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GM Food & Feed Comments from the Public Comments received on Maize MON863 x MON810 x NK603 1. Private person, NL 2. Luce, NL 3. Gothenburg University, dept. of Clinical Nutrition, SE 4. University

NK 1. The application, in combination with the proposed chemical application, is therefore submitted as a single submission (no different from the previous application in 2004) to make an overall risk assessment. No new study has been brought forward to support the application and therefore the risk assessments of the above crops (excluding maize) continue as in the previous application. c. Public Comment: “We're asking for these new tests to be done on at least some of the more important crops, so that the safety of all the crops, including those which have been tested, is also checked.” d. Public comment on the following points: 2. It is not the intention of the Commission to restrict the genetic engineering of food crops and feed crops. “In order for food and feed genetically modified organisms (GMOs) to play an important role in the public health, the environmental and economic welfare of our citizens, the Commission shall examine and establish the appropriate conditions and mechanisms for the use of these organisms in food and feed in the Union and recommend to the European Communities the measures that should be taken to prevent their introduction, import and use in the Union. It shall also examine in greater detail and from a broader perspective the safety assessment of these GMOs, as well as public concerns concerning their introduction and use.” 3. The author (Luce) suggests several other new tests for safety, but all have limitations and do not address as fully the problems in the first application which are the most important of all. These include: a) the tests on maize which tested positive for two new traits in 2009 and 2012 in the Netherlands. These crops are not included in the main assessment, because they are small, do not produce enough and are of low productivity. b) the tests on a total of 22 new GMO crops proposed for the 2009 assessment (not including MON810 maize). These crops would increase genetic diversity and the amount of traits on the European market. c) testing for the presence of new, unknown toxins (see para 4 above), not in the current test. The testing of non-traditional pesticides, especially those not tested before, would need an even wider scope. 4. The safety of these crops would be assessed if GMO-derived foods are subject to the existing European Union legislation, not if the legislation is harmonized with this application. 5. In the light of the above, we recommend that all other tests not be carried out. We urge that the precautionary principle be applied to GMO-derived products, i.e.

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Genetically modified (GM) food and feed refers to organisms whose genetic material has been altered in a way that does not occur naturally through mating or natural recombination.

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