The Northern Ireland Grain Trade Association represents the importers, manufacturers and distributors of feedstuffs to livestock producers in Northern Ireland. The association is deeply concerned that the EU is proposing to allow member states to restrict or ban the use of authorised Genetically Modified food and feed products.

Northern Ireland imports over 90% of the feed materials it consumes and is totally reliant on the global grain market. Two million tonnes of feed materials enter the province each year from all corners of the globe and much of this material is derived from genetically modified crops grown in other countries. This material is permitted for use in the EU because it has undergone a rigorous risk assessment by the European Food Standards Authority and has been approved as safe for use in food and feed.

Like all Member States we are strongly reliant on these GM imports for the viability of our livestock industry, with 90% of feed produced containing some GM material.              Soybean is the most important protein with 230 million tonnes grown globally – mainly in North and South America. Genetic modification is the norm for this crop – only around 2 M tonnes can be classified as Non GM (less than 1% of global production) This involves segregation of the crop at harvest and Identity Preservation throughout the supply chain.

Imported maize and maize by-products from the starch and ethanol industries are also key protein sources and bring the EU consumption of feed materials derived from GM crops to 32 million tonnes. Regions which reject these GM imports will be unable to sustain intensive livestock production and will face food shortages and inflated food prices.

The only demand for non GM food comes from within the EU where the feed industry offers the option of non-GM feed supply chains for specific demand. However interest in Non GM food has declined as the retailers perceived that a Non GM requirement adds cost without adding any value. Given that the market solutions already exist and non GM foods can be supplied where necessary the proposed regulation is both unnecessary and damaging.    

Response to Questions

1.The sectors affected by  member states banning GM food and feeds include, 

a. Feed Importers and who would face massive logistical challenges and increased costs in shipping feed materials into the different regions of the EU. 

b. Feed manufacturers who may not be able to trade into neighbouring states and could find it impossible to formulate feeds to meet the nutritional requirements of livestock as many key ingredients would no longer be available. 

c. Farmers and consumers - Increasing the demand for non GM feed would drive up the premiums which it commands and drive up costs to primary producers and ultimately the consumer.

2. Price of Non GM feed

Currently the premium for Non GM soya is around £100/tonne - this adds about £30/tonne (15%) to the price of a typical non GM ration . However any increase in demand would immediately inflate these premiums but regardless of price, the reality is that there would not be sufficient material to meet demand in those countries ruling against GM.

3. Additional Costs

The additional costs of livestock production, food processing, distribution, retailing and the regulation necessary to police the ban would be astronomic and so far reaching as to be impossible to quantify.

4. Risks and Uncertainties

The distortion of trade which would result from some regions regulating against the use of GM would jeopardise the future of EU livestock farming, drive up prices and cause chaos in terms of logistics and labelling of product throughout the whole EU agrifood sector.         Food shortages and imports of livestock products from third countries (where they would have been fed on GM materials) are inevitable.  

5. Substitutes for GM feed

Intensive livestock production throughout the world depends on soybean as the principal protein source. There is no alternative which can supply the volume and quality of protein and any restriction to accessibility of soya will limit livestock production and raise costs. 

Yours Sincerely,