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GENETICALLY MODIFIED FORAGES




Genetically Modified Forages
Emerging Issues
Summary                                                            Changing drivers for genetic modification in agriculture
The past decade has seen both global growth of the use of          Fifteen years ago, intense public interest about the
genetically modified (GM) technologies in agriculture and          management of genetic technologies led to the creation of
increasing concern over the ability to maintain adequate           the Independent Biotechnology Advisory Council in 1999,
food production.                                                   followed by the Royal Commission on Genetic
                                                                   Modification report in 2001. The Commission
New Zealand research into genetically modified forages             recommended that New Zealand “should proceed
has led to plants with traits that, when grown in                  carefully, minimising and managing risk”. 1 That finding
containment, offer improved performance over                       contributed to a period of continuing but less intense
traditionally-bred lines. Improved forage performance can          concern around genetic modification.
be delivered by both transgenic (using genes from other
species) and cisgenic (using genes from the original species)      Since then, issues of food production and food security
methods. Cisgenic transformation may be more socially              have grown in significance internationally.2,3 For this
acceptable, but many believe that the benefits and risks           country a number of factors have arisen that may influence
depend more upon the traits themselves, not upon the               opinion about the release of genetically modified forages.
sources of the genes that deliver the traits.
                                                                   These include:
The use of genetically modified forage could increase farm               Ongoing intensification of pastoral farming and the
productivity, drought resistance, and reduce greenhouse                   need to transform the sustainability of agriculture
gas emissions intensity. However, the release of genetically             Increasing costs of farm inputs, e.g. fertiliser and
modified organisms is at variance with identities and                     fuel, and the corresponding concerns about the
values that many New Zealanders hold dear.                                potential limits of ‘business as usual’ agriculture
                                                                         Mitigating agricultural greenhouse gas emissions
In overseas markets, some consumers retain a preference
                                                                         Adapting to climate change, e.g. more frequent and
for non-GM products but such opposition is decreasing.
However, research on social and market acceptance is                      intense droughts
largely limited to the European market. These issues are                 Growing competition from low cost producers
seen as less of a concern for animal feed than for human                  overseas
food.                                                                    Increasing animal welfare concerns, particularly the
                                                                          nutrition of pasture-fed animals
The scope of this paper covers the technologies and drivers              Improving precision of GM techniques
associated with the development and use of genetically
transformed forages that are of interest to New Zealand’s
pasture-based industries. The pastoral sector is an area
where New Zealand research is world-leading. The intent
of this document is not to make recommendations, but to
inform discussion on the benefits, risks, and acceptability of
the use of these technologies.




1 ”Report of the Royal Commission on Genetic Modification”, 2001 3 “Agriculture at a Crossroads”, International Assessment of Agri-
2 “Reaping the benefits: Science and the sustainable intensification cultural Knowledge, Science and Technology for Development,
of global agriculture”, The Royal Society of London, October 2009 2008


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GENETICALLY MODIFIED FORAGES




                                                                                 >10 million ha
                                                                                 >1 million ha
                                                                                 >50,000 ha
                                                                                 <50,000 ha


Figure 1: Nations using genetically modified crops. The majority of GM crops are grown in the US, Argentina and
Brazil.4

Many researchers believe that traits influence risks and              based approach, although these countries show differing
benefits more than the techniques used to deliver the trait           degrees of precaution. New Zealand legislation
A trait is a distinct variant of the observable characteristics       differentiates between GM and non-GM methods of
of an organism. An example of this is blue or brown eyes.             modification prior to assessing the effect of new traits.
Commonly used traits in commercial crops that have been
manipulated by genetic modification are those for                     Many believe trait evaluation should be carried out on a
herbicide tolerance and insect resistance.4                           case-by-case basis
                                                                      When new traits are introduced, they enter dynamic and
In brief, consideration of genetic modification 5 broadly has         complex systems. These systems range from the
three components: (i) the nature of the trait being                   biochemistry and physiology of the plant, the ecosystem of
introduced and how it is expressed, (ii) the technique being          the soil and pasture, through to the wider local
used to introduce the DNA encoding the trait into a host’s            environment, the farm business system and ultimately, the
genome and (iii) the source of the introduced trait-related           national economy. Impacts must be evaluated across all of
genes. Many regulators and members of the public have                 these levels. This multi-faceted evaluation raises a number
focused on the techniques used to introduce new traits into           of questions including:
plants and any resulting effects upon food products, rather                  How much system-level understanding is there
than the traits themselves. This being the case, it is also                   available?
necessary to recognise that ‘conventional’ plant breeding                    How well can outcomes (and risk profiles) for
can be expedited via the use of mutagens to alter a plant’s                   ecosystems, individual agricultural businesses and
DNA to create new base-pair combinations that, by chance,                     the sectors be predicted?
may create a useful trait. This approach is seen by some to                  How well understood are the likely impacts on
be more acceptable than the precise insertion of trait-                       social and cultural responses and New Zealand’s
coding genes into a DNA sequence.                                             market position?
Given the above, the question can be asked whether it is              Extrapolation based on prior experience with currently-
the trait that matters, rather than how it is arrived at. Many        used traits does not provide full information on the possible
of our contributors believe that risk management should               effects of newly introduced traits. Each new trait may have
lean more towards understanding a new trait's functions               widely different impacts, and should therefore be
and implications rather than the method of modification.              considered as a new and separate effect interacting with
Focusing on the technique used, instead of the trait, could           existing components.
create its own risks around incomplete understanding of a
trait’s impacts.                                                      When considering new traits, researchers can sometimes
                                                                      use conventionally bred analogues grown under field
Regulation based on traits rather than techniques is already          conditions to partially assess impacts in place of releasing
in use in Canada with the USA taking a similarly safety-

4 James, C. “Brief 39 – Global Status of Commercialized Bio-       5 Defined here as recombinant techniques as regulated by the Haz-
tech/GM Crops: 2008”, International Service for the Acquisition of ardous Substances and New Organisms Act
Agri-biotech Applications, 2008


www.royalsociety.org.nz                                           2                                                    March 2010
GENETICALLY MODIFIED FORAGES



Categories                        Source of new genes                    Potentially achievable with        Genetic distance
                                                                         conventional breeding?
Cisgenic                          From species genome                    Yes                                Low
Famigenic                         Species in the same family             Maybe
Transgenic                        Unrelated species                      No
Xenogenic                         Synthetic genes                        No                                 High


Table 1: Definitions of genetically modified organisms based upon sources for modified genes 11



genetically modified organisms.6 Such preliminary                         that are modified for pest resistance. This contrasts with
assessment of a trait’s likely effects can aid subsequent field           the prospects of persistent inter-seasonal perennial forages
investigation using the modified organisms themselves.                    with other introduced traits.10 Thus all modifications
There are limits to the extent non-genetic modification                   should be considered on a case-by-case basis.
approaches can replicate the traits delivered by genetic
modification so these approaches will remain useful, but                  Sources of genes: cisgenic versus transgenic modification
incomplete, ways to assess the impacts of new traits.                     In general, barriers between multi-cellular species prevent
                                                                          interbreeding and functional gene transfer. This is seen by
Increasing offshore experience with genetically modified                  many as part of the “natural order”. Genetic manipulation
crops                                                                     crosses these barriers.
Up to fifteen years have elapsed since the US and other
nations began intensive cultivation of genetically modified               There is a continuum of sources of potential genes that
crops, particularly soya bean, maize, and cotton. The area                may be used in genetic modifications. For example, genes
sown reached 125 million hectares in 2008.4 Such use of                   may be acquired from within a species, or from species of
genetically modified technology has been associated with                  increasing genetic distance from the transformed species.
reduced pesticide use and increased farm income from                      Alternatively, genes may be created entirely synthetically
insect resistant maize in parts of the EU7 and from various               by assembling new combinations of base pairs.
other crops globally.8
                                                                          The process of cisgenetic (or intragenic) modification
No evidence has been found of harm to human health2 or                    involves manipulating genetic material only from the
permanent ecological damage.9 This is often taken as                      species being transformed. When genes are sourced from a
evidence in favour of the use of genetically modified crops.              different species, the process is known as transgenic.
However, as has been noted in the consideration of traits, it
is necessary to recognise that if one type of modification or             The implications of cisgenics and transgenics are
group of modifications has been safely and successfully                   sometimes viewed differently amongst scientists,
used, that does not automatically mean that all genetically               regulators, and the general public. Cisgenic transformation
modified crops are safe. By the same token, it cannot be                  may appear to conform more to the “natural order” of
assumed that the products of conventional breeding are                    species isolation and therefore may be more acceptable for
inherently safe. A modification for one purpose may not in                that reason to the New Zealand public.
any way resemble another modification, be it functionally,
biologically, or ecologically. For example, most experience
with genetically modified crops has been with annual crops


6 An example of this approach is the work being carried out by Dr        10 For example, alfalfa is perennial, insect-pollinated, regrows
Anthony Parsons under the FRST contract “Novel Trait-based               quickly, is drought and cold tolerant, and produces dormant seeds.
Assessment”. Earlier work has been published as:                         These characteristics aid gene flow in wild populations. GM alfalfa
Parsons, T., Rasmussen, S., Newton, P., Bergelson, J. “A basis for       has been approved for unconfined release in Canada.
developing a priori assessments of the risks and benefits of novel       Bagavathiannan, M.V. Van Acker, R.C. “The Biology and Ecology
organisms” AgResearch Internal Report, 2003                              of Feral Alfalfa (Medicago sativa L.) and Its Implications for Novel
7 Brookes, G. “The impact of using GM insect resistant maize in          Trait Confinement in North America”, Critical Reviews in Plant
Europe since 1998”, International journal of Biotechnology, 10           Sciences, 28 (1&2); pp 69 – 87, 2009
(2/3); pp 148-166, 2008                                                  Bagavathiannan, M.V., Van Acker, R.C. “The Feral Nature and
Gómez-Barbero, M, Berbel, J., Rodriguez-Cerezo, E. “Bt corn in           Implications for The Co-Existence of Genetically Modified and
Spain – the performance of the EU’s first GM crop”, Nature Bio-          Non-GM Alfalfa”, Department of Plant Science, University of
technology correspondence, 26 (4); pp 384-386, 2008                      Manitoba, 2009
8 Brookes, G., Barfoot, P. “Global impact of Biotech Crops: Socio-       11 Adapted from Nielsen, K.M. “Transgenic organisms – time for
Economic and Environmental Effects, 1996-2006”, AgBioForum,              conceptual diversification?”, Nature Biotechnology, 21; pp227-228,
11 (1); pp 21-38, 2008                                                   March 2003
9 Department of Environment Food and Rural Affairs “Farm
Scale Evaluations of herbicide tolerant GM crops”, 2005


www.royalsociety.org.nz                                              3                                                         March 2010
GENETICALLY MODIFIED FORAGES



Demonstrated and potential benefits of genetically                        gas emissions and nitrogen leaching will also need to be
modified forages                                                          factored in as their reduction will increasingly offer
The Royal Commission referred to the “exciting promise”                   economic as well as environmental value. Some
of genetic modification. Such promise is no longer                        preliminary modelling has shown potential economic
speculative. Forage research now has made demonstrable                    benefit,12 whereas other substantial work predicts that
progress towards the discovery and incorporation of useful                strategies to simply increase market demand will have a
traits. For example, those in ryegrass and clover plants (in              more profitable impact.13 Both approaches may be
containment) now include:                                                 necessary, but the impact of the use of genetically modified
        Drought resistance and improved performance                      technology on demand for New Zealand products will
         under moisture stress that will increasingly arise               always rest with consumers.
         from climate change
        Improved balance of soluble carbohydrate and                     Potential adverse effects of genetically modified forages
         protein levels for increased available energy, higher            Ryegrass is perennial and produces wind-blown pollen.
         productivity, and better nitrogen use efficiency                 Unlike, previous field trials of GM pine trees, it would not
        Higher levels of condensed tannins for the                       be possible to guarantee that there will be no movement of
         elimination of bloat and optimal protein uptake                  genetic material. Flowering cannot be avoided if proper
         leading to less nitrogenous waste and possibly less              agronomic evaluations are to be made of large areas of
         methane production                                               forages. Whilst the vast majority of ryegrass pollen is
                                                                          deposited a few metres from the source,14 viable pollen has
        Changed lipid content leading to higher available
                                                                          been shown to move at least three kilometres.15 Seed
         energy and reduced methane production                            dispersal will also be a concern, with limited information
                                                                          available about possible role of birds and mammals. 14
Other traits under development include:
      Reduced lignin for more digestibility and improved                 Enhanced traits may create potential for more weediness
       nitrogen efficiency                                                where those traits deliver plant persistence and vigour.
      Improved efficiency in the plant's use of water and                Conversely, many traits under development promote
       nutrients                                                          nutritional value to livestock rather than likely adaptive
      Encapsulated lipids to increase the level of omega 3               fitness. Such transformed plants often generate new
       unsaturated fats in the grazing animal, with                       proteins which could incur an increased metabolic cost,
       potential human health benefits                                    reducing overall fitness and thus survival in the wild.
      Improved growth at lower temperatures for
       increased production outside of the peak growth                    The exclusive use of cisgenics limits the potential changes
       period                                                             made to an organism, purely because the range of usable
                                                                          genes is limited to those already present within the species.
If these benefits are realised in production systems, then                This reduces the range of available traits but similarly, may
they should lead to improved feed production and                          limit the risks and the potential for unexpected
conversion, increased tolerance to droughts, reduced                      consequences.16 This limitation has led to the assumption
greenhouse gas emissions, reduced nitrogen intensity, and                 that the greater the genetic difference between the host
improved animal nutrition. Overall, the effect on farms                   plant and a gene donor species, the greater the risk of
should be to increase productivity while providing more                   unpredicted consequences. Conversely, within a plant’s
options to manage the environmental effects of                            genome there is a range of unused genes; use of them may
intensification.                                                          incur risks equivalent to the use of foreign genes. For this
                                                                          reason, some argue that the use of cisgenic plants does not
However, the possible impacts of genetically modified                     differ materially in risk from transgenic plants. Again,
forages on farm income and profitability have not yet been                there is a view that risk depends more on the impacts of the
modelled in detail. Definitive work has yet to be done that               trait used than the source of the genes for that trait. 17 This
clearly links farm productivity improvement to the uptake                 point remains subject to debate.
of new forage technologies, and also links farm
profitability to the response of international markets to                 There are no indigenous ryegrass (Lolium) or white clover
increased production. Potential reductions in greenhouse                  (Trifolium) species in New Zealand and thus modified


12 Simon Harris, Harris Consulting, personal communication               14 “The Biology of Lolium multiforum Lam. (Italian ryegrass),
AgResearch modelling reported in Harrigan, J. “Switching on to           Lolium perenne L. (perennial ryegrass) and lolium arundinaceum
grass”, Country-Wide 31 (9); pg57, Sept 2009                             (Schreb.) Darbysg (tall fescue)”, Office of the Gene Technology
13 Kaye-Blake, W.H., Saunders, C.M., Cagatay, S. “Genetic modi-          Regulator, Australian Government, May 2008
fication technology and producer returns: the impact of productiv-       15 Busi, R.; Yu, Q.; Barrett-Lennard, R.; Powles, S. “Long distance
ity, preferences, and technology uptake”, Review of Agricultural         pollen-mediated flow of herbicide resistance genes in Lolium ri-
Economics, 3 (4); 692-710, 2008                                          gidum” Theoretical and Applied Genetics 117; pp 1281-1290, 2008
Saunders, C., Kaye-Blake, W., Cagatay, S. “Economic impacts on           16 As reported in Francois, F. “Regulatory Issues Concerning
New Zealand of GM crops: Result from partial equilibrium model-          Emerging GM Techniques”, Ministry for the Environment, Pre-
ling”, Agricultural Economics Research Unit, Lincoln University,         sented at the Ninth International Symposium on Biosafety of Ge-
Research Report No 261, August 2003                                      netically Modified Organisms, September 2006



www.royalsociety.org.nz                                              4                                                        March 2010
GENETICALLY MODIFIED FORAGES



forages do not directly threaten to hybridise with endemic                   individual or to their environment. When perceived
species. However, UK research on insect resistant crops                      benefit compensates for risk, then acceptance is more
suggests that the major conservation impact comes not                        common.21 Such risk and benefit analyses are often
from genetic modification itself, but from changed farm                      considered on a case-by-case basis. For example, New
practises enabled by that modification9 and from the spread                  Zealand focus groups considered a hypothetical rot-
of forages into off-farm ecosystems. This suggests that the                  resistant GM potato to be less acceptable than a GM
conservation effects as well should be assessed on a trait by                bacterial strain for removing pesticide contamination from
trait and ecosystem by ecosystem basis.                                      soil.22

Horizontal gene transfer needs to be considered as part of                   The first generation of genetically modified crops were
the risk assessment for the introduction of genetically                      seen to benefit producers and corporate owners of
modified forages. This involves the uptake, integration,                     intellectual property, rather than the consumers who bore
and expression of genetic material from one species to                       any risk. This led to their widespread public rejection in
another without interbreeding. Horizontal gene transfer                      many nations. More recent justification for genetically
has always played an important role in the evolution of                      modified organisms now focuses more on reducing
bacteria. In terms of higher plants and animals, horizontal                  environmental impacts, such as lowered greenhouse gas
gene transfer has been the subject of thorough and                           emissions or nitrogenous run-off. Such offerings stand to
extensive investigation which has produced sparse evidence                   benefit the human population and the environment as a
of such activity.18 To date there is no evidence of transfer of              whole and may therefore be more acceptable. However,
genes from plants to vertebrate genomes.                                     even then, environmental benefits are diffuse and lagged
                                                                             and therefore may still not be seen as adequate
Social acceptance is driven by personal and national                         compensation for perceived risk.
identity
Much of New Zealanders’ personal and national identity,                      Social and market opposition to GM food is decreasing
and sense of place is linked to concepts about nature. This                  The question of market acceptability of genetically
is expressed as both the concept of New Zealand’s clean,                     modified biological material in some parts of the world is
green image and Maori concepts of whakapapa and mauri.                       unresolved and evolving, whereas in other countries (e.g.
Such values provide a standpoint from which to consider                      the USA & China), the issue is much less contentious.
biotechnology and genetic modification and, for many,
justify the rejection of field releases of genetically modified              Reviews of consumer attitudes are showing a gradual
organisms.19                                                                 reduction in concern over genetically-modified organisms
                                                                             as anxiety over climate change, security of food supply, and
The social acceptability of new technologies is influenced                   other environmental problems grow. However, around a
by people's identities and values, the trust they place in                   fifth of Europeans continue to see GMOs in agriculture as
authorities, and a natural desire to preserve options in the                 a significant environmental threat.23 Conversely, the effect
face of uncertainty.20 Other factors influencing acceptability               on consumer buying patterns is less pronounced. In many
include: fear of negative environmental impacts, threats to                  situations consumers do not actively avoid GM-foods and,
food safety, dislike of corporate ownership of food                          while labelling of GM status is stated as desirable by
production systems, and ethical beliefs around modifying                     consumers, few consumers apparently use the information
the natural state.                                                           presented on the labels.24

Within this framework, acceptance of new biotechnologies
depends upon the perceived risk and benefit to the


17 For examples of this debate, see:                                        20 A useful summary of the research from the “Socially and Cul-
Russel, A.W., Sparrow, R. “The case for regulating intragenic               turally Sustainable Biotechnology” project can be found in the
GMOs”, Journal of Agricultural and Environmental Ethics, 21; pp             workshop proceedings “Working across boundaries: science indus-
153-181, 2008                                                               try in society”, Royal Society of New Zealand, 2007
Jacobsen, E., Schouten, H.J., “Cisgenesis, a New Tool for Tradi-            Also relevant is Frewer, L., Lassen, J., Kettlitz, B., Scholderer, J.,
tional Plant Breeding, Should be Exempted from the Regulation               Beekman, V., Berdal, K.G. “Societal aspects of genetically modi-
on Genetically Modified Organisms in a Step by Step Approach”,              fied foods”, Food and Chemical Toxicology, 42; pp 1181-1193, 2004
Potato Research, 51(1); pp 75-88, 2008                                      21 Knight, J.G., Mather, D.W., Holdsworth, D.K, “Consumer
One commentary on the evidence in the cis/trans debate can be               benefits and acceptance of genetically modified food”, Journal of
found at:                                                                   Public Affairs, 5 (3-4); pp 226 – 235, 2005
“Cisgenic Plants: Just Schouten from the Hip?”, Bioscience Re-              22 Hunt, L.M., Fairweather, J.R., Coyle, F.J. “Public Understand-
source Project, 23rd February, 2007                                         ings of Biotechnology in New Zealand: Factors Affecting Accept-
18 van den Eede, et.al. “The relevance of gene transfer to the safety       ability Rankings of Five Selected Biotechnologies”, Agribusiness
of food and feed derived from genetically modified (GM) plants”,            and Economics Research Unit, Lincoln University, Research Re-
Food and Chemical Toxicology, 42; pp 1127-1156, 2004                        port No. 266, December 2003
19 Fairweather, J., Campbell, H., Hunt, L., Cook, A. “Why do                23 “Attitudes of European citizens towards the environment”,
some of the public reject novel scientific technologies? A synthesis        Eurobarometer 295, 2008
of results from the Fate of Biotechnology Research Programme”,              “Opposition decreasing or acceptance increasing? An overview of
AERU Research Report No 295, Lincoln University, June 2007                  European consumer polls on attitudes to GMOs”, GMO Compass,
                                                                            April 16, 2009


www.royalsociety.org.nz                                                 5                                                          March 2010
GENETICALLY MODIFIED FORAGES



Consumer acceptance of animals fed on GM feeds is poorly                 Linked to this is the question of whether the presence of
researched                                                               low but measurable levels of cisgenic or transgenic material
There are differences in market acceptability between                    in food would, in the eyes of the market, mean that NZ
genetically modified food products and food products from                forage systems would be considered as genetically modified
non-genetically modified animals that have been fed on                   or not. In the EU there are tolerated levels of GM co-
genetically modified feeds. Some surveys show that many                  mixing in GM free products. Up to now separation
consumers believe that food products from a non-GM                       distances and control of seed mixing has enabled the New
animal fed on GM feed should be considered as genetically                Zealand seed industry to produce proprietary seeds of
modified. However, food products from animals fed on                     certified quality. These methodologies are widely accepted
transgenic soya bean products (amongst others) are widely                as sufficient to minimise genetic contamination between
purchased and generally not labelled as containing GM                    non-GM lines. The same practises may also be suitable for
material.25 Few trade restrictions are placed on the                     maintaining mandated separation between GM and non-
products.                                                                GM seed lines.

There has been little research done to investigate consumer
attitudes to products from non-GM animals fed on GM                      Further Reading
feeds, especially in markets beyond the EU. The ABARE                    “Reaping the benefits: Science and the sustainable
review GM stockfeed in Australia is one of the few relevant              intensification of global agriculture”, The Royal Society of
summaries of this limited research; their key                            London, October 2009
recommendation is further market analysis. Despite this,                 Ansell, E., McGinn, E. “GM stockfeed in Australia”,
their conclusion is that livestock producers using GM feed               Australian Bureau of Agricultural and Resource
are unlikely to be disadvantaged in the market or suffer                 Economics, prepared for the Australian Government
market access problems.26                                                Department of Agriculture, Fisheries and Forestry,
                                                                         Canberra, 2009
The effect on market value of GM-fed animals
Questions remain around the size of any price differentials              Principal Contributor
for genetically unmodified products obtained from a nation               Dr Stephen Goldson FRSNZ, Royal Society of New
that also supports production systems using genetically                  Zealand, Vice President – Biological and Life Sciences
modified crops.27 More specifically, how would this apply
to New Zealand and to the use of GM forages, not GM                      Contributors and Reviewers
food? It is important to determine whether this country’s                Dr David Burritt, Dr Greg Bryan, Dr Vern Collette,
trading status would be compromised should genetically                   Dr Richard Curtis, Dr Michael Dunbier, Dr Zac Hanley,
modified crops be introduced commercially. It appears that               Simon Harris, Professor Paula Jameson, Dr Chris Jones,
European consumer concern about GM technology is                         Professor Michael McManus, Dr Richard Macknight,
apparently linked to the products themselves rather than                 Dr Tony Parsons, Associate Professor Russell Poulter,
GM use in the countries of origin. The limited domestic                  Dr Susanne Rasmussen, Dr Nick Roberts,
research on this suggests that co-existence of non-GM food               Professor Caroline Saunders, Professor Barry Scott,
production and GM forages for non-food use has little                    Professor David Thorns, Dr Christian Walter,
impact on consumer perceptions of country-of-origin                      Dr Heather Went, Dr Derek Woodfield
image.28 Similar work looking at the Chinese market
suggests that current ambivalence about GM products may                  For further information, please contact
change if GM products deliver consumer benefits or price                 Dr Jez Weston
advantages. There is little suggestion that Chinese buyers               jez.weston@royalsociety.org.nz
would discriminate against non-GM products from
countries also growing GM crops.29




24 European Commission CONSUMERCHOICE project, “Do                      27 This issue has been a continuing feature of the NZ debate
European consumers buy GM foods? – Final report”, 2008                  around the use of genetic modification. For a previous example of
25 One recent New Zealand government finding is that some               the discussion, see:
products have been mislabelled, with chickens that had been fed         “Economic Implications of a First Release of Genetically Modified
GM soya labelled as containing no GM ingredients.                       Organisms in New Zealand”, Independent Biotechnology Advi-
“Inghams warned over GM free chicken claims”, Commerce Com-             sory Council, December 1999
mission, Release no 50, November 18th, 2009                             28 Knight, J.G., Mather, D.W., Holdsworth, D.K. “Impact of ge-
26 Ansell, E., McGinn, E. “GM stockfeed in Australia”, Australian       netic modification on country image of imported food products in
Bureau of Agricultural and Resource Economics, prepared for the         European markets: Perceptions of channel members”, Food Policy
Australian Government Department of Agriculture, Fisheries and          30; pp 385-398, 2005
Forestry, Canberra, 2009                                                29 Knight, J.G, Gao, H. “Chinese gatekeeper perceptions of geneti-
                                                                        cally modified food”, British Food Journal, 111 (1); pp 56-59, 2009



www.royalsociety.org.nz                                             6                                                        March 2010

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Emerging Issues Paper Genetically Modified Forages

  • 1. GENETICALLY MODIFIED FORAGES Genetically Modified Forages Emerging Issues Summary Changing drivers for genetic modification in agriculture The past decade has seen both global growth of the use of Fifteen years ago, intense public interest about the genetically modified (GM) technologies in agriculture and management of genetic technologies led to the creation of increasing concern over the ability to maintain adequate the Independent Biotechnology Advisory Council in 1999, food production. followed by the Royal Commission on Genetic Modification report in 2001. The Commission New Zealand research into genetically modified forages recommended that New Zealand “should proceed has led to plants with traits that, when grown in carefully, minimising and managing risk”. 1 That finding containment, offer improved performance over contributed to a period of continuing but less intense traditionally-bred lines. Improved forage performance can concern around genetic modification. be delivered by both transgenic (using genes from other species) and cisgenic (using genes from the original species) Since then, issues of food production and food security methods. Cisgenic transformation may be more socially have grown in significance internationally.2,3 For this acceptable, but many believe that the benefits and risks country a number of factors have arisen that may influence depend more upon the traits themselves, not upon the opinion about the release of genetically modified forages. sources of the genes that deliver the traits. These include: The use of genetically modified forage could increase farm  Ongoing intensification of pastoral farming and the productivity, drought resistance, and reduce greenhouse need to transform the sustainability of agriculture gas emissions intensity. However, the release of genetically  Increasing costs of farm inputs, e.g. fertiliser and modified organisms is at variance with identities and fuel, and the corresponding concerns about the values that many New Zealanders hold dear. potential limits of ‘business as usual’ agriculture  Mitigating agricultural greenhouse gas emissions In overseas markets, some consumers retain a preference  Adapting to climate change, e.g. more frequent and for non-GM products but such opposition is decreasing. However, research on social and market acceptance is intense droughts largely limited to the European market. These issues are  Growing competition from low cost producers seen as less of a concern for animal feed than for human overseas food.  Increasing animal welfare concerns, particularly the nutrition of pasture-fed animals The scope of this paper covers the technologies and drivers  Improving precision of GM techniques associated with the development and use of genetically transformed forages that are of interest to New Zealand’s pasture-based industries. The pastoral sector is an area where New Zealand research is world-leading. The intent of this document is not to make recommendations, but to inform discussion on the benefits, risks, and acceptability of the use of these technologies. 1 ”Report of the Royal Commission on Genetic Modification”, 2001 3 “Agriculture at a Crossroads”, International Assessment of Agri- 2 “Reaping the benefits: Science and the sustainable intensification cultural Knowledge, Science and Technology for Development, of global agriculture”, The Royal Society of London, October 2009 2008 www.royalsociety.org.nz March 2010
  • 2. GENETICALLY MODIFIED FORAGES >10 million ha >1 million ha >50,000 ha <50,000 ha Figure 1: Nations using genetically modified crops. The majority of GM crops are grown in the US, Argentina and Brazil.4 Many researchers believe that traits influence risks and based approach, although these countries show differing benefits more than the techniques used to deliver the trait degrees of precaution. New Zealand legislation A trait is a distinct variant of the observable characteristics differentiates between GM and non-GM methods of of an organism. An example of this is blue or brown eyes. modification prior to assessing the effect of new traits. Commonly used traits in commercial crops that have been manipulated by genetic modification are those for Many believe trait evaluation should be carried out on a herbicide tolerance and insect resistance.4 case-by-case basis When new traits are introduced, they enter dynamic and In brief, consideration of genetic modification 5 broadly has complex systems. These systems range from the three components: (i) the nature of the trait being biochemistry and physiology of the plant, the ecosystem of introduced and how it is expressed, (ii) the technique being the soil and pasture, through to the wider local used to introduce the DNA encoding the trait into a host’s environment, the farm business system and ultimately, the genome and (iii) the source of the introduced trait-related national economy. Impacts must be evaluated across all of genes. Many regulators and members of the public have these levels. This multi-faceted evaluation raises a number focused on the techniques used to introduce new traits into of questions including: plants and any resulting effects upon food products, rather  How much system-level understanding is there than the traits themselves. This being the case, it is also available? necessary to recognise that ‘conventional’ plant breeding  How well can outcomes (and risk profiles) for can be expedited via the use of mutagens to alter a plant’s ecosystems, individual agricultural businesses and DNA to create new base-pair combinations that, by chance, the sectors be predicted? may create a useful trait. This approach is seen by some to  How well understood are the likely impacts on be more acceptable than the precise insertion of trait- social and cultural responses and New Zealand’s coding genes into a DNA sequence. market position? Given the above, the question can be asked whether it is Extrapolation based on prior experience with currently- the trait that matters, rather than how it is arrived at. Many used traits does not provide full information on the possible of our contributors believe that risk management should effects of newly introduced traits. Each new trait may have lean more towards understanding a new trait's functions widely different impacts, and should therefore be and implications rather than the method of modification. considered as a new and separate effect interacting with Focusing on the technique used, instead of the trait, could existing components. create its own risks around incomplete understanding of a trait’s impacts. When considering new traits, researchers can sometimes use conventionally bred analogues grown under field Regulation based on traits rather than techniques is already conditions to partially assess impacts in place of releasing in use in Canada with the USA taking a similarly safety- 4 James, C. “Brief 39 – Global Status of Commercialized Bio- 5 Defined here as recombinant techniques as regulated by the Haz- tech/GM Crops: 2008”, International Service for the Acquisition of ardous Substances and New Organisms Act Agri-biotech Applications, 2008 www.royalsociety.org.nz 2 March 2010
  • 3. GENETICALLY MODIFIED FORAGES Categories Source of new genes Potentially achievable with Genetic distance conventional breeding? Cisgenic From species genome Yes Low Famigenic Species in the same family Maybe Transgenic Unrelated species No Xenogenic Synthetic genes No High Table 1: Definitions of genetically modified organisms based upon sources for modified genes 11 genetically modified organisms.6 Such preliminary that are modified for pest resistance. This contrasts with assessment of a trait’s likely effects can aid subsequent field the prospects of persistent inter-seasonal perennial forages investigation using the modified organisms themselves. with other introduced traits.10 Thus all modifications There are limits to the extent non-genetic modification should be considered on a case-by-case basis. approaches can replicate the traits delivered by genetic modification so these approaches will remain useful, but Sources of genes: cisgenic versus transgenic modification incomplete, ways to assess the impacts of new traits. In general, barriers between multi-cellular species prevent interbreeding and functional gene transfer. This is seen by Increasing offshore experience with genetically modified many as part of the “natural order”. Genetic manipulation crops crosses these barriers. Up to fifteen years have elapsed since the US and other nations began intensive cultivation of genetically modified There is a continuum of sources of potential genes that crops, particularly soya bean, maize, and cotton. The area may be used in genetic modifications. For example, genes sown reached 125 million hectares in 2008.4 Such use of may be acquired from within a species, or from species of genetically modified technology has been associated with increasing genetic distance from the transformed species. reduced pesticide use and increased farm income from Alternatively, genes may be created entirely synthetically insect resistant maize in parts of the EU7 and from various by assembling new combinations of base pairs. other crops globally.8 The process of cisgenetic (or intragenic) modification No evidence has been found of harm to human health2 or involves manipulating genetic material only from the permanent ecological damage.9 This is often taken as species being transformed. When genes are sourced from a evidence in favour of the use of genetically modified crops. different species, the process is known as transgenic. However, as has been noted in the consideration of traits, it is necessary to recognise that if one type of modification or The implications of cisgenics and transgenics are group of modifications has been safely and successfully sometimes viewed differently amongst scientists, used, that does not automatically mean that all genetically regulators, and the general public. Cisgenic transformation modified crops are safe. By the same token, it cannot be may appear to conform more to the “natural order” of assumed that the products of conventional breeding are species isolation and therefore may be more acceptable for inherently safe. A modification for one purpose may not in that reason to the New Zealand public. any way resemble another modification, be it functionally, biologically, or ecologically. For example, most experience with genetically modified crops has been with annual crops 6 An example of this approach is the work being carried out by Dr 10 For example, alfalfa is perennial, insect-pollinated, regrows Anthony Parsons under the FRST contract “Novel Trait-based quickly, is drought and cold tolerant, and produces dormant seeds. Assessment”. Earlier work has been published as: These characteristics aid gene flow in wild populations. GM alfalfa Parsons, T., Rasmussen, S., Newton, P., Bergelson, J. “A basis for has been approved for unconfined release in Canada. developing a priori assessments of the risks and benefits of novel Bagavathiannan, M.V. Van Acker, R.C. “The Biology and Ecology organisms” AgResearch Internal Report, 2003 of Feral Alfalfa (Medicago sativa L.) and Its Implications for Novel 7 Brookes, G. “The impact of using GM insect resistant maize in Trait Confinement in North America”, Critical Reviews in Plant Europe since 1998”, International journal of Biotechnology, 10 Sciences, 28 (1&2); pp 69 – 87, 2009 (2/3); pp 148-166, 2008 Bagavathiannan, M.V., Van Acker, R.C. “The Feral Nature and Gómez-Barbero, M, Berbel, J., Rodriguez-Cerezo, E. “Bt corn in Implications for The Co-Existence of Genetically Modified and Spain – the performance of the EU’s first GM crop”, Nature Bio- Non-GM Alfalfa”, Department of Plant Science, University of technology correspondence, 26 (4); pp 384-386, 2008 Manitoba, 2009 8 Brookes, G., Barfoot, P. “Global impact of Biotech Crops: Socio- 11 Adapted from Nielsen, K.M. “Transgenic organisms – time for Economic and Environmental Effects, 1996-2006”, AgBioForum, conceptual diversification?”, Nature Biotechnology, 21; pp227-228, 11 (1); pp 21-38, 2008 March 2003 9 Department of Environment Food and Rural Affairs “Farm Scale Evaluations of herbicide tolerant GM crops”, 2005 www.royalsociety.org.nz 3 March 2010
  • 4. GENETICALLY MODIFIED FORAGES Demonstrated and potential benefits of genetically gas emissions and nitrogen leaching will also need to be modified forages factored in as their reduction will increasingly offer The Royal Commission referred to the “exciting promise” economic as well as environmental value. Some of genetic modification. Such promise is no longer preliminary modelling has shown potential economic speculative. Forage research now has made demonstrable benefit,12 whereas other substantial work predicts that progress towards the discovery and incorporation of useful strategies to simply increase market demand will have a traits. For example, those in ryegrass and clover plants (in more profitable impact.13 Both approaches may be containment) now include: necessary, but the impact of the use of genetically modified  Drought resistance and improved performance technology on demand for New Zealand products will under moisture stress that will increasingly arise always rest with consumers. from climate change  Improved balance of soluble carbohydrate and Potential adverse effects of genetically modified forages protein levels for increased available energy, higher Ryegrass is perennial and produces wind-blown pollen. productivity, and better nitrogen use efficiency Unlike, previous field trials of GM pine trees, it would not  Higher levels of condensed tannins for the be possible to guarantee that there will be no movement of elimination of bloat and optimal protein uptake genetic material. Flowering cannot be avoided if proper leading to less nitrogenous waste and possibly less agronomic evaluations are to be made of large areas of methane production forages. Whilst the vast majority of ryegrass pollen is deposited a few metres from the source,14 viable pollen has  Changed lipid content leading to higher available been shown to move at least three kilometres.15 Seed energy and reduced methane production dispersal will also be a concern, with limited information available about possible role of birds and mammals. 14 Other traits under development include:  Reduced lignin for more digestibility and improved Enhanced traits may create potential for more weediness nitrogen efficiency where those traits deliver plant persistence and vigour.  Improved efficiency in the plant's use of water and Conversely, many traits under development promote nutrients nutritional value to livestock rather than likely adaptive  Encapsulated lipids to increase the level of omega 3 fitness. Such transformed plants often generate new unsaturated fats in the grazing animal, with proteins which could incur an increased metabolic cost, potential human health benefits reducing overall fitness and thus survival in the wild.  Improved growth at lower temperatures for increased production outside of the peak growth The exclusive use of cisgenics limits the potential changes period made to an organism, purely because the range of usable genes is limited to those already present within the species. If these benefits are realised in production systems, then This reduces the range of available traits but similarly, may they should lead to improved feed production and limit the risks and the potential for unexpected conversion, increased tolerance to droughts, reduced consequences.16 This limitation has led to the assumption greenhouse gas emissions, reduced nitrogen intensity, and that the greater the genetic difference between the host improved animal nutrition. Overall, the effect on farms plant and a gene donor species, the greater the risk of should be to increase productivity while providing more unpredicted consequences. Conversely, within a plant’s options to manage the environmental effects of genome there is a range of unused genes; use of them may intensification. incur risks equivalent to the use of foreign genes. For this reason, some argue that the use of cisgenic plants does not However, the possible impacts of genetically modified differ materially in risk from transgenic plants. Again, forages on farm income and profitability have not yet been there is a view that risk depends more on the impacts of the modelled in detail. Definitive work has yet to be done that trait used than the source of the genes for that trait. 17 This clearly links farm productivity improvement to the uptake point remains subject to debate. of new forage technologies, and also links farm profitability to the response of international markets to There are no indigenous ryegrass (Lolium) or white clover increased production. Potential reductions in greenhouse (Trifolium) species in New Zealand and thus modified 12 Simon Harris, Harris Consulting, personal communication 14 “The Biology of Lolium multiforum Lam. (Italian ryegrass), AgResearch modelling reported in Harrigan, J. “Switching on to Lolium perenne L. (perennial ryegrass) and lolium arundinaceum grass”, Country-Wide 31 (9); pg57, Sept 2009 (Schreb.) Darbysg (tall fescue)”, Office of the Gene Technology 13 Kaye-Blake, W.H., Saunders, C.M., Cagatay, S. “Genetic modi- Regulator, Australian Government, May 2008 fication technology and producer returns: the impact of productiv- 15 Busi, R.; Yu, Q.; Barrett-Lennard, R.; Powles, S. “Long distance ity, preferences, and technology uptake”, Review of Agricultural pollen-mediated flow of herbicide resistance genes in Lolium ri- Economics, 3 (4); 692-710, 2008 gidum” Theoretical and Applied Genetics 117; pp 1281-1290, 2008 Saunders, C., Kaye-Blake, W., Cagatay, S. “Economic impacts on 16 As reported in Francois, F. “Regulatory Issues Concerning New Zealand of GM crops: Result from partial equilibrium model- Emerging GM Techniques”, Ministry for the Environment, Pre- ling”, Agricultural Economics Research Unit, Lincoln University, sented at the Ninth International Symposium on Biosafety of Ge- Research Report No 261, August 2003 netically Modified Organisms, September 2006 www.royalsociety.org.nz 4 March 2010
  • 5. GENETICALLY MODIFIED FORAGES forages do not directly threaten to hybridise with endemic individual or to their environment. When perceived species. However, UK research on insect resistant crops benefit compensates for risk, then acceptance is more suggests that the major conservation impact comes not common.21 Such risk and benefit analyses are often from genetic modification itself, but from changed farm considered on a case-by-case basis. For example, New practises enabled by that modification9 and from the spread Zealand focus groups considered a hypothetical rot- of forages into off-farm ecosystems. This suggests that the resistant GM potato to be less acceptable than a GM conservation effects as well should be assessed on a trait by bacterial strain for removing pesticide contamination from trait and ecosystem by ecosystem basis. soil.22 Horizontal gene transfer needs to be considered as part of The first generation of genetically modified crops were the risk assessment for the introduction of genetically seen to benefit producers and corporate owners of modified forages. This involves the uptake, integration, intellectual property, rather than the consumers who bore and expression of genetic material from one species to any risk. This led to their widespread public rejection in another without interbreeding. Horizontal gene transfer many nations. More recent justification for genetically has always played an important role in the evolution of modified organisms now focuses more on reducing bacteria. In terms of higher plants and animals, horizontal environmental impacts, such as lowered greenhouse gas gene transfer has been the subject of thorough and emissions or nitrogenous run-off. Such offerings stand to extensive investigation which has produced sparse evidence benefit the human population and the environment as a of such activity.18 To date there is no evidence of transfer of whole and may therefore be more acceptable. However, genes from plants to vertebrate genomes. even then, environmental benefits are diffuse and lagged and therefore may still not be seen as adequate Social acceptance is driven by personal and national compensation for perceived risk. identity Much of New Zealanders’ personal and national identity, Social and market opposition to GM food is decreasing and sense of place is linked to concepts about nature. This The question of market acceptability of genetically is expressed as both the concept of New Zealand’s clean, modified biological material in some parts of the world is green image and Maori concepts of whakapapa and mauri. unresolved and evolving, whereas in other countries (e.g. Such values provide a standpoint from which to consider the USA & China), the issue is much less contentious. biotechnology and genetic modification and, for many, justify the rejection of field releases of genetically modified Reviews of consumer attitudes are showing a gradual organisms.19 reduction in concern over genetically-modified organisms as anxiety over climate change, security of food supply, and The social acceptability of new technologies is influenced other environmental problems grow. However, around a by people's identities and values, the trust they place in fifth of Europeans continue to see GMOs in agriculture as authorities, and a natural desire to preserve options in the a significant environmental threat.23 Conversely, the effect face of uncertainty.20 Other factors influencing acceptability on consumer buying patterns is less pronounced. In many include: fear of negative environmental impacts, threats to situations consumers do not actively avoid GM-foods and, food safety, dislike of corporate ownership of food while labelling of GM status is stated as desirable by production systems, and ethical beliefs around modifying consumers, few consumers apparently use the information the natural state. presented on the labels.24 Within this framework, acceptance of new biotechnologies depends upon the perceived risk and benefit to the 17 For examples of this debate, see: 20 A useful summary of the research from the “Socially and Cul- Russel, A.W., Sparrow, R. “The case for regulating intragenic turally Sustainable Biotechnology” project can be found in the GMOs”, Journal of Agricultural and Environmental Ethics, 21; pp workshop proceedings “Working across boundaries: science indus- 153-181, 2008 try in society”, Royal Society of New Zealand, 2007 Jacobsen, E., Schouten, H.J., “Cisgenesis, a New Tool for Tradi- Also relevant is Frewer, L., Lassen, J., Kettlitz, B., Scholderer, J., tional Plant Breeding, Should be Exempted from the Regulation Beekman, V., Berdal, K.G. “Societal aspects of genetically modi- on Genetically Modified Organisms in a Step by Step Approach”, fied foods”, Food and Chemical Toxicology, 42; pp 1181-1193, 2004 Potato Research, 51(1); pp 75-88, 2008 21 Knight, J.G., Mather, D.W., Holdsworth, D.K, “Consumer One commentary on the evidence in the cis/trans debate can be benefits and acceptance of genetically modified food”, Journal of found at: Public Affairs, 5 (3-4); pp 226 – 235, 2005 “Cisgenic Plants: Just Schouten from the Hip?”, Bioscience Re- 22 Hunt, L.M., Fairweather, J.R., Coyle, F.J. “Public Understand- source Project, 23rd February, 2007 ings of Biotechnology in New Zealand: Factors Affecting Accept- 18 van den Eede, et.al. “The relevance of gene transfer to the safety ability Rankings of Five Selected Biotechnologies”, Agribusiness of food and feed derived from genetically modified (GM) plants”, and Economics Research Unit, Lincoln University, Research Re- Food and Chemical Toxicology, 42; pp 1127-1156, 2004 port No. 266, December 2003 19 Fairweather, J., Campbell, H., Hunt, L., Cook, A. “Why do 23 “Attitudes of European citizens towards the environment”, some of the public reject novel scientific technologies? A synthesis Eurobarometer 295, 2008 of results from the Fate of Biotechnology Research Programme”, “Opposition decreasing or acceptance increasing? An overview of AERU Research Report No 295, Lincoln University, June 2007 European consumer polls on attitudes to GMOs”, GMO Compass, April 16, 2009 www.royalsociety.org.nz 5 March 2010
  • 6. GENETICALLY MODIFIED FORAGES Consumer acceptance of animals fed on GM feeds is poorly Linked to this is the question of whether the presence of researched low but measurable levels of cisgenic or transgenic material There are differences in market acceptability between in food would, in the eyes of the market, mean that NZ genetically modified food products and food products from forage systems would be considered as genetically modified non-genetically modified animals that have been fed on or not. In the EU there are tolerated levels of GM co- genetically modified feeds. Some surveys show that many mixing in GM free products. Up to now separation consumers believe that food products from a non-GM distances and control of seed mixing has enabled the New animal fed on GM feed should be considered as genetically Zealand seed industry to produce proprietary seeds of modified. However, food products from animals fed on certified quality. These methodologies are widely accepted transgenic soya bean products (amongst others) are widely as sufficient to minimise genetic contamination between purchased and generally not labelled as containing GM non-GM lines. The same practises may also be suitable for material.25 Few trade restrictions are placed on the maintaining mandated separation between GM and non- products. GM seed lines. There has been little research done to investigate consumer attitudes to products from non-GM animals fed on GM Further Reading feeds, especially in markets beyond the EU. The ABARE “Reaping the benefits: Science and the sustainable review GM stockfeed in Australia is one of the few relevant intensification of global agriculture”, The Royal Society of summaries of this limited research; their key London, October 2009 recommendation is further market analysis. Despite this, Ansell, E., McGinn, E. “GM stockfeed in Australia”, their conclusion is that livestock producers using GM feed Australian Bureau of Agricultural and Resource are unlikely to be disadvantaged in the market or suffer Economics, prepared for the Australian Government market access problems.26 Department of Agriculture, Fisheries and Forestry, Canberra, 2009 The effect on market value of GM-fed animals Questions remain around the size of any price differentials Principal Contributor for genetically unmodified products obtained from a nation Dr Stephen Goldson FRSNZ, Royal Society of New that also supports production systems using genetically Zealand, Vice President – Biological and Life Sciences modified crops.27 More specifically, how would this apply to New Zealand and to the use of GM forages, not GM Contributors and Reviewers food? It is important to determine whether this country’s Dr David Burritt, Dr Greg Bryan, Dr Vern Collette, trading status would be compromised should genetically Dr Richard Curtis, Dr Michael Dunbier, Dr Zac Hanley, modified crops be introduced commercially. It appears that Simon Harris, Professor Paula Jameson, Dr Chris Jones, European consumer concern about GM technology is Professor Michael McManus, Dr Richard Macknight, apparently linked to the products themselves rather than Dr Tony Parsons, Associate Professor Russell Poulter, GM use in the countries of origin. The limited domestic Dr Susanne Rasmussen, Dr Nick Roberts, research on this suggests that co-existence of non-GM food Professor Caroline Saunders, Professor Barry Scott, production and GM forages for non-food use has little Professor David Thorns, Dr Christian Walter, impact on consumer perceptions of country-of-origin Dr Heather Went, Dr Derek Woodfield image.28 Similar work looking at the Chinese market suggests that current ambivalence about GM products may For further information, please contact change if GM products deliver consumer benefits or price Dr Jez Weston advantages. There is little suggestion that Chinese buyers jez.weston@royalsociety.org.nz would discriminate against non-GM products from countries also growing GM crops.29 24 European Commission CONSUMERCHOICE project, “Do 27 This issue has been a continuing feature of the NZ debate European consumers buy GM foods? – Final report”, 2008 around the use of genetic modification. For a previous example of 25 One recent New Zealand government finding is that some the discussion, see: products have been mislabelled, with chickens that had been fed “Economic Implications of a First Release of Genetically Modified GM soya labelled as containing no GM ingredients. Organisms in New Zealand”, Independent Biotechnology Advi- “Inghams warned over GM free chicken claims”, Commerce Com- sory Council, December 1999 mission, Release no 50, November 18th, 2009 28 Knight, J.G., Mather, D.W., Holdsworth, D.K. “Impact of ge- 26 Ansell, E., McGinn, E. “GM stockfeed in Australia”, Australian netic modification on country image of imported food products in Bureau of Agricultural and Resource Economics, prepared for the European markets: Perceptions of channel members”, Food Policy Australian Government Department of Agriculture, Fisheries and 30; pp 385-398, 2005 Forestry, Canberra, 2009 29 Knight, J.G, Gao, H. “Chinese gatekeeper perceptions of geneti- cally modified food”, British Food Journal, 111 (1); pp 56-59, 2009 www.royalsociety.org.nz 6 March 2010