribusiness and patent enforcement may be difficult due to the possibility of natural cross-breed. Moreover, there is a risk that patenting will raise prices of seeds so high that small farmers and third world countries will not be able to afford seeds of these new kinds of plants. This will not only widen the gap between the wealthy and the poor but also will diminish several advantages of the GM food. One of them is the possibility to improve nutrition in many countries through auditioning vitamins and minerals to the crop that is the primarily source of food. Another is the possibility to develop edible vaccines and medicines in e.g. vegetables which would be much easier to ship, store and administer.
“FOOD SAFETY” IN CIS
The Commonwealth of Independent States (CIS) is a regional organization whose participating countries are former 12 Soviet Republics, except Baltic States. Since all the countries have earlier been part of one legal system, judicially they had the same platform for development. Therefore a comparison of the current legislation in these countries poses a great interest. Judicial changes reflect government’s and people’s attitude towards e.g. scientific development.
Overall, one could say that CIS countries’ laws define several state policies that are common for all the countries. All of the CIS states are aiming on the realization of state policy on providing country’s population with good quality and safe food products. This is done mainly by prevention of production and import of bad quality and dangerous food products on the territory of the country. There are requirements of certification and standardization as well as organization of actions for unified state system of supervision and control of the market. Nevertheless, discussion on the issue of food safety is relatively new. The term “food safety” ten years ago was not as urgent as today. Consumers expect safety of food products sold on the market. The primary responsibility for it lies on the government, which shouldinsure human right for life and health. The notion of “safety of food products”, being a strategic component of “food safety”, is reflected in all legislations of CIS countries as requirement to food products to correspond with specific state standards, technical conditions, sanitary, veterinary and fitosanitary rules and norms. Such standards, rules and norms are aimed on prevention of any harm and danger to people during usage of different products and on guaranteeing of concern for life and health of present and next generations. In every CIS country there is a relevant law that is a key element in national legislation on insurance of national food safety. The laws that have been analyzed in this study are as followed:
- Law of the Republic of Azerbaijan "On Food Products" of November, 18 1999, with accepted changes.
- Federal Law N 29-F3 of the Russian Federation “On the Quality and Safety of Food Products” of January 2, 2000
- Law of Ukraine № 2809-IV “On the Safety and Quality of Food Products and Food Raw Materials” of with changes from September 6, 2005
- Law of the Republic of Belarus № 217-Z of June 29, 2003 “On the Quality and Safety for Human Life and Health of Food Raw Materials and Food Products”
- Law of Georgia № 2212-IIs “On Food and Tobacco” of June 25, 1999 and “On the Quality and Safety of Products” of the year 2005
- Law of the Republic of Armenia “On the Safety of Food Products” of December 30, 1999
- Law of the Republic of Kazakhstan № 301 “On the Safety of Food Production” with the changes of July 24, 2009
- Law of the Republic of Turkmenistan №31-IV “On the Quality and Safety of Food Products” of April 18, 2009
- Law of the Republic of Uzbekistan “On the Quality and Safety of Food Products” of August, 30 1997
- Law of the Republic of Tajikistan “On the Quality and Safety of Food Products” of May, 10 2002
How mentioned laws regulate food safety and what is the government's role in this process? All the laws are more or less similar in definition of state policy on providing quality and safety of food products (from CIS laws):
- realization of state policy on providing country’s population by good quality and safe food products, on prevention of production and import in the territory of the country of bad quality and dangerous food products;
- realization of citizens rights to use good quality and safe food products;
- legal regulation of relations in the field of providing quality and safety of food products;
- planning and realization of state purposeful and scientific-technical programmes on providing quality and safety of food products;
- state certification, standardization and insertion of norms in the field of providing quality and safety of food products;
- formation and organization of activities of unified state system of supervision and control in the field of providing quality and safety of food products
How do they reflect GMO and genetically modified products? Different. Generally the ways of regulation of the GM products in CIS countries can be divided into three groups:
1/ with completely revised and re-new legislation about food products where attitude to GM products reflects well controlled regulation (Kazakhstan and Turkmenistan);
2/ with amended GMO-related legislation but not well controlled regulation yet (Russia, Belorussia, Ukraine, Moldova) and
3/ old legislation not reflecting attitude to GMO products that permits uncontrolled turnover of such products within the countries (Azerbaijan, Georgia, Armenia, Uzbekistan, Tajikistan, Kirgizia).
CIS COUNTRIES LEGISLATION
As mentioned above, Kazakhstan’s legislation is one of the two completely updated legislations on the issue of GM products. The Law on the Safety of Food Production is clear and detailed. The law defines genetically modified objects as products and raw materials of animal and plant origin received with usage of gene engineering methods, including genetically modified sources, organisms (point 7 of article 1). In the article 5 is stated competence of Kazakhstan government. Among other things under point 5 the government is given competence for the affirmation of rules on turnover of genetically modified objects and on prosecution of work on scientifically justified confirmation of safety of genetically modified objects. In article 6 states that it is competence of health and sanitary-epidemiology plenipotentiary authorities to make state registration, re-registration and take registration back for genetically modified objects. In article 8 point 2 states that in purposes of implementation of state control of food products safety state ensures organization of activities of state veterinary-sanitary and sanitary-epidemiologic expertise laboratories, including laboratories for determination of quantitative and qualitative content of presence of genetically modified objects, in accordance with international requirements to their equipment and personnel. According to article 9, production, import and realization of genetically modified objects are permitted only after their state registration, excluding cases of production and import done for implementation of registration tests. State registration includes insertion into state registries genetically modified objects, permitted for production and import. Moreover, all firstly produced and imported genetically modified objects must undergo state registration. Point 5 of article 12 permits turnover of genetically modified products only after state registration and scientifically justified confirmation of their safety, which is carried out in accordance with the legislation of the Republic of Kazakhstan. Article 13 forbids usage of raw materials produced by usage of animal’s growth stimulators (including hormones) and genetically modified objects in the production of special food products such as baby, diet, treatment-prophylactic food. According to article 17 information on the content of genetically modified objects in food products must be declared in documents, on packages, information leaflets, labels, stickers and be in Russian and Kazakh languages. Permitted level of content of genetically modified objects in food products must not be higher than in permitted content in the European Union. However, this is only until confirmation of safety of genetically modified object in food product is scientifically justified (see article 34).
Turkmenistan’s legislation is second one of the two completely updated legislations on the issue of GM products. However, the legislator has taken a more, as one could say, radical path and has prohibited GM products in the country. Article 9 requires that all food products that are imported for the first time must be registered by the state on the basis of documents of the producer and relevant state authorities of Turkmenistan that confirm quality and safety of these products. If necessary, the importer is obliged to submit samples, technical documents, results of laboratory tests, declared content and actual content of certain substances, formal statement of producer about presence or absence of genetically modified sources (organisms) and/or other documents. State registration is not permitted for products containing narcotic, psychotropic substances, precursors and their analogs as well as genetically modified sources and other substances dangerous for human life and health.According to article 16 it is forbidden to use genetically modified sources under production of food products. Article 21 forbids import and distribution in the country of food products produced by usage of genetically modified organisms. Producer must inform if under production of the food supplement genetically modified organisms (sources) have been used (article 22). Article 25 states that food products must be recognized as bad-quality and dangerous for human life and health and cannot be in turnover in several cases, among others is if genetically modified sources have been used under their production.
The Law on the Quality and Safety of Food Products of Russian Federation does not provide any definition of the notion GMO. Article 5 gives requirements of information given to state bodies and consumers about quality and safety of food products. The article states that physical and juridical persons implementing activities in production and turnover of food products must inform consumers and state control authorities about quality and safety of their products, their compliance with certain normative documents. These documents state among other things, that if the content of GMO in the product exceeds 0.9 % it must be indicated on the package. Cultivation of genetically modified plants is banned in Russia. However, the rule that products containing more than 0.9% GM ingredients must be labeled in practice is often ignored and according to this rule, if the GM percentage in a product is less than 0.9%, the producer is entitled to mark it as a GM-free product. Currently, there are 16 types of GM food products that are allowed in Russia – eight types of maize, six types of potato, one type of rice and one variant of sugar beet. According to an All-Russia Public Opinion Research Center poll 95% of Russians who have heard of GM foods would not buy them if the products were labeled as such. Consumers, however, are still not able to exercise their right to choose. However, different regions of Russia can adapt additional regulative norms to all-Russian legislation like legislative amendments in the Moscow region for example:
- all agricultural raw materials or foods that are brought to Moscow through an organized supply system must contain information about their GM ingredients
- it is illegal in Moscow to use budgetary funds to buy GMO containing baby food.
The Belorussian Law on the Quality and Safety for Human Life and Health of Food Raw Materials and Food Products defines GM food products and raw materials as food products and raw materials that are received by methods of gene engineering from genetically-engineered organisms or with their usage. Article 10 states that information about quality and safety of food products, food supplements and raw materials must be in accompanying documents, on the packages, labels or delivered to the population by other way. Such information must state, among other things, if the product is genetically modified or contains genetically modified components.
The Ukranian Law on the Safety and Quality of Food Products and Food Raw Materials defines GM food products and raw materials as food products and raw materials received by methods of gene engineering from genetically-engineered organisms or with their usage. Article 38 provides that all food products that are in turnover in the country must be marked in state language of Ukraine and contain easily understandable by consumer information, including information about presence or absence of GMO, which should be reflected by labels “with GMO” or “GMO free”. 2009 amendments stipulate that all food products (except tobacco products and homemade food) shall be labeled either “GMO” or “GM-free”. Though, there is no regulation on a quantitative threshold for the presence of GMO. Amendments give also mandate to the government to develop and implement the procedure for registration of GMO and products derived from them. However, reaction of the food industry is alarming and new amendments are expected.
Most of the laws that have been analyzed in this article are relatively new and address issue of GM products. As we have shown above, turnoverand distribution of the GMO-containing products is allowed in CIS countries, apart from Turkmenistan. Half of CIS countries have adopted fundamental changes and made amendments on the subject of GMOs. Their legislations require that only after science-based evidence of a product’s safety and with submission of full information and assurances of quality and safety the product may be allowed on the market. Unfortunately, apart from others, legislations of 6 countries differ as they completely ignore any relation to food products containing GMOs. As result of this, turnover of GMO containing foods is absolutely free and non-controlled in these territories, including Azerbaijan. It means that GMO products which can’t be imported in well-controlled European and CIS countries may easily re-directed towards us representing big health, environmental and economic hazards for Azerbaijan. Institute of Human Rights of Azerbaijan National Academy of Sciences has prepared a number of legal recommendations on updating or amending existing Azerbaijan legislation on food products that were
approved by the Expert Council of the Institute and transmitted to the relevant parliamentary committees (on human rights, on social issues, on economic development, and on agricultural issues). The main recommendation is banning turnover of GMO products in Azerbaijan territory. We understand that a blanket ban of GMO-containing products is a last resort, but a total ban seems to us to be the most proper way of protection of the rights of our citizens in the absence of any safeguards for the health of future generations on the part of manufacturers, scientists, and states-exporters. Our recommendation is based on following arguments:
- risk of hunger - one of main needs for production of genetically modified products - is not existing in Azerbaijan, which has rich agricultural lands and resources and not relatively big population (about 9 millions inhabitants;
- historically Azerbaijan was producing and exporting a lot of natural agricultural products to CIS countries and till now markets of Russia, Ukraine and others are supplied by natural fruits and vegetables from Azerbaijan. Uncontrolled turnover and further cultivation of GMO products in Azerbaijan may lead to destructions of our natural plants and agricultural harvests;
- Azerbaijanhas unique biodiversity conditioned by number of factors, particularly due to the diversity of altitudes, climatic zones (9 out of 11 exist in this not very big country) and landscapes; uncontrolled turnover of genetically modified products plays against this biodiversity;
- Agriculture is an important factor in national economy because of the jobs and incomes it provides and because it is often an important source of hard currency; in Azerbaijan the system of agricultural food products is one of the most important sectors of the economy, has a crucial role in the improvement of Azerbaijan’s overall social and economic situation and ensuring its food products’ safety; uncontrolled import of cheap genetically modified products plays against local farmers and development of national agriculture;
- Relevant state bodies are not equipped well by GMO-detecting equipment and specialized laboratories that can identify GMO and their amounts in the importing products;
- Absence of clear scientific evidences about safety of genetically modified products for the health of present and next generations
- Most of countries in Europe and world-wide have strengthened controlling measures on genetically modified products turnover within own territories during last decade that is related with increasing awareness about negative hazards of their large spread;
- Azerbaijanwill not be only country with banning GMO turnover in own territory. Such a radical position for products containing GMOs is already marked today in several countries - Switzerland, Austria, Poland and Turkmenistan.
However, millions of people in all over the world, including Azerbaijan population, already consume such products, remaining ignorant, while scientists around the world argue about dangers and benefits of these products. And every state is interested in reviewing the achievements of science in terms of the state’s national interests and security of its citizens. And this interest is reflected in development of legislative and regulatory acts that we believe are created in the notion of bioethics. If we wish to enjoy all the benefits emanating from the development of science, it is necessary to create effective legislative tools as well as define rights and obligations of a state, researchers, investors and citizens. Several decades and generations that have been eating GM-products should pass in order to fully understand all risks of the consumption of transgenic products.
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