To: 2nd November 2021

Ms Uma Devi,

Chairperson,

Genetic Engineering Appraisal Committee,

Ministry of Environment, Forest & Climate Change,

Government of India.

Dear Madam,

Sub: Companies permitted by GEAC to sell particular kinds of authorised GM cotton seeds are now found to be selling unauthorised and illegal HT Bt cotton also – Demanding strict and immediate action on such entities – reg.

Greetings! This is with regard to news reports that indicate that a GEAC-authorised company Raasi Seeds has been found to be selling unauthorised and illegal HT Bt cotton seeds in Maharashtra. Reports indicate that RCH 608 and RCH 797 samples were detected with CP4epsps herbicide tolerant gene in testing by the Maharashtra agriculture department.

https://www.facebook.com/watch/?v=608232680628930 (News18 Lokmat channel’s news report dated Sept 23, 2021, on HT cotton from News18 Lokmat Channel’s official page)

In the past, Andhra Pradesh government had issued notice to companies like Nuziveedu and Kaveri for their seed samples containing unauthorised Herbicide Tolerance gene (February 2018). We do not know what happened subsequently however.

The FISEC (Field Inspection and Scientific Evaluation Committee) set up by Department of Biotechnology at the behest of Prime Minister’s Office had earlier in 2017-18 concluded that the illegal hybrids collected from the field could be grouped into two major groups indicating a very narrow genetic base reflecting organised breeding activity by a couple of companies. While this is so, there has been no concrete action taken by any agency including GEAC of withdrawing authorisations or licenses issued to these companies. Incidentally, this report has not been uploaded onto the regulators’ websites and it is unclear why this is not a public document, which can be used by alert civil society organisations to help regulators perform their duties diligently.

We have been saying for a long time now and have written to the FISEC set up to look into the matter, that it is easy enough to curb and stop the illegal spread of HT cotton cultivation in India if the Government regulators crack down on the seed supply systems, starting from hybrid cotton seed production areas of the country. The number of districts in India in which hybrid cotton seed production takes place is a handful. Starting from checking in the seed production plots randomly through rapid (strip) tests to begin with, followed by drawing samples in ginning and seed processing units, it is easy enough to locate lots that are creating and selling HT cotton seeds.

We demand that GEAC put into action the long-pending crackdown on the illegal HT cotton seed supply systems in India, and also that previous authorisations accorded to companies like Raasi seeds, Nuziveedu Seeds, Kaveri Seeds and others caught selling HT cotton seeds be cancelled, and licenses revoked so that such deterrent penal action prevents any further spread of illegal GM seeds. We would like to remind GEAC and all its implementation arms for regulation of gene technologies that this is the time when seed processing would begin after harvest, and this is the time to take action. Needless to say, citizens are waiting anxiously to see if the regulators are serious and responsible about their mandate at all or not. We also request you to please let us know what action has been taken in response to this letter. Thank you.

Sincerely,

Kavitha Kuruganti

8880067772

kavitha_kuruganti@yahoo.com

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