A group of experts representing business, farming, certification, academia, science and civil society have lodged a formal complaint against the UK’s Food Standards Agency (FSA), raising serious concerns about its public consultation process on genetically modified precision bred organisms (PBOs)^. 

They say the consultation breaches Cabinet Office Consultation Principles and are calling on the Agency to withdraw it until multiple issues can be resolved

The complaint, submitted to the Agency and copied to the Department of Health and Social Care (DHSC) to whom it reports, alleges multiple breaches of Cabinet Office Consultation Principles and serious misrepresentation of the facts, which call into question the integrity of the Agency and its stated goal of transparency and truthfulness.

The ten signatories – including familiar and trusted names in the farming and food world including Doves Farm Organic, Sheepdrove Organic Farm, Riverford Organic Farmers and Slow Food in the UK – contend that the information within the consultation pack is misleading, specifically regarding the nature of precision breeding and the science around its safety. 

The complaint questions the claimed independence of the FSA’s Advisory Committee on Novel Foods and Processes (ACNFP) and its subcommittee, involved in providing scientific advice to the FSA on the safety of PBOs. 

The group alleges that the FSA has, in several instances, “seriously misrepresented the results of its own public surveys, and a literature review it commissioned into detection of precision bred organisms, in order to create a narrative designed to influence the outcome of the consultation”.

The group also says that consultation is “overly technical” … “creating a barrier for the general public”, observing “that accessibility and clarity are paramount for genuine public participation”.

A compressed 8 week consultation process could reduce opportunity for public engagement, says the group, while its timing – over Christmas and New Year – is, it says, at odds Cabinet Office Principles.

The complaint also criticises the FSA for not performing a full impact assessment on its plans to remove labelling and traceability from genetically modified precision bred organisms in the food and feed system.

Instead, the group says, the FSA has relied heavily on a highly discredited impact assessment performed by Defra in 2022 and rated as “not fit for purpose” by the Regulatory Policy Committee. 

The deregulation of genetically modified PBOs and the removal of labelling and end-to-end traceability in the food system, the complainants argue, will have a domino effect throughout the food system affecting non-GM, organic, artisanal and natural food producers who wish to avoid PBOs, “removing consumers’ right to choose whether or not to purchase and consume these foods as well as farmers’ right to choose whether to feed them to their livestock”.

One of the signatories, Michael Antoniou, professor of Molecular Genetics and Toxicology at King’s College London, said: “Not only is this consultation misleading and anti-democratic, but it also misrepresents the science underpinning gene editing. Gene editing is prone to causing a wide range of unintended DNA damage, altering patterns of gene function and consequently the biochemistry of the organism, which could lead to the production of unexpected toxins and allergens. Citizens should be protected against these risks.”

Pat Thomas, Director, Beyond GM/ A Bigger Conversation, said: “Public consultations are a valuable way to understand citizen’s views, but they must be conducted with integrity and honesty. We are concerned that this consultation falls short of the standards we should be able to expect from the Food Standards Agency, whose motto is ‘food you can trust’. We are also concerned given that the FSA has already voted through its proposed regulatory changes, that this consultation has been designed to take the box of public engagement without any commitment or possibility that public views will be taken into account or have the power to alter the outcome. This too is a betrayal of public confidence.”