Europe’s Farm to Fork Strategy and Its Commitment to Biotechnology and Organic Farming: Conflicting or Complementary Goals?

Abstract

Sustainable food systems will require profound changes in people’s consumption patterns and lifestyles, which is true regardless of the farming methods used and does not change the fact that organic farming often requires more land than conventional farming for the same quantity of food output.Some features of organic farming in the EU contribute to the Sustainable Development Goals (SDGs); other features may jeopardize the achievement of SDGs 2, 13, and 15. The negative indirect effects of additional land-use change may outweigh the positive direct effects on global climate and biodiversity, so that a large-scale switch to organic farming in the EU could possibly turn out to be a disservice to global sustainability.Achieving the SDGs would benefit from the inclusion of biotech innovations in organic farming.The implementation of required changes in the EU law is unlikely under current political realities but is nevertheless recommended from a scientific perspective. The European Commission’s Farm to Fork (F2F) strategy, under the European Green Deal, acknowledges that innovative techniques, including biotechnology, may play a role in increasing sustainability. At the same time, organic farming will be promoted, and at least 25% of the EU’s agricultural land shall be under organic farming by 2030. How can both biotechnology and organic farming be developed and promoted simultaneously to contribute to achieving the Sustainable Development Goals (SDGs)? We illustrate that achieving the SDGs benefits from the inclusion of recent innovations in biotechnology in organic farming. This requires a change in the law. Otherwise, the planned increase of organic production in the F2F strategy may result in less sustainable, not more sustainable, food systems. The European Commission’s Farm to Fork (F2F) strategy, under the European Green Deal, acknowledges that innovative techniques, including biotechnology, may play a role in increasing sustainability. At the same time, organic farming will be promoted, and at least 25% of the EU’s agricultural land shall be under organic farming by 2030. How can both biotechnology and organic farming be developed and promoted simultaneously to contribute to achieving the Sustainable Development Goals (SDGs)? We illustrate that achieving the SDGs benefits from the inclusion of recent innovations in biotechnology in organic farming. This requires a change in the law. Otherwise, the planned increase of organic production in the F2F strategy may result in less sustainable, not more sustainable, food systems. The European Commission (EC) recently launched its Farm to Fork (F2F) strategy. This strategy is a cornerstone of the European Green Deal and is instrumental in working toward the United Nations Sustainable Development Goals (SDGs) [32.European Commission A Farm to Fork Strategy for a Fair, Healthy and Environmentally-friendly DG SANTE/Unit ‘Food information and composition, food waste'.2020Google Scholar]. The F2F strategy acknowledges that new innovative techniques, including biotechnology, may play a role in increasing sustainability. At the same time, organic farming will be promoted, and at least 25% of the EU’s agricultural land shall be under organic farming by 2030. How can both biotechnology and organic farming be developed and promoted simultaneously to contribute to the overall aim of achieving the SDGs? It is a common interpretation that the current EU legal framework regulates many products resulting from novel techniques in plant breeding as genetically modified (GM) organisms (GMOs), while organic farming and processing of organic products legally exclude the use of GMOs. Hence, combining these two components of the F2F strategy appears conflicting and challenging, if not impossible, even though the two could actually fit together very well if legally permitted (Figure 1). Through a few cases, we illustrate that achieving the SDGs benefits from the inclusion of biotechnology innovations in organic farming. To make this possible, we advocate for a change in the EU law. Implementation of such a legal change is unlikely under current political realities. Many EU and national policymakers and interest groups, including nongovernmental organizations (NGOs), seem to prefer coexistence policies whereby organic production and modern biotechnology are strictly separated. Notwithstanding the fact that it is hard to justify such a strict separation of ‘organic,’ ‘conventional,’ and GMO from a scientific point of view, without legal change, the planned increase of organic production in the F2F strategy may result in less sustainable, not more sustainable, food systems. In order to produce or market an agricultural product or foodstuff in the EU as an organic product, EU law requires separating organic production from the use of GMOs. Recital 23 Regulation (EU) 2018/848 stipulates that organic production and consumers’ perception of organic products are incompatible with GMOs. As a result, according to Article 11 Regulation (EU) 2018/848, ‘the use of GMOs in organic production is prohibited.’ To be precise, ‘GMOs, products produced from GMOs, and products produced by GMOs shall not be used in food or feed, or as food, feed, processing aids, plant protection products, fertilisers, soil conditioners, plant reproductive material, micro-organisms or animals in organic production.’ To determine whether products shall not be used, operators may rely on their labeling in accordance with the EU rules on labeling of organic products in combination with the rules on labeling of GMOs. In principle, the majority of food and feed on the EU market ‘containing, consisting of or produced from GMOs’ (Article 2, Regulation 1829/2003), with GMOs understood as defined in Directive 2001/18, require labeling. As to the interpretation by many academics and stakeholders of the judgment Confédération paysanne, the products of most novel breeding technologies, including targeted mutagenesis through genome editing, are subject to the GMO regulations [1.Purnhagen K.P. Wesseler J.H.H. EU regulation of new plant breeding technologies and their possible economic implications for the EU and beyond.Appl. Econ. Perspect. Policy. 2020; (Published online September 28, 2020. https://doi.org/10.1002/aepp.13084)Crossref Scopus (15) Google Scholar,2.Purnhagen K.P. How to manage the Union’s diversity: the regulation of new plant breeding technologies in Confédération paysanne and others.Common Market Law Rev. 2019; 56: 1379-1396Google Scholar]. Others argue that certain applications of targeted mutagenesis may still be excluded postjudgment [3.Vives-Vallés J.A. Collonnier C. The judgment of the CJEU of 25 July 2018 on mutagenesis: Interpretation and interim legislative proposal.Front. Plant Sci. 2020; 10: 1813Crossref PubMed Scopus (11) Google Scholar,4.van der Meer P. et al.The status under EU law of organisms developed through novel genomic techniques.Eur. J. Risk Regul. 2021; (Published online January 6, 2021. https://doi.org/10.1017/err.2020.105)Crossref Scopus (5) Google Scholar]. Labeling exemptions apply to the adventitious or technically unavoidable presence of traces of GMOs, as long as they do not exceed the threshold level of 0.9%, as defined under Regulation 1829/2003. This threshold applies to the labeling of GMOs that have been authorized for import and processing. For GMOs that have not been approved, a zero tolerance applies, while for those that have received a positive risk assessment by the European Food Safety Authority, a zero tolerance applies for food, with a threshold of 0.1% for feed. In case the respective product is not labeled as GMO, operators may assume that no GMOs or products produced from GMOs have been used in the manufacture of purchased food and feed products [Article 11(3), Regulation (EU) 2018/848]. Article 11, Regulation (EU) 2018/848 only prohibits the use of ‘GMOs, products produced from GMOs, and products produced by GMOs.’ Arguably, organic production of food with GMOs is legally not explicitly prohibited. This means, for example, that organic production of foods using GM microbes can be common practice if the food is considered produced ‘with’ GMOs. Organic beer, bread, and cheese are allowed to be produced with the enzymes or directly with GM yeast and GM bacteria. European consumers have been consuming products made with GMO technology for over 35 years [5.Wesseler J. Agriculture in the Bioeconomy - Economics and Policies. Wageningen University, 2015https://edepot.wur.nl/384179Google Scholar]. The existing legal framework leads us to assess whether the focus of F2F on increasing organic production contributes to achieving the SDGs while not using GMO techniques (including those novel techniques that are commonly considered as such). Organic farming is considered to cause less environmental damage than conventional agriculture. It promotes higher levels of agrobiodiversity and uses less environmental pollutants (e.g., synthetic pesticides and inorganic fertilizer) [6.Clark M. Tilman D. Comparative analysis of environmental impacts of agricultural production systems, agricultural input efficiency, and food choice.Environ. Res. Lett. 2017; 12: 64016Crossref Scopus (431) Google Scholar], contributing to achieving SDGs 13 and 15 (Figure 1). While some facets of organic farming can contribute to the achievement of these SDGs, we focus on those aspects where it does not or only to a limited extent and where biotechnological innovations have the potential to serve as a remedy. Given that food demand continues to rise globally and that hunger reduction is central to SDG 2, production quantities remain relevant and need to be factored in. Many of the positive environmental effects of organic production on the SDGs disappear when evaluating per kilogram of food rather than per hectare of land and while taking absolute amounts needed into consideration [7.Tuomisto H.L. et al.Does organic farming reduce environmental impacts? A meta-analysis of European research.J. Environ. Manag. 2012; 112: 309-320Crossref PubMed Scopus (460) Google Scholar]. One hectare of organically cultivated land produces a lower crop yield than one hectare of conventionally cultivated land under conditions that allow effective use of conventional farming methods. This ‘organic’ yield gap can vary by crop type and several other factors; studies suggest that it is in a magnitude of 20–25% under experimental conditions and up to 50% under practical farming conditions [8.Seufert V. Ramankutty N. Many shades of gray - the context-dependent performance of organic agriculture.Sci. Adv. 2017; 3e1602638Crossref PubMed Scopus (183) Google Scholar,9.Meemken E.M. Qaim M. Organic agriculture, food security, and the environment.Annu. Rev. Resour. Econ. 2018; 10: 39-63Crossref Scopus (117) Google Scholar]. Increasing organic agricultural land from 7.5%, as currently observed in the EU, to at least 25% of total agricultural land by decree might have various unintended land-use implications. Effects could range from a mere conversion of existing conventional farmland to organic without much yield loss in certain regions (e.g., areas with low-yield conventional farming systems) to larger yield losses (in areas with high-yield conventional farming systems), entailing the need for additional conversion of forests, swamps, or other natural habitats within the EU or elsewhere through rising food imports [9.Meemken E.M. Qaim M. Organic agriculture, food security, and the environment.Annu. Rev. Resour. Econ. 2018; 10: 39-63Crossref Scopus (117) Google Scholar]. Already today, with only 7.5% of the EU land under organic farming, Europe is a major importer of vegetable oil and feed protein (e.g., palm oil, soy), contributing to deforestation in Southeast Asia and South America [10.Qaim M. et al.Environmental, economic, and social consequences of the oil palm boom.Annu. Rev. Resour. Econ. 2020; 12: 321-344Crossref Scopus (68) Google Scholar]. More precisely, the EU already imports about 5 million tons of soybeans from Brazil or 55% of the total imports of soybean,i some of which has been linked to illegally forested land [11.Rajão R. et al.The rotten apples of Brazil’s agribusiness.Science. 2020; 369: 246-248Crossref PubMed Scopus (115) Google Scholar]. Imports and global land requirements would rise with more of the EU farmland being converted to organic. Using more land for agricultural production threatens natural biodiversity and therefore jeopardizes the achievement of SDG 15. Also, land conversion is responsible for half of the total climate effects of agriculture. Studies predict that the GHG emissions from additional land conversion would offset any potential direct climate benefits resulting from a switch to organic agriculture [12.Smith L.G. et al.The greenhouse gas impacts of converting food production in England and Wales to organic methods.Nat. Commun. 2019; 10: 4641Crossref PubMed Scopus (73) Google Scholar], jeopardizing the achievement of SDG 13. Reducing consumers’ meat consumption and food waste [13.Muller A. et al.Strategies for feeding the world more sustainably with organic agriculture.Nat. Commun. 2017; 8: 1290Crossref PubMed Scopus (273) Google Scholar] does not alter these results. Sustainable food systems will require profound changes in people’s consumption patterns and lifestyles, but this is true regardless of the farming methods used and does not change the fact that organic often requires more land than conventional agriculture for the same quantity of food output. Beyond the yield gap, there are further environmental problems jeopardizing SDG 15 caused by organic farming. Especially in organic potato and horticultural production, toxic copper-based pesticides are widely used to control fungal diseases [33.European Food Safety Authority (EFSA) et al.Peer review of the pesticide risk assessment of the active substance copper compounds copper(I), copper(II) variants namely copper hydroxide, copper oxychloride, tribasic copper sulfate, copper(I) oxide, Bordeaux mixture.EFSA J. 2018; 16e05152PubMed Google Scholar]. Furthermore, a few relevant insect pests in organic farming can only be controlled with certain broad-spectrum biological insecticides that are known to also harm honeybees and other nontarget organisms.ii Climate change will challenge current farming systems. Increasing mean temperatures, changing rainfall patterns, and more frequent weather extremes will create new stresses for crop plants and will also alter pest and disease pressure with dramatic consequences [14.Bebber D.P. et al.The global spread of crop pests and pathogens.Glob. Ecol. Biogeogr. 2014; 23: 1398-1407Crossref Scopus (238) Google Scholar]. Organic farming with more diverse production can potentially increase system resilience to a certain extent [15.Serra T. et al.Differential uncertainties and risk attitudes between conventional and organic producers: the case of Spanish arable crop farmers.Agric. Econ. 2008; 39: 219-229Crossref Scopus (68) Google Scholar]. However, by prohibiting chemical and biotech innovations, organic farming has fewer tools available for rapid which will be required with changing climate in order to major production While some aspects of organic agriculture in the EU contribute to the achievement of the SDGs, features could jeopardize the achievement of SDGs 2, 13, and 15 in Especially in of global climate and biodiversity, the negative indirect effects of additional land-use change may outweigh the positive direct so that a large-scale switch to organic farming in the EU could possibly turn out to be a disservice to global sustainability. in breeding technologies can contribute to the potential negative impacts of organic farming on certain of the breeding for the of organic agriculture, including the of plants of organic food and PubMed Scopus Google Scholar], could be more through genome and new breeding innovations could reduce organic risk of more land conversion by the yield including systems such as and a of tools on breeding methods and further for of controlled or to the mutagenesis of or the of et genome and plant breeding in Rev. Plant 2019; PubMed Scopus Google Scholar] rapid crop regardless of the agricultural production For certain that require only the targeted of a this potential has already been only a few years the of genome techniques et for of food 2020; Scopus Google Scholar]. plants are under from and while the use of synthetic pesticides is with organic farming. pressure is in climate that the rapid spread of or to it will further Many are to be with pests and by if current of spread [14.Bebber D.P. et al.The global spread of crop pests and pathogens.Glob. Ecol. Biogeogr. 2014; 23: 1398-1407Crossref Scopus (238) Google Scholar]. of the used in organic farming to control crop damage have impacts on and environmental could have a rapid positive on pest and disease in crop plants without negative environmental and in other they could breeding that would make it for organic farming to contribute to SDGs 2, 13, and 15 of organic food and PubMed Scopus Google Scholar]. is the which to in The is a in a and has been widely used in breeding R. an to 2017; PubMed Scopus Google Scholar]. with genome techniques in such as and other disease et of in to 2014; PubMed Scopus Google et of to in Res. PubMed Scopus Google et al.The to is a on and 2008; Scopus Google Scholar]. broad-spectrum to in an disease in and by changing only a few in the of R. et to in using genome 2019; PubMed Scopus Google Scholar]. The can no of these and the for its Many more of pest and disease through [1.Purnhagen K.P. Wesseler J.H.H. 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EU regulation of new plant breeding technologies and their possible economic implications for the EU and beyond.Appl. Econ. Perspect. Policy. 2020; (Published online September 28, 2020. https://doi.org/10.1002/aepp.13084)Crossref Scopus (15) Google Scholar]. to the it is excluded from the in the with the majority of its it only to its on GMOs, not of new GM crop For example, on the not only a the of GM but also the Commission to to any new GMO and not to the risk assessment methods have been the majority in both relevant EU is rather the of GMOs, which that a majority is also to a of organic to allow the inclusion of new breeding techniques [1.Purnhagen K.P. Wesseler J.H.H. EU regulation of new plant breeding technologies and their possible economic implications for the EU and beyond.Appl. Econ. Perspect. Policy. 2020; (Published online September 28, 2020. https://doi.org/10.1002/aepp.13084)Crossref Scopus (15) Google Scholar]. 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