Concerns on imports of Genetically Modified (GM) agricultural produce (seeds/grain/feed) and foods, from known commercialised GM crops

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From: GM Free India <>
Date: Tue, 23 Jul 2019 at 16:06
Subject: Concerns on imports of Genetically Modified (GM) agricultural produce (seeds/grain/feed) and foods, from known commercialised GM crops – reg.
To: <>, <>
Cc: Kavitha Kuruganti <>

To:                                                                           July 23rd 2019

1.Shri Alok Vardhan Chaturvedi,

Director General of Foreign Trade,

Ministry of Commerce & Industry,

Government of India.


  1. Shri SP Roy,


Ministry of Commerce & Industry,

Government of India.


Dear Sirs,

Sub: Concerns on imports of Genetically Modified (GM) agricultural produce (seeds/grain/feed) and foods, from known commercialised GM crops – reg.

Greetings! This is with regard to the fact that India is importing consignments of agricultural produce in the form of seeds and/or grain and/or feed and/or foods, of such commodities which have commercialised transgenic versions of the crops being grown on a large scale and also from countries which have a significant proportion of their crop land under these crops growing only the transgenic or genetically modified (GM) varieties. This includes corn/maize, soybean, canola, cotton, papaya, sugarbeet and apple from countries like USA, Canada, Brazil, Argentina, Paraguay, Australia, Spain, Philippines etc.

This is a matter of great concern since declared or undeclared imports could be the route for bringing in GM seeds and products into India, while the stated policy of Government of India is to have case-by-case approvals after regulatory assessments.

While the apex regulatory authority for the deployment of gene technologies is the Genetic Engineering Appraisal Committee (GEAC) in the Ministry of Environment, Forest & Climate Change, under the Foreign Trade (Development & Regulation) Act which is in your jurisdiction, regulation exists for GM imports (notified in 2007). The notification lays down that no GM imports can take place into India, without the approval of competent authorities like GEAC and without an explicit declaration at the time of import.

It is against this background that we approach the DGFT to raise the following concerns.

Some of the illegal GM crop cultivation that we witnessed in India is in crops where no R&D has been done in India. It clearly indicates that such seed has originated through illegal GM imports. For example, GM HT soy being illegally cultivated in Gujarat has not even been approved for field trials in India.


There is clearly a problem with imports coming in from known GM producing countries (USA, Canada, Brazil, Argentina, Paraguay, Spain, Philippines etc.), where a substantial part of the produce is of the GM variants in crops like soy, corn/maize, canola, cotton, papaya, apples, sugarbeet etc.

What is even more dangerous is that SEEDS are being imported of crops for which transgenic variants are being grown on a commercial scale in different countries, in large as well as small quantities. Despite this being a possible source of illegal imports and contamination of our seed stocks and environment, this is being allowed. Apart from the urgent need to stop the imports of viable seeds, there is also a need to put into place of random, sample testing of such imports with required scientific rigour to ensure that non-declared GM material does not come in clandestinely. Right now, India is relying on importers to declare their consignments to be GM, and to walk up to the regulators for approvals if it is GM. This is obviously inadequate to check clandestine imports.

Like mentioned above, what is worrying is that regulatory agencies including the DGFT do not have a testing or institutional mechanism to have a rigorous and active surveillance on every consignment of imports for crops and crop products for which GM variants exist in the world. DGFT is relying on the Customs officials to implement its policies. How is DGFT sure, for instance, that the applicants who asked for GM feed import permission in 2015, and have not yet been given any permission, have not found other ways and means to import such feed into the country?


We find that as regarding transgenic material, institutional coordination is missing between different ministries and agencies right now. DGFT has no institutional wherewithal to implement its own policies and regulations. Customs Division of Department of Revenue or Ministry of Finance are not in the regulatory regime of any kind, despite being the frontline agency for imports. Similarly, Agriculture Ministry is not in the regulatory regimes of DGFT or MoEFCC, though the PPQS (Plant Protection & Quarantine Services) division has its own legal regulation around GM crop imports, which require prior approval from GEAC. It is not clear how they enforce their regulations without coordination with other ministries and regulatory bodies, especially when an importer chooses to illegally import GM material. When it comes to imports, FSSAI, DBT/RCGM and NBPGR also come into the picture on occasion. In the absence of such institutional coordination, it has been seen that GM food materials have been brought in without the permission of GEAC or FSSAI and without any declarations to the DGFT – here, there were even cases where the labels clearly mentioned that the food product could be GM.

It is apparent that there is a need to have one inter-ministerial and inter-agency body that is tasked with monitoring all imports into India, with scientific sampling and testing, to ensure that no GM material gets into India in violation of existing regulations, and in violation of the Cartagena Biosafety Protocol. GEAC itself was visualised to be that body with representation from DGFT, PPQS, FSSAI etc., but from the proceedings of the meetings of GEAC, it is clear that it is not focusing on the dangers of illegal GM imports, nor does it in reality have any power to enforce stoppage of illegalities. Hence, the DGFT should address itself to recommending mechanisms to ensure this.

It is against this background that we demand:

  1. that DGFT organise a meeting of representatives of all concerned agencies along with representatives from civil society to brainstorm about what mechanisms need to be put into place to make the Ministry of Commerce’s regulatory notifications related to GM meaningful in their implementation. Such a meeting should have representatives of Genetic Engineering Appraisal Committee (GEAC) from the Ministry of Environment, Forest & Climate Change, Customs from Revenue Department of Ministry of Finance, Plant Protection & Quarantine Services division and EXIM Committee for exports and imports of seeds and planting materials of Ministry of Agriculture & Farmers’ Welfare, Review Committee on Genetic Manipulation (RCGM) of Department of Biotechnology (DBT), Department of Consumer Affairs and their Director of Legal Metrology, Food Safety and Standards Authority of India (FSSAI) official etc. Civil society representatives can include representatives of Alliance for Sustainable & Holistic Agriculture (ASHA), Coalition for a GM-Free India, Bhartiya Kisan Sangh, Navdanya, Gene Campaign, Swadeshi Jagaran Manch, Centre for Sustainable Agriculture, Bhartiya Kisan Union etc.
  1. Such a meeting should result in effective mechanisms (technical and institutional) being put in place for random testing from all  import consignments from USA, Brazil, Argentina, Australia, South Africa, Spain, Philippines, Canada etc., especially of soy product lines, corn/maize product lines, canola product lines, cotton product lines, sugarbeet product lines, papaya product lines and apple product lines. These mechanisms should also address the matter of mid-sea or transit country shipments, by placing a focus on the country of origin.
  1. DGFT and Customs should also issue a notification requiring all consignments to be certified as non-GM by competent or recognised agencies in the countries of export/country of origin.
  1. that no viable seeds/planting material should be allowed at any cost, of soybean, corn/maize, canola, cotton, sugarbeet, papaya and apple from any country of the world. Additionally, since field trials of various transgenic crops are taking place which are routinely found to be contaminating export consignments, it is important to make sure that seeds of all other crops are also randomly checked to ensure that no clandestine imports of GM contaminated material is being brought in. All seeds should also be de-vitalised where explicit permission for seed import is not given.
  1. Any import of processed GMO foods is in any case illegal, as explained by the Food Safety and Standards Authority of India (FSSAI) in an affidavit in the Supreme Court last year.
  1. that an inter-ministerial, inter-agency empowered body be set up to coordinate with each other, with a DGFT official being the Convenor of the body, to monitor all imports regularly, rigorously.

We hope and request that you consider all our demands seriously and adopt the same and any more mechanisms, to ensure that India’s biosafety and biosecurity are not breached by violation of existing regulations. Thank you.


Kavitha Kuruganti

Co-Convenor, Coalition for a GM-Free India

Phone: 8880067772


The full letter with an Annexure can be downloaded here:

Coalition for a GM-free India 

Website:, email :,  Facebook page – GM Watch India


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