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Action Alert: Forest Stewardship Council consultation on GMOs

Posted 11th September 2025 in News

The biggest global certifier of forest sustainability – the FSC – is consulting on whether newer forms of Genetically Modified Organisms (GMOs) should continue to be considered GMOs.

Environmental organisations including the Canadian Biotechnology Action Network (CBAN) and GM Freeze are urging groups to respond to the consultation to help stop the introduction of GMO trees. This would threaten forests, ecosystems, local communities and indigenous people.

The consultation closes on the 28th September – please respond on the FSC website. Below are some suggestions of issues you may want to raise. CBAN has also produced background documents in French, Spanish and English.

Trees

The Forest Stewardship Council (FSC) currently considers all GMOs to be GMOs, but, according to the consultation page, it has “received several informal enquiries concerning the definition of GMO in FSC Principles and Criteria… suggesting a lack of clarity regarding modern genetic engineering technologies, such as CRISPR-based gene editing”.

We need to send a clear message to the FSC to stand firm in their position that all GMOs are GMOs!

Filling in the consultation can be as quick as filling in your details and answering yes to one question. However, there is space to provide further commentary.

The consultation

You don’t have to represent an organisation to respond, you can be a member of a local community or an interested stakeholder such as a consumer.

FSC certified products can be any that contain or are made from wood or paper, from wardrobes to toilet roll to drinks packaging. Consumers of FSC-certified products are stakeholders because they may not want to buy products that contain GMOs.

After you have filled in details about yourself, there are only two or three questions to answer.

Q1. Do you agree with the drafted interpretation?

  • If you do not want the FSC to allow new GMOs in its certified operations, answer YES to this question.

[The “drafted interpretation” states that the definition of GMOs covers organisms in which the genetic material has been altered using modern, CRISPR-based gene editing technologies. It confirms that the definition refers to the process used rather than the resulting change.]

Q2 is only relevant if you answer no to Q1.

Q3.  Please provide any additional comments or suggestions, if you have them.

Issues and points you may want to raise in a consultation response:

  • Recategorising new GMOs as not GMOs may result in the uncontrolled and unmonitored release of such organisms.
  • This creates unnecessary and unpredictable risks to the environment, public health, local communities and indigenous people.[i]
  • In a forest context, this is particularly dangerous as the consequences could be ecosystem-wide and could impact large numbers of species and a range of livelihoods.
  • The lifespan of trees means that it is impossible to fully assess the long term risks, as it isn’t possible to monitor the impact of genetic changes on subsequent generations.
  • The number of species that trees interact with and their ability to spread pollen and seeds over long distances creates additional risks.
  • Recategorising some GMOs would go against the precautionary principle, which is enshrined in law in many countries, including in the European Union. According to this principle, if there is not an agreement about what the risks are, or if they are unknown, then an activity should not be carried out.
  • The majority of countries still consider new GMOs to be GMOs and it is not appropriate for the FSC to introduce lower standards than the countries in which it operates.
  • This could introduce trade problems across supply chains.
  • Even in jurisdictions where new GMOs have been deregulated, they are still considered to be GMOs – the EU for example.[ii]
  • There is no sound scientific basis for recategorising new GMOs that some claim to be less risky. For example, the UK’s definition creates an untestable hypothesis.
  • The French National Agency for Food, Environmental and Occupational Health Safety (ANSES) has found that the potential risks associated with newer forms of GMOs include unexpected changes in the composition of plants, which could lead to nutritional, allergenicity or toxicity problems.[iii]
  • The German Federal Agency for Nature Conservation (BfN) has found that “even small changes by genetic engineering can have a high-risk potential for the environment and health”.[iv]
  • The Environment Agency Austria (UBA) has highlighted unintended changes and risks associated with newer forms of GMOs.[v]
  • For the FSC to unilaterally change its definition of GMOs would undermine international agreements such as the Aarhus Convention and Cartagena Protocol on Biosafety to the Convention of Biological Diversity.
  • Gene editing in human and animal cells has been found to have significant unintended genetic consequences,[vi] including “off-target effects” and “unintended on-target effects” at the intended edit site.
  • The case of the genetically engineered American chestnut tree provides a warning of what can go wrong and what is at risk when GM trees are released.[vii]
  • As a consumer, if you see the FSC logo on a product, you may expect assurance that it does not contain GMOs.
  • If the FSC begins to allow GMOs it will compromise the FSC’s reputation and certification standards.
  • The FSC must not give in to pressure from the biotech industry!

References

[i] ‘The Global Status of Genetically Engineered Tree Development: A Growing Threat’, the Canadian Biotechnology Action Network for The Campaign to STOP GE Trees, September 2022. Available from: https://stopgetrees.org/wp-content/uploads/2022/09/The-Global-Status-of-Genetically-Engineered-Tree-Development-EN.pdf

[ii] See the Greenpeace European Unit media briefing ‘New GMOs: sorting spin from facts,’ 07/04/2025, available from: https://www.greenpeace.org/eu-unit/issues/nature-food/47491/new-gmos-sorting-spin-from-facts-media-briefing

[iii] ‘Risques et enjeux socio-économiques liés aux plantes NTG’, ANSES, January 2024. Available from: https://www.actu-environnement.com/media/pdf/news-43622-avis-anses-nouveaux-ogm.pdf Cited in: ‘Risks of new GMOs: French food safety agency ANSES recommends case-by-case assessment’, GM Watch, 7th March 2024. Available from: https://www.gmwatch.org/en/106-news/latest-news/20391-risks-of-new-gmos-french-food-safety-agency-anses-recommends-case-by-case-assessment

[iv] ‘For a science-based regulation of plants from new genetic techniques: Deregulation of NGT plants contradicts the precautionary principle,’ BfN Policy Brief #2/2024, available from:  https://www.bfn.de/sites/default/files/2024-02/24_02_07_BfN_policy_brief_NGT-7_0.pdf

[v] ‘New Genetic Engineering – possible unintended effects,’ available from: https://emedien.arbeiterkammer.at/viewer/image/AC16982244/6/LOG_0007/

[vi] ‘Potential DNA Damage from CRISPR “Seriously Underestimated,” Study Finds’, July 16th 2018. Available from: https://www.scientificamerican.com/article/potential-dna-damage-from-crispr-seriously-underestimated-study-finds/

[vii] See Earth Island Journal and GMO Promises website.