To:                                                                                                                     

1. Director General of Foreign Trade, MoC&I

2. Joint Director, Plant Quarantine, Plant Protection & Quarantine Services, MoA&FW

3. Joint Secretary, Plant Protection, DAC&FW

4. Director, National Bureau of Plant Genetic Resources, MoA&FW

5. Chairperson, Genetic Engineering Appraisal Committee, MoEF&CC

6. Directorate, Plant Protection & Quarantine Services, MoA&FW

7. CEO, FSSAI

8. Secretary, MoH&FW

22nd October 2018

Dear Madam/Sir,

Subject: Our concerns with regard to continued import of GM seeds – reg.

Namaste. We write to you with regard to the import of seeds/food of crops in which GM versions exist, that too from countries which are predominantly GM-variant-producing without any systems of segregation and labelling. You might remember our previous communication on this months ago http://indiagminfo.org/citizens-group-complains-to-centre-on-illegal-import-of-multiple-gm-seeds-and-lack-of-action-on-confirmed-gm-soybean-case-from-months-ago/  and http://indiagminfo.org/regulators-pass-buck-to-each-other-other-ministries-while-hundreds-of-tonnes-of-illegal-gm-seed-import-takes-place-into-india-english-and-hindi-press-release/.

In the recent 235th meeting of EXIM committee for export and import of seeds and planting material, we find that the Committee has again taken decisions that increase the risk of GM seed imports into India. To highlight a few examples –

1) 30,000 kg maize seeds proposal for import from US imported by M/S Gourmet Popcornica, LLP (Mylapore, Chennai) has been accepted (See Page 4). More than 90% maize in US is known to be genetically modified.

2) 1200 kg Papaya seed import proposal from Taiwan by M/s Known-You Seed, Bhima Koregaon, Pune (See Page 7) and 100 kgs by M/s Aranyak Agriventures, Sanawad, Khargone, Madhya Pradesh (Page 8) have been approved. GM Papaya is well known to have been grown in Taiwan and been exported to other locations too.

3) Proposal for import of 14000 apple tissue culture plants from US by M/s Seven Star Fruits Pvt Ltd Mumbai import approved. (Page 3). As you would be aware, GM apple is now cultivated in the United States of America.

These are only but a few examples from the last meeting alone, whereas various such examples can be found in previous meeting minutes too. Below is a comprehensive list from our investigation on seeds/crops imported from countries growing (some of which have been openly described as being for cultivation from source below) GM varieties of these over last decade –

Meanwhile, in the 134th meeting of GEAC, “the representative from Plant Quarantine informed that import of grains in bulk for processing is allowed subject to certain conditions, which include that grains are devitalized either by splitting or by heating to 120 degrees C.” This method is clearly not being implemented properly nor is it stopping import of illegal GM seeds as evidenced from the fact that GM soybean has been found to be cultivated illegally in Gujarat with no action being taken by GEAC yet. https://www.downtoearth.org.in/news/agriculture/illegal-gm-soybean-farmers-body-demands-cbi-probe-into-geac-inaction-59850. The illegal GM soybean cultivation that has been discovered in Gujarat last year can only be explained by unlawful imports, given that GM soy field trials have not been allowed in the country for seeds to have been leaked out from such trials.

This apparent care being taken by PPQS authorities for grains meant for processing also does not address the fact that seeds and food products imported from countries growing GM varieties of those crops are likely to be GM. There have been many recorded cases in other countries where GM seeds and contaminated seeds have been imported whereas the original seed import approval or permission was given for non-GM seed alone. Further, from the DGFT side, merely asking for a declaration will not stop such illegal imports, if someone is keen on importing such seed. This can only be addressed if India stops importing seeds and food products from countries which grow GM varieties of these crops/seeds.

While applicants (that too only in some cases) are being asked to provide affidavits on GM-free status of the import consignment, this is not adequate to stop unlawful imports. It is obvious that unlawful entry is happening with no declarations being provided, and this is what the authorities need to prevent and take action on. To ensure what we import is GM-free, scientific and stringent testing is needed, of all consignments of crops/seeds/food for which GM variants exist in the world, including those being imported from countries which do not grow GM crops as they might (knowingly/unknowingly) import GM varieties of these crops/food/seeds. Given that only a handful of crops are grown in their genetically-modified versions anywhere in the world – soybean, maize, cotton, canola, papaya, sugarbeet, apple, potato and tobacco – it is not that difficult to stay alert on imports of these commodity consignments, and for the DGFT, NBPGR, GEAC and PPQS to collectively confirm that all import consignments of these commodities are non-GM by rigorous scientific testing.

In 2016, in the guise of ease of doing business FSSAI removed requirement for specialised food safety experts to inspect imported food consignment at India’s ports and handed the responsibility to untrained custom officials. This move would have no doubt led to fastening the import of illegal GM foods, which in the recent CSE study was found to be the case for 46% of imported food products!

For the obvious reason that not everyone is applying to the authorities, declaring a GM-free status of the import consignment and bringing in the commodity, we need additional measures. Our demands are as below –

• Stop any import of food/seed from countries which are growing GM variety of the seed/food product

• Build a strong scientific testing system and ensure trained food/seed safety experts are responsible for food safety to ensure that countries which do not grow GM crops but might import them do not export these to India.

Attaching a Word copy of the mail here too.

Sincerely,

 Rajesh KrishnanLetter to authorities on illegal GM Imports

For Coalition for GM-Free India