To:

Shri Piyush Goyal

Union Minister of Commerce & Industry

Government of India.

Dear Shri Piyush Goyal,

Date: 14th July 2025

Sub: India should not agree to any self-certification regimes with regard to GM-Free Status of American exports to India – Nor should India accept any import of GM feed/DDGS/Alfalfa – Concerns – Reg.

Greetings! We have been following news reports that seem to indicate that India is managing to hold out against American pressure with regard to GM crops/seeds/products thereof, which are in any case highly subsidised too, in the current trade deal being negotiated between India and the USA. We will wait to see if the Government of India actually protects the interests of Indian farmers, consumers and industry/exporters when the final deal is put into place.

We would like to reiterate that the ongoing trade deal negotiations between India and US stands to not only potentially compromise India’s livestock and human health, but also compromise India’s export markets, if our Government does not stand firm against GM imports, including against the proposed modality of self-certification of GM-Free status.

Self-certification of GM-free status is extremely unreliable from a country like the USA without any segregation being maintained in the supply chains between GM and non-GM. India should rely on accredited certification bodies for non-GMO status, and should also adopt its own stringent testing mechanisms at the ports of import of certified non-GM consignments too. Self-certification declaration will also lead to import of contaminated GM produce from US to India too.

We also object to concessions under consideration for US Alfalfa hay and Distiller’s Dried Grains with Solubles (DDGS) for animal feed. Import of GM animal feed from elsewhere will negatively impact our local producers. For instance, every year the US government subsidizes US farmers tens of billions of dollars for animal feed. Opening India for GM feed imports will be disastrous for our farmers. This will lower market prices for our farmers which will further discourage domestic production of animal feed leading to a vicious cycle. GM alfalfa in US has led to large-scale contamination of non-GM alfalfa as per a US Department of Agriculture study itself1. US has faced rejection of exports due to GM detection in its alfafa too2. The letter 3 we wrote to GEAC five years ago on strictly regulating import of GM feed including DDGS gives evidence of the adverse changes that happen in animals as a result of them consuming GM animal feed. Such GM feed poses a threat not merely to India’s livestock, but also to humans via the entire food chain which includes milk and milk products, eggs, and meat: chicken, mutton, pork. The Supreme Court’s Technical Expert Committee’s analysis of biosafety dossiers that have been green-signalled by the regulatory body GEAC based on GM promoter’s own data show that no safety-related conclusion can be drawn from the data presented on animals fed with GM feed, and in fact, further independent, longer-term studies are needed for such a conclusion to be arrived at.

When India’s GM-Free status (except in cotton) gets compromised through any concessions provided to the USA now on its GM crop/feed imports, there are obviously implications for our exports to markets that prefer non-GM supply chains.

India should firmly reject any terms and conditions that ask the Union Government to bypass domestic regulations, and that seek to compromise our citizens’ interests.

Sincerely,

Rajesh Krishnan,

Co-Convenor,

Coalition for a GM-Free India

07559915032

Copy –

1. Shri Rajesh Agarwal – Additional Secretary, Ministry of Commerce and Industry

References – 

1 https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0143296

2 https://www.wsj.com/articles/u-s-hay-exports-to-china-shrivel-up-1418598477

3 https://indiagminfo.org/coalitions-letter-to-geac-against-gm-animal-feed-imports/

Website: www.indiagminfo.org, email : indiagmfree@gmail.com,  Facebook page – GM Watch India