The European Union is poised to enact a radical transformation of its agricultural policy through the proposed deregulation of New Genomic Techniques (NGTs), or so-called ‘novel GMOs’. This reform project, supported by the European Parliament since 2019, and adopted by the Commission in 2023, had until now faced resistance from some Member States. However, these States finally reached an agreement on 14 March 2025 to conclude negotiations.
This crucial turning point is no cause for celebration for those who, like the author, defend biodiversity, environmental integrity, public health, and the rights of farmers. Instead, it represents a blatant violation of the precautionary principle, in defiance of the Treaty, and a direct attack on the food sovereignty of peoples.
What follows is a constructive critique of this subversive reform, highlighting its false premises, dangerous environmental and socio-economic implications, and the deliberate obfuscation of consumers’ rights to know the identity of their food. The Council’s mandate, far from fostering innovation, will consolidate corporate power and undermine the very foundations of sustainable and equitable agriculture.
1. Deregulation of novel GMOs (NGTs): the Commission’s proposal
On 5 July 2023, the European Commission adopted a legislative proposal for the deregulation of novel GMOs. These have been deliberately disguised behind the acronyms NGTs (New Genomic Techniques), to deceive citizens and farmers and stifle their historic opposition to genetic engineering in our food.
The European Parliament’s Committee on Environment, Public Health and Food Safety (ENVI) holds primary responsibility for the dossier, with the Committee on Agriculture and Rural Development (AGRI) associated. Parliament has already adopted its position in favour of deregulation, as noted, on 24 April 2024.
2. The Council’s mandate for negotiations
The Council’s mandate for negotiations, agreed on 14 March 2025 under the Polish presidency, represents a significant step towards the deregulation of NGTs. The mandate confirms the Commission’s proposal, which is based on a two-category system for novel GMOs:
• category 1 NGT plants. These are plants with up to 20 genetic modifications, excluding (under the Council’s mandate) those with herbicide-tolerant traits. Such plants are considered equivalent to those obtained through conventional breeding methods, based on a scientifically unfounded theorem. They are thus exempt from the rules established for first-generation GMOs, which require pre-market authorisation based on a risk assessment by EFSA (European Food Safety Authority), as well as specific traceability and labelling requirements;
• category 2 NGTs. These ‘novel GMOs’ are plants that do not meet the criteria for Category 1 and remain, at least in part, subject to some of the EU’s GMO rules. However, there is a dangerous simplification of risk assessment and monitoring procedures, creating a gaping hole in the system designed to protect biodiversity, the environment, and public and animal health (Anses, 2023; Antoniou et al., 2023).
The Council has confirmed its intention to exclude the use of NGTs in organic farming, without, however, protecting organic farmers from the risks of severe damage they may face in cases of accidental contamination of their fields and/or products (resulting in the loss of organic certification).
2.1. Food sovereignty crushed
Member States have annihilated their own agricultural and food sovereignty by renouncing the right to ban the cultivation of Category 1 novel GMOs (NGTs) on their territories. Regardless of their potential environmental, health, socio-economic, and cultural impacts.
It is worth recalling that Francesco Lollobrigida, the Coldiretti Italian Minister of ‘Food Sovereignty’, was among the first to renounce traditional local cultivars in favour of the advancing novel GMOs.
National governments reserve the right to prohibit the cultivation of Category 2 novel GMOs (NGTs). They can thus better deceive citizens, making them believe they are protecting health and the environment by banning the cultivation of plants with more than 20 genetic modifications, after allowing the uncontrolled propagation of all others.
2.2. Coexistence
The mandate also allows Member States to adopt optional coexistence measures to prevent the unintended presence of Category 2 NGT plants in other products and to address cross-border contamination. While this may seem like a step forward, it places the burden of managing contamination risks on Member States, without addressing the responsibilities of biotech corporations for the spread of genetically modified organisms.
Moreover, the mandate allows Member States to adopt measures to avoid the unintended presence of Category 1 NGT plants in organic farming, but only in areas with specific geographical conditions (e.g., insular regions). The drastic restriction of such measures exposes organic farmers to uncontrolled risks of GMO contamination and the irreversible loss of their organic status.
In essence, Member State governments have overcome any hesitation in privileging the interests of agribusiness giants over the rights of citizens and farmers. The latter have already been convinced by the major agricultural confederations that novel GMOs will be a great success. Certainly for the agricultural consortia they control, which will sell the new seeds at high prices.
2.3. Darkness
Member State representatives, in the continuation of this farce, have insisted that only Category 2 novel GMOs (NGTs) be labelled as such. Or rather, with other deceptive nicknames or fancy names that Big Ag’s marketing offices will suggest to each government before the publication of the de-regulation.
The Council even boasts a commitment to ‘accurate and complete information’, for having proposed that — only in the event that operators decide to voluntarily include information on modified traits (e.g., gluten-free, drought-resistant) on the label — they must report all ‘relevant traits’. Or none at all, and long live transparency.
Citizens and consumers, in any case, will be deprived of the right to know whether foods contain or are derived from novel GMOs – NGTs of Category 1. Breakfast, lunch, and dinner in the dark with the biotech stranger, with only one alternative choice: certified organic foods (not even those from ‘sustainable’, ‘integrated’, or ‘regenerative’ agriculture, mind you).
4. Scientific concerns
One of the most controversial aspects of the proposed deregulation is the assertion of equivalence between Category 1 GMO (NGT) plants and those obtained through conventional breeding methods. This assertion is not only scientifically unfounded — as indeed refuted by the French National Agency for Food, Environmental and Occupational Health & Safety (ANSES, 2023) — but also overlooks several critical issues:
• unintended genetic changes and their implications. NGTs, particularly CRISPR/Cas9, can cause unintended genetic changes, including off-target effects that disrupt essential genes (Koller & Cieslak, 2023; Chu & Agapito-Tenfen, 2022) and on-target effects leading to unforeseen phenotypic changes (Kawall et al., 2020). These alterations, ça va sans dire, can also be harmful (Eckerstorfer et al., 2019). Unlike conventional breeding, NGTs can cause unpredictable genomic rearrangements (Koller & Cieslak, 2023; Kawall et al., 2020). Therefore, specific risk assessments are necessary before their release into the environment, as currently required by the European Court of Justice (ECJ, 2018), which affirmed the equivalence of novel GMOs (NGTs) not to conventional plants, but to first-generation GMOs. Precisely because they are genetically modified organisms, regardless of the tools used for biotech engineering;
• potential public health risks. The introduction of genetically modified microorganisms into the intestinal microbiome could disrupt its balance through horizontal gene transfer (HGT), where genetic material is exchanged between gut bacteria. This could alter the composition and function of the microbiome, leading to potential health risks. Moreover, these changes could influence the long-term evolutionary trajectory of gut microorganisms, raising concerns about unforeseen health consequences (Lerner, Benzvi, & Vojdani, 2024);
• environmental interactions and cumulative risks. The release of NGT organisms can trigger complex ecological interactions with cumulative and combinatorial effects not visible in isolated assessments (Bauer-Panskus & Then, 2023). For example, the release of multiple NGT organisms with different traits could lead to unintended gene transfers or disrupt ecosystem services (Bauer-Panskus & Then, 2023; Dolezel et al., 2024). Furthermore, the use of herbicide-resistant NGT crops could lead to the emergence of superweeds resistant to multiple herbicides, which could outcompete cultivated crops (Gaharwar et al., 2021; Eckerstorfer et al., 2019);
• off-target effects and spurious DNA insertions. One of the most significant unintended consequences of NGTs is the occurrence of off-target effects, where the CRISPR/Cas9 system edits genes other than the intended targets. Off-target effects can disrupt critical genes, causing harmful changes (Hoepers et al., 2024; Lema, 2021), with 42% of species, including humans, potentially affected (Hoepers et al., 2024). NGTs can also lead to spurious DNA insertions, introducing harmful traits (Lema, 2021), and current methods struggle to detect large variations or complex rearrangements (Chu & Agapito-Tenfen, 2022; Lema, 2021);
• sustainability and long-term impacts. The long-term sustainability of NGTs in agriculture and environmental management remains debated. While they offer solutions to climate change and food security, unintended consequences could offset their benefits (González-Ortega et al., 2024). It is worth recalling the recent study that demonstrated — after 12 years of analysis in 10 US states — that the most promising first-generation GMO, Bt corn, drastically reduced yields and farmers’ incomes (Ye et al., 2025).
5. Environmental and agricultural implications
The deregulation of NGTs poses significant risks to the environment and traditional agriculture:
• threat to biodiversity. The widespread cultivation of NGT plants could accelerate the loss of agrobiodiversity, cultural heritage, and crop genetic diversity. With increased vulnerability to pests, diseases, and climate change. In the long term, this phenomenon could undermine the resilience of agricultural systems and threaten ‘food security’ (i.e., the security of food supplies);
• herbicide resistance. Although the Council’s mandate excludes herbicide-resistant plants from Category 1, the potential development of herbicide-resistant weeds remains a concern. The increased use of herbicides associated with NGT plants (already widely observed with first-generation GMOs, including non-‘herbicide-resistant’ ones) could lead to environmental contamination and harm non-target organisms;
• cross-contamination and patents. The deregulation of NGTs could lead to the cross-contamination of non-GMO crops, resulting in legal and economic challenges for farmers. Patents on NGT plants based on conservation species could force farmers to pay royalties to patent holders, even when contamination is not their fault.
6. Socio-economic implications
The proposed deregulation of novel GMOs (NGTs) has significant socio-economic implications, especially for family and peasant farms, which still represent 94.8% of farms in the EU (Source: Eurostat, 2020):
• concentration of power. The radical transformation of our agricultural systems will have only four winners: Bayer, Corteva, ChemChina, and BASF. The Big 4 which already control over 70% of the global pesticide and seed market will hoard the most promising patents, just as the IT giants did in the 70s and 90s of the last century with source codes, to consolidate their absolute monopoly on the critical IT infrastructure of much of the planet (Stallman, 2002);
• absolute dependence. Farmers have already been deprived of the right to exchange and sell their seeds, by their own unfaithful representatives in the European Parliament and national governments who have approved and/or are pushing for the deregulation of novel GMOs. And when they find themselves convinced (by their bad advisors, in perpetual conflict of interest) or forced to introduce NGTs, they will begin to depend 100% on the four monopolists who will decide when, where, and what to grow. As well as programming/manipulating yields and perhaps even ensuring that farmers are forced to buy more pesticides, from the same Big 4. A de facto slavery, at their own risk and peril, with higher costs and increasing vulnerability to market fluctuations (Dongo, 2015; Munawar et al., 2024).
7. Democratic implications
A deeper look reveals that the deregulation of ‘novel’ GMOs does not align with the interests of:
• small and medium-sized farms (94.8% of the total), as increases in production costs do not correspond to proportional variations in selling prices;
• citizens, the majority of whom (56%, according to the latest Eurobarometer survey) express concern about the safety of GMOs in food (EFSA, 2023);
• food processing businesses and industries (99% SMEs), and retailers, which derive no benefit from their suppliers’ use of biotech agricultural raw materials.
European and Member State politicians, on the other hand, since 2019 have dedicated and continue to dedicate absolute priority to the liberalisation of novel GMOs. In whose interest, and why? The only interested parties, when scrutinized, are those financial oligarchies which simultaneously dominate the global markets of:
• agricultural inputs. Pesticides and seeds, via the Big 4, and fertilisers via another six giants;
• industrial agriculture and commodities, through ABCD (Archer Daniels-Midland, Bunge, Cargill, Dreyfus);
• ultra-processed foods, often junk food, through the 10 big sisters of Big Food.
The quartet BlackRock, Vanguard, State Street Global Advisors, Geode, in the first quarter of 2024, managed approximately $25.14 trillion (Aguileira et al., 2024). That is, a figure slightly higher than the GDP produced in 2023 by: 27 EU Member States, the UK, Russia, Norway, Ukraine, Serbia, Moldova, Bosnia and Herzegovina, North Macedonia, and Albania (World Bank, 2024). Coincidentally, the quartet is also heavily involved in the military industry, and in recent weeks Ursula von der Leyen has been considering how to extract €800 billion from citizens’ private savings to buy weapons.
8. The role of civil society and peasant movements
Civil society organisations — including peasant movements, NGOs like our Égalité, and environmental groups — are at the forefront of the peaceful fight against the deregulation of NGTs. They highlight the risks to biodiversity, public health, and farmers’ rights. They demand, and indeed we demand, a precautionary approach with rigorous risk assessments, traceability, and labelling.
The European Coordination Via Campesina (ECVC), a leading peasant movement, has been particularly vocal in opposing the deregulation of NGTs. ECVC, with a lucid and consistent position:
• argues that the proposed changes undermine the very foundations of agroecology and food sovereignty, and
• calls for a moratorium on the commercial use of NGTs until their safety and socio-economic impacts are fully understood.
9. Wait, please
The urgency and pressure to establish regulations based on the misleading premise of an assumed equivalence between conventional plants and novel GMOs (even with up to 20 genetic modifications) reflect a deeply flawed governance approach that risks further undermining Europe’s foundations. It is crucial to recognise the implications of this trajectory and take a firm stance against such reckless policies, which compromise fundamental human rights, including those to life and health, environmental protection and biodiversity, as well as food security and sovereignty.
It is worth highlighting that food sovereignty also encompasses decision-making autonomy over the means of production, as outlined in the United Nations Declaration on the Rights of Peasants and Other People Working in Rural Areas (UNDROP, 2018).
A precautionary approach — based on rigorous risk assessments, traceability, and mandatory ‘from seed to fork’ labelling of all NGT plants — is the only solution consistent with the Treaty. And agroecology is the true path to follow, according to FAO (2019) recommendations, for the good of all.
#Égalité, #PeaceLandDignity!
Dario Dongo
References
- European Commission. (2023). Proposal for a Regulation of the European Parliament and of the Council on plants obtained by certain new genomic techniques and their food and feed, and amending Regulation (EU) 2017/625. COM(2023) 412 final. https://tinyurl.com/5b3h528e
- Council of the European Union. (2025). Mandate for negotiations with the European Parliament on the proposal for a Regulation on plants obtained by certain new genomic techniques and their food and feed. 6426/25. https://tinyurl.com/4uxj9fy3
- Bundesanstalt für Landwirtschaft und Ernährung (BLE). (2024). Machbarkeitsstudie zu “Nachweis-und Identifizierungsverfahren für ge-nomeditierte Pflanzen und pflanzliche Produkte” abgeschlossen: Berichte wurden veröffentlicht. https://tinyurl.com/2bzmcx84
- Anses (2023). AVIS de l’Anses relatif à l’analyse scientifique de l’annexe I de la proposition de règlement de la Commission européenne du 5 juillet 2023 relatable aux nouvelles génomiques (NTG) – Examen des critères d’équivalence proposed to define the NTG plants of category 1. https://tinyurl.com/2npybjhs
- Antoniou, M.N., Robinson, C., Castro, I. et al. (2023). Agricultural GMOs and their associated pesticides: misinformation, science, and evidence. Environ Sci Eur 35, 76. https://doi.org/10.1186/s12302-023-00787-4
- Dario Dongo. (2015). GMO, the Big Scam. Great Italian Food Trade, Rome. ISBN: 9788894200423. https://tinyurl.com/bdhent4p
- Koller, F., & Cieslak, M. (2023). A perspective from the EU: unintended genetic changes in plants caused by NGT—their relevance for a comprehensive molecular characterisation and risk assessment. Frontiers in Bioengineering and Biotechnology. https://doi.org/10.3389/fbioe.2023.1276226
- Chu, P. N., & Agapito-Tenfen, S. Z. (2022). Unintended Genomic Outcomes in Current and Next Generation GM Techniques: A Systematic Review. Plants, 11(21), 2997. https://doi.org/10.3390/plants11212997
- Kawall, K., Cotter, J., & Then, C. (2020). Broadening the GMO risk assessment in the EU for genome editing technologies in agriculture. Environmental Sciences Europe, 32(1), 1–24. https://doi.org/10.1186/S12302-020-00361-2
- European Court of Justice. (2018). Judgment of the Court (Grand Chamber) of 25 July 2018, Confédération paysanne and Others v Premier ministre and Ministre de l’Agriculture, de l’Agroalimentaire et de la Forêt, Case C-528/16. ECLI:EU:C:2018:583. https://eur-lex.europa.eu
- Lerner, A., Benzvi, C., & Vojdani, A. (2024). The potential harmful effects of genetically engineered microorganisms (GEMs) on the intestinal microbiome and public health. Microorganisms, 12(2), 238. https://doi.org/10.3390/microorganisms12020238
- Bauer-Panskus, A., & Then, C. (2023). The need for assessment of risks arising from interactions between NGT organisms from an EU perspective. Environmental Sciences Europe, 35(1), 1–15. https://doi.org/10.1186/s12302-023-00734-3
- Dolezel, M., Lang, A., Greiter, A., Miklau, M., Eckerstorfer, M., Heissenberger, A., Willée, E., & Züghart, W. (2024). Challenges for the Post-Market Environmental Monitoring in the European Union Imposed by Novel Applications of Genetically Modified and Genome-Edited Organisms. Biotech. https://doi.org/10.3390/biotech13020014
- Gaharwar, U. S., Verma, A., Singh, R., Prasad, T., & Rajamani, P. (2021). Health Risks and Environmental Concerns of GM Crop Adoption (pp. 371–400). Academic Press. https://doi.org/10.1016/B978-0-12-820780-2.00017-0
- Hoepers, A. M., Heinemann, J. A., Zanatta, C. B., Chu, P., Hiscox, T. C., & Agapito-Tenfen, S. Z. (2024). Predicted multispecies unintended effects from outdoor genome editing. Ecotoxicology and Environmental Safety, 282, 116707. https://doi.org/10.1016/j.ecoenv.2024.116707
- Lema, M. A. (2021). Regulatory Assessment of Off-Target Changes and Spurious DNA Insertions in Gene-Edited Organisms for Agri-Food Use. 9(1), 1–15. https://journals.tdl.org/regsci/index.php/regsci/article/download/136/210
- González-Ortega, E., Piñeyro‐Nelson, A., & Martínez Debat, C. (2024). On techno-fixes in the era of crises: genomic interventions in food crops. Agroecology and Sustainable Food Systems, 1–24. https://doi.org/10.1080/21683565.2024.2429620
- Ye, Z., DiFonzo, C., Hennessy, D.A., Zhao, J., Wu, F., Conley, S.P., Gassmann, A.J., Hodgson, E.W., Jensen, B., Knodel, J.J., McManus, B., Meinke, L.J., Michel, A., Potter, B., Seiter, N.J., Smith, J.L., Spencer, J.L., Tilmon, K.J., Wright, R.J., and Krupke, C.H. (2025). Too much of a good thing: Lessons from compromised rootworm Bt maize in the US Corn Belt. Science, 387(6737), 984. DOI: 10.1126/science.adm7634
- Munawar, N., Ahsan, K., & Ahmad, A. (2024). CRISPR-edited plants’ social, ethical, policy, and governance issues (pp. 367–396). Elsevier BV. https://doi.org/10.1016/b978-0-443-18444-4.00011-9
- Eckerstorfer, M., Dolezel, M., Heissenberger, A., Miklau, M., Reichenbecher, W., Steinbrecher, R. A., & Waßmann, F. (2019). An EU Perspective on Biosafety Considerations for Plants Developed by Genome Editing and Other New Genetic Modification Techniques (nGMs). Frontiers in Bioengineering and Biotechnology, 7, 31. https://doi.org/10.3389/FBIOE.2019.00031
- Stallman, R. M. (2002). Free software, free society: Selected essays of Richard M. Stallman. Free Software Foundation. ISBN: 978-1-882114-98-6
EFSA (2023). Special Eurobarometer Wave EB97.2 – Food safety in the EU. ISBN:978-92-9499-467-7. https://tinyurl.com/unyvupwr - Aguilera, R.V., Desender, K.A., LópezPuertas-Lamy, M. (2024). Are the Big Three asset managers beneficial stewards or corporate overlords? Columbia Law School Blue Sky Blog. https://tinyurl.com/2s3nxh52
- World Bank. (2023). World Development Indicators [Data file]. World Bank. https://data.worldbank.org/indicator/NY.GDP.MKTP.CD
- United Nations General Assembly. (2018). United Nations Declaration on the Rights of Peasants and Other People Working in Rural Areas (A/RES/73/165). United Nations. https://undocs.org/en/A/RES/73/165
- Food and Agriculture Organization of the United Nations (FAO). (2019). The 10 elements of agroecology. Guiding the transition towards sustainable food and agricultural systems. [FAO Publications Repository]. https://tinyurl.com/mr35xphb
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
, or ‘novel GMOs’.){kind=link}