The National Grain and Feed Association (NGFA) and North American Export Grain Association (NAEGA) urged the Obama administration to address the marketability of biotech-enhanced crops in international and domestic commerce as it develops a long-term strategy for modernizing the U.S. regulatory system governing biotech-enhanced products.

In a joint statement submitted to the Federal Register No. 12 and presented at an Oct. 30 public meeting, the NGFA and NAEGA said that to create a "truly workable biotech regulatory framework for the future," the U.S. government "needs to address the challenge of achieving regulatory coherence and compatibility in the global part of a broad trade-facilitation initiative." The NGFA and NAEGA said that "regrettably," it does not appear the U.S. government plans to address these issues as part of its review of the U.S. biotech regulatory framework, which they said would be a "missed opportunity."

The public meeting was the official launch of the Obama administration's effort to update the so-called coordinated framework for regulation biotechnology that involves the White House Office of Science and Technology, Food and Drug Administration, U.S. Department of Agriculture and Environmental Protection Agency. 

The NGFA and NAEGA said a trade-facilitation discussion with foreign governments should focus on:  1) increasing predictability and reducing current disruptions in trade that can occur when a biotech trait is approved under a science-based regulatory system in the country of export, but not yet by one or more importing countries, including establishment of a low-level presence policy given the impossibility of achieving a zero tolerance; 2) establishing appropriate regulatory oversight of biotech traits that have functionally different output characteristics that make their presence in the food or feed system inappropriate above a specific threshold level; and 3) addressing current and future innovation, including how new non-transgenic breeding techniques will be addressed by U.S. and international government entities.

"A broad and effective trade-facilitation effort has been made even more essential by the increasing lack of coherence in various nations' regulatory systems regarding safety reviews and approval of new biotech-enhanced events - combined with the increasing practice of biotechnology trait owners to release into commerce new events before obtaining import approvals..., as well as unknown conditions for retirement of these technologies," the NGFA and NAEGA testified.  "There is no shortage of documented cases in which access of U.S. crops to markets has been disrupted or stopped entirely, resulting in significant downward pressure on prices paid to farmers and reducing the economic value of U.S. agricultural production. Are we prepared to have the United States relegated to being the world's residual provider of agricultural products like corn and soybeans, where we have a distinct comparative advantage?  That certainly is not what the President's Export Council envisions with its goal of doubling exports when the majority of our trade surplus value consists of agricultural commodities."

As part of the U.S. government's review of its biotech regulatory system, the NGFA and NAEGA asked how the new biotechnology platform included in the Trans Pacific Partnership (TPP) Agreement could be leveraged to bring about increased international coherence and compatibility when it comes to science-based systems for reviewing and approving biotech traits; and how a restructuring at the U.S. Department of Agriculture to create a new undersecretary position focused on trade-related issues should be integrated into a comprehensive approach to facilitate U.S. government communication and trade-facilitation efforts with foreign governments.

"We believe this review needs to be much more than a 'check-the-box' activity," NGFA and NAEGA said.  "Rather, it needs to encompass a robust review to address the marketability issues and trade facilitation policies that are essential to food security and the future economic growth of all sectors of U.S. agriculture."