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Testbiotech

Testbiotech is an independent scientific organization focusing on impact assessments of biotechnology.

Lobbying Activity

Meeting with Martin Häusling (Member of the European Parliament)

19 Nov 2025 · Veranstaltung zu NGT Annex I

Testbiotech urges stricter rules for genetically engineered food products

14 Oct 2025
Topic — This EU consultation reviews ways to simplify food safety regulations and market access procedures.
Message — The group demands mandatory risk assessment and labeling for all products created using genetically modified organisms. They also want all safety data and detection methods to be publicly available.12
Why — Full data access would allow the group to challenge industry safety claims effectively.3
Impact — Food manufacturers would lose the legal protection to keep specific product details confidential.4
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Meeting with Ana Vasconcelos (Member of the European Parliament)

20 May 2025 · NGTs

Meeting with Miriam Lexmann (Member of the European Parliament)

19 May 2025 · New genomic techniques and their impact on health and environment

Meeting with Manuela Ripa (Member of the European Parliament)

30 Apr 2025 · NGTs

Meeting with Bert-Jan Ruissen (Member of the European Parliament)

26 Mar 2025 · Agriculture

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

25 Feb 2025 · NGTs

Meeting with Manuela Ripa (Member of the European Parliament)

16 Feb 2025 · NGT

Meeting with Biljana Borzan (Member of the European Parliament)

19 Nov 2024 · NGTs

Meeting with Martin Häusling (Member of the European Parliament) and Bund für Umwelt und Naturschutz Deutschland e. V. and Eberhard Karls Universität Tübingen

24 Sept 2024 · BUND- Onlineveranstaltung: "Weniger Regeln für Neue Gentechnik in Europa? Kritik aus der Wissenschaft“

Meeting with Karsten Lucke (Member of the European Parliament)

9 Jan 2024 · NGTs

Meeting with Martin Häusling (Member of the European Parliament)

4 Dec 2023 · Austausch zu NGT

Meeting with Günther Sidl (Member of the European Parliament)

25 Oct 2023 · NGTs

Meeting with Katarína Roth Neveďalová (Member of the European Parliament)

25 Oct 2023 · New Genomic Techniques

Meeting with Juozas Olekas (Member of the European Parliament, Shadow rapporteur for opinion)

24 Oct 2023 · New plant breeding techniques

Meeting with Margrete Auken (Member of the European Parliament, Shadow rapporteur)

19 Sept 2023 · Pharma legislation

Testbiotech Warns Against Deregulating New Genomic Technique Plants

31 Aug 2023
Topic — A proposal for a new legal framework regulating plants produced by certain new genomic techniques.
Message — Testbiotech demands mandatory risk assessment for all genetically engineered organisms to ensure safety. They call for the removal of the deregulated Category 1 and mandatory labelling.12
Why — Stricter oversight preserves their influence and mission as an independent biotech impact assessor.34
Impact — Consumers lose freedom of choice and smaller breeders face new patent monopolies.56
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Meeting with Christophe Clergeau (Member of the European Parliament)

19 Jul 2023 · Nouveaux OGMs et biotechnologies

Meeting with Martin Häusling (Member of the European Parliament) and European Coordination Via Campesina and

6 Jul 2023 · Teilnahme Veranstaltung zu Patenten und Neuer Gentechnik

Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)

6 Mar 2023 · VTC Meeting: New Genomic Techniques (NGTs)

Meeting with Martin Häusling (Member of the European Parliament) and foodwatch

17 Nov 2022 · Konferenz zu GMO-Free Europe

Meeting with Joanna Stawowy (Cabinet of Commissioner Janusz Wojciechowski), Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski)

24 Oct 2022 · New genetic engineering techniques (NGTs)

Meeting with Joanna Stawowy (Cabinet of Commissioner Janusz Wojciechowski), Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski)

20 Oct 2022 · Potential and risks of new genetic engineering techniques (NGTs)

Meeting with Pascal Durand (Member of the European Parliament)

29 Jun 2022 · New genomic techniques, environmental and health risks - APA only

Meeting with Joanna Stawowy (Cabinet of Commissioner Janusz Wojciechowski)

8 Apr 2022 · New Genomic Techniques

Meeting with Manuel Bompard (Member of the European Parliament)

22 Sept 2021 · Échange de vue sur la question des nouveaux OGM

Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)

15 Sept 2021 · VTC meeting on New Genomic Techniques

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

15 Sept 2021 · New genomic techniques

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

24 Feb 2021 · New genomic techniques

Meeting with Agne Razmislaviciute-Palioniene (Cabinet of Commissioner Virginijus Sinkevičius), Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius)

20 Jan 2021 · To discuss new genomic techniques (NGTs) and their impacts

Response to Farm to Fork Strategy

16 Mar 2020

The Farm to Fork strategy must ensure that both 1st and 2nd generation genetic engineering (GE) techniques need to stay regulated under EU law, ensuring risk assessment, labelling and post-market monitoring. This is important in order to achieve the F2F strategy's objectives of increasing transparency and consumer information, and reducing the environmental footprint of EU agriculture and food systems. 2nd generation GE: "Novel genomic techniques" In November 2019, the Council of the EU requested the Commission to submit, by 30 April 2021, “a study in light of the Court of Justice’s judgment [...] regarding the status of novel genomic techniques under Union law”. New genomic techniques are frequently hailed by stakeholders from industry and science for their supposed benefits. They are also said to be less risky than conventional breeding because of their precision. It is argued that only those applications which insert novel genes (SDN3) should be regulated. SDN-1 and SDN-2 should be deregulated according to industry’s wishes. However, as our new report "Overview of genome editing applications using SDN-1 and SDN-2 in regard to EU regulatory issues" shows, the need for regulation of SDN-1 and SDN-2 applications does not result solely from the ECJ judgment, but rather is also scientifically imperative. Higher precision in changing the genome does not necessarily result in greater safety or higher success rates. The report uses selected examples to provide a greater understanding of possible implications for environment, health and ethics resulting from SDN-1 and SDN-2 applications. Examples are grouped into five categories: Implications on the food web Imlications for plant communication and interaction with the environment Enhanced fitness Persistance and propagation in the environment Ethical implications, including animal health and welfare, nature protection and rights of future generations The authors conclude that there are several important reasons why organisms derived from applications of SDN-1 and SDN-2 should all undergo mandatory risk assessment. In short, the pattern of intended and unintended changes and the resulting new combinations of genetic information arising from genome editing will, in most cases, be different in comparison to those derived from conventional breeding. These differences co-occur with biological characteristics and risks that need to be fully investigated before any conclusions on the safety of the new organisms can be drawn. Detailed examination of an organism’s genetic and overall biological characteristics, starting with the process that was used to generate the organism, is needed to decide whether the organism is safe. The requirements for regulation as foreseen by current GMO law in the EU is mandatory whether or not additional DNA sequences were inserted. In addition, a broad range of ethical and social issues also have to be taken into account by the regulatory decision-makers. 1st generation GE: Gaps in risk assessment The F2F strategy should also aim at closing existing gaps in risk assessment of GE organisms. The research project RAGES recently showed that EU assessment & management of 1st generation GE plants has failed to sufficiently deal with the risks to public health and the environment. The main finding of the project which was carried out 100% independently from the biotech industry: The current GMO approval process does not take all relevant risks into account. Instead it mostly confines its focus to those risks that can be most easily assessed. Consequently, current standards of risk assessment are not sufficient to determine the safety of GE organisms. They fail to fulfil legal requirements to apply the “highest possible standard” to “any risks which they present”. Therefore, the F2F strategy should also include a re-evaluation of current GE market approvals, assessing their overall and combinatorial impact on the food and feed chain and the environment.
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Response to Transparency and sustainability of the EU risk assessment model in the food chain

17 Jan 2018

In principle, Testbiotech welcomes this initiative. However, its priority must be to strengthen the precautionary principle. There are several possibilities to move forward: For example, research programs focussing on the protection goals should become crucial element. These research programs have to be independent of the interests of regulated industries, but should enable participation of civil society in planning and evaluation. Another issue in this context, is the improvement of the feedback processes in the area of GMO risk assessment. Currently, the processes involving the public are mostly formalistic, and neither aim to deal with relevant arguments nor encourage public contributions. In general, if there are concerns from the public about current practise of risk assessment, the Commission should not just consider transparency and communication, but also address the substantive underlying issues. Even though Regulation 178/2002 aims for highest standards in food security by highlighting the relevance of uncertainties and the role of precaution, this is rarely reflected in current practise of EFSA.
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Response to Draft Commission Directive updating the environmental risk assessment of GMOs

8 Dec 2016

Based on detailed analysis, Testbiotech rejects the current proposal of the EU Commission in most of its elements and instead make the following recommendations for future environmental risk assessment: Avoid oversimplification: It has to be acknowledged that the absence of observable effects cannot be interpreted as evidence for the safety of the plants. Risk assessment has to be based on a broad range of empirical data and mandatory investigations that can cast a 'wide but finely meshed net' at each level of risk assessment, and not be organised in a linear model. The assessment has to include worst case scenarios. Make empirical testing mandatory: Clear mandatory criteria must be defined for each step of risk assessment (laboratory, greenhouse, small-scale experiments, non-target organisms, pollinators, wildlife species etc.). Define a proper step-by-step process: The impact of climate and specific regional conditions on the plants as well as interference with other biotic or abiotic stressors should be investigated under controlled conditions before genetically engineered plants are released. Assess combinatorial effects: Special attention must be paid to synergistic and cumulative effects, such as those stemming from mixtures of herbicide residues, the stacking of Bt toxins or interactions between Bt toxins and herbicide residues. Take on board new scientific insights: Some of the most dynamic new scientific findings are in epigenetics, the concept of the hologenome (looking at the organism and its microbiome as a unit) and RNAi effects. There have been significant advances made in understanding signalling pathways and related implications for e.g. plant defence mechanisms. All these areas are relevant for the risk assessment of genetically engineered organisms and should be included in Annex II of the Directive. Apply new methods: A much broader set of empirical data is required to assess the technical properties and genetic stability (including metabolic profiles) of genetically engineered organisms, their reaction to environmental stress conditions and their interactivity with the environment. Define cut-off criteria: Criteria for the rejection of applications must be integrated into the overall concept. It must be made sufficiently clear to applicants at an early stage that invasive plants that are and/or persistent will be rejected as will plants that foster unsustainable agricultural practices. Establish improved data requirements: Fully validated methods for measuring new gene products, such as new proteins, have to be made available to enable independent controls. In addition, independent controls have to be integrated at each step of data generation. Make all data available: It must be made mandatory for the companies to make all risk relevant data available, including data from investigations that do not show results that the companies might have expected. Make material for research available: As soon as applications are filed, the company must make sure that access to relevant material is available for independent research. If the EU Commission wants fulfil its obligations, the following levels of “technical progress” have to be considered: (i) New methods that were developed to improve risk assessment (ii), new areas of risk assessment that were not central issues when the Directive was adopted (iii), new evidence showing that specific issues have to be considered in more depth than previously thought (iv), new scientific findings indicating specific uncertainties or limits of knowledge that require a greater level of precaution. Further, in regard to the interplay of pesticide regulation and GMO regulation, the proposal made by the EU Commission is not in line with the Council conclusions and it also in contradicts the opinion of EFSA´s experts. For more details see: www.testbiotech.org/node/1776
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Meeting with Vytenis Andriukaitis (Commissioner) and

28 Sept 2015 · New breeding techniques, GMO