Coalition’s Letter & Presentation to “Field Inspection and Scientific Evaluation Committee” looking into illegal Herbicide Tolerant (HT) Cotton in India

Civil society representatives were called to a meeting of a new Committee called FISEC (Field Inspection and Scientific Evaluation Committee) which was set up at the PMO’s behest to look into illegal GM HT cotton cultivation in India. There have been years and years of inaction on this by our regulators incl. state agriculture departments. It is not clear who is in the FISEC and why certain invitees were called. From the discussions that unfolded in this meeting yesterday, it is apparent that this Committee does not want to even acknowledge the risks associated with such illegal HT cotton cultivation, given their observations that we should not discuss evidence of glyphosate ill effects from other countries etc!

Our Presentation to FISEC is downloadable here.



To:                                                                                                                                          November 29th 2017


Chairperson & Members of Field Inspection & Scientific Evaluation Committee.



Dear Madams and Sirs,


Sub: Demand for Effective Action to Stop Any HT GM Crop Cultivation in India


It was in 2001 that illegal Bt cotton cultivation on a large area in Gujarat was noted by regulators in India – this was a time when field trials for Bt cotton were still underway, and testing incomplete. However, regulators were delivered a fait accompli by seed industry players against whom no effective action has been taken to this day. Bt cotton was regularised in 2002, with inadequate and unscientific testing. We are now seeing a similar situation with Herbicide Tolerant cotton in India, except that the situation is worse. Even though the first complaints about illegal HT cotton were lodged with GEAC in 2009 itself [1], recent RTI replies and media statements by the regulatory body kept denying [2] that GEAC is even aware of such illegal cultivation, despite GEAC meeting minutes themselves recording and discussing the complaints!

The problem of illegal HT cotton cultivation was allowed to fester and grow by the absolute inaction of the regulators. Lack of any effective deterrent action also meant that those in the biotech seed industry who have a stake in spreading such GMOs illegally in the hope that approval would be provided sooner or later, and to profiteer in any case in the meantime, have expanded their illegal activities brazenly, in contempt of the law of the land. Regulatory inaction is to be blamed squarely for this. It is clear that Indians are being forced to consume such illegal GM foods when HT cotton oil enters the food chain (as per FSSAI, all GM foods are illegal in any case, including the GEAC-approved imported GM oils). We are alarmed to note that meanwhile, GEAC is also discussing applications for import of HT soybean, grain as well as oil!

Now, the Review Committee on Genetic Manipulation (RCGM), with its Field Inspection and Scientific Evaluation Committee (FISEC), wants to assess the ‘veracity’ of the spread of unapproved HT cotton and recommended strategies and measures to be adopted. We believe that the veracity is under no question, not now and not earlier when lab tests have already ascertained the spread of unapproved HT cotton. We are also left wondering what is the legal status of this FISEC in its ability to recommend and control the spread of illegal HT cotton, when GEAC which is the responsible authority is unsurprisingly silent, as usual.

The Coalition for a GM-Free India calls for immediate action to weed out HT cotton from India. The reasons why this should be done are clear:

  • There is adequate scientific evidence of the ill effects of HT crops and associated herbicides in general in terms of their health and environmental implications, and glyphosate in particular. Recent research publications have showcased adequately the major problem of glyphosate-resistant weeds worldwide (“superweeds”), about antibiotic resistance related to several herbicides including glyphosate which should ring huge warning bells in countries like India, about soil health impacts, about carcinogenic potential of glyphosate including a study with Indian scientists’ involvement etc. Several of the studies point to the problem cropping up even at sub-lethal doses of the active ingredient as well as the problem with surfactants and other so-called ‘inert’ materials of herbicides like Glyphosate [3] [4] [5] [6] [7] [8] [9] [10] [11] [12];
  • We in India have additional socio-economic considerations to take into account, especially with regard to employment potential for poor women farmers in our agriculture, in the context of HT crops/cotton. Credible committees have repeatedly rejected the idea of herbicide tolerant crops and recommended that the regulators do not permit them in any form.
  • Importantly, the use of illegal HT cotton seed is also accompanied by illegal use of glyphosate in the country. This illegality also needs to be curbed to strengthen regulation around toxic pesticides.
  • There is also the need to take decisive action on HT cotton for another reason – that of the regulators having to establish their credibility, and to seriously discharge their responsibility, and so that effective deterrents may be created that prevent future illegal spread of GMOs in India.

Having stated why HT cotton should be tackled on a war-footing in the country, we present our demands as interventions needed immediately, as well as in the medium and long term.

Immediate Action –

  • Wide spread campaigns to be initiated immediately on ill effects and illegality of HT crops through TV, cyber media and print media in vernacular languages (Risks associated; Illegalities, how and why it is illegal; Details of punitive actions and provisions)
  • Encourage farmers to deposit HT cotton seeds at specially opened government counters – Cost of seed purchase to be borne by government – destroy the collected material.
  • Cotton processing units – Ginning factories (a key place to collect the seeds), textile mills and oil mills to be warned. Punitive actions against them to be declared immediately because as per EPA, they should not be processing this illegal material. As per FSSAI, it is illegal for oil mills to process and sell cotton seed oil.
  • Be extra vigilant and develop an Informers’ network with the help of Agriculture Departments in the states, to catch illegal seed sales networks – this has to be done between February and August 2018 –There should be immediate prosecution initiated with FIRs lodged, and cases initiated. Punishments under EPA 1986 should be meted out, to be a deterrent. Withdrawal of seeds sale licenses permanently should be taken up.
  • Lint collected from seized material should be sold with label “illegal produced HT cotton lint”. This will create due awareness in the society.
  • Ban Glyphosate immediately, which is also being used illegally along with illegal HT cotton seeds – this is the only effective action that will resolve both illegalities of unapproved pesticide usage as well as unapproved seed sales/sowing.

Medium Term Action –

  • Special vigilance should be created over seed production plots which are easy enough to trace during Kharif 2018. Thousands of acres are sown as hybrid seed production plots to produce seed for next season. It is well known which districts and staets harbor 95% of India’s hybrid cotton seed production. Illegal HT cotton seed production should be destroyed through special squads set up.
  • HT cotton seeds are produced in India mainly by local seed companies through illegal contract with farmers. They should be black listed permanently and their license should be withdrawn with immediate effects. Punitive actions be declared and exercised/ implemented properly.
  • Farmers, who voluntarily disclose should be exempted. Otherwise they should also face the punishment.
  • All loss to the farmers should be compensated by seed companies.
  • Tightening of monitoring through special teams set up in each state, with proper training & a clearly-defined ToR – Testing (Elisa) kits should be made easily accessible and free to citizens- consumers, farmers and processors.

Long Term Action –

  • No HT crop field trials to be permitted in India as asked by the Supreme Court Technical Expert Committee and as recommended by the Swaminathan Task Force report (2004).
  • Significant Improvements should be made in quarantine regulation and proper implementation. The first entry points of illegal GM seeds are land, sea and air routes, where quarantine regulations are failing. Customs officials need to be trained. Special drive to initiate punitive action on those bringing in seeds illegally is needed, so that it is a deterrent for others.
  • Monitoring systems to be set up with reporting of the situation should be made mandatory. Institutional Biosafety Committees, State Biotechnology Coordination Committees and District Level Committees as per Rules 1989 [13] should be made to function and function effectively. Special squads and monitoring teams should be created and details put in the public domain. If not adhered to, mechanism of penalties must also be laid down for the administration/regulators.
  • Citizens in general and farmers in particular should be made aware of the Acts, Rules and penal clauses through strong campaigns before sowing season. Enroll the assistance of farmer organisations also for such a campaign.
  • Update of IGMORIS (Indian GMO Research Information System) website in the public domain as ordered by the Supreme Court too.
  • A liability regime to be evolved wherein the technology developer will be made liable for any leakage of seeds and their illegal spread, with progressively higher penalties.
  • Training of concerned department officials around legal provisions as well as technical matters is to be established. Testing facilities to be improved and made accessible to all.
  • Special orientation on ‘How to handle illegal cultivation’, should be given to state level teams.
  • Improvement in seed regulation and proper implementation are an imperative.
  • NARS should evolve sustainable weed management solutions within an agro-ecological framework
  • GoI has to evolve some policy solutions around supporting labour costs, appropriate implements for weed control, supporting labour banks like the Green Army in Kerala etc.




Neha Saigal                                                                                            Ajay Etikala

Member, Coalition for GM Free India                                              Member, Coalition for GM Free India

Mob: 7760968772                                                                              Mob: 9971615133



[1] 98th Meeting of the GEAC, 2009 ;

[2] CSA complaint on illegal spread of Herbicide Tolerant cotton, 2013 ;
[3] We heard about illegal HT cotton cultivation recently, says Genetic Engineering Appraisal Committee Chairperson Amita Prasad, Oct 2017 ; Financial Express
[4]  IARC Monographs Volume 112: evaluation of five organophosphate insecticides and herbicides, 2015 ; International Agency for Research on Cancer, World Health Organization -
[5] Final Report of the Technical Expert Committee (TEC) , 2012 ;
[6] Exposure to Glyphosate, Chemical Found in Weed Killers, Increased Over 23 Years, 2017 ; University of California San Diego, Health
[7] Nature, July 2016 ; Multiomics reveal non-alcoholic fatty liver disease in rats following chronic exposure to an ultra-low dose of Roundup herbicide
[8]  New research finds common herbicides cause antibiotic resistance 2017 ;

[9] Glyphosate, Pesticide Action Network Monograph, 2016 ;
[10] Studies on glyphosate-induced carcinogenicity in mouse skin: a proteomic approach

[11] Overview of glyphosate-resistant weeds worldwide 2017 ;
An Assessment of weed flora 14 years after the introduction of glyphosate-tolerant cotton in Australia

[12] Proteomic analysis of the soil filamentous fungus Aspergillus nidulans exposed to a Roundup formulation at a dose causing no macroscopic effect  : a functional study, 2017 ;


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