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Key themes to cover in your response to the gene editing consultation

This is one of a series of linked pages on the UK Government’s gene editing consultation. Please see the main consultation page for more information and guidance on taking part.

Challenging the core proposition in the consultation

We have published detailed suggestions for answering each of the questions in the consultation but there are also problems with the way the whole thing is being presented. With most of the questions, the government expects respondents to accept its proposition that gene edited organisms could occur naturally or through traditional breeding.

You do not have to accept this proposition and if you disagree with it, you should say so in your response.


Other key themes to consider throughout your response are:

Product- vs process-based assessment

Current GM regulations ensure that when genetic engineering is used, there are at least some checks on whether the genetic engineering has introduced any errors before that crop or animal can be farmed and/or eaten. This is often referred to as ‘process-based regulation’. Process-based regulation acknowledges that how an organism is produced is relevant. This approach recognises that direct intervention at the genetic level is different from traditional breeding and can result in multiple and unexpected errors across the genome, some of which may pose a threat to people or the environment.

Shifting to ‘product-based regulation’ means that regulators will no longer have to consider how a plant or animal was created. This amounts to taking the genetic engineer’s word for it that they have only made the DNA changes that they have planned and declared. Any unexpected effects, such as new allergens or toxins, may go unnoticed. This is not safe or sensible.

Technofixes vs system change

Our food system needs to change, but the changes we need include the widespread adoption of agroecological farming systems, a massive reduction in food waste, and food sovereignty, which gives people around the world control over their own food supply.

Gene editing makes big promises: to improve yields, fight climate change, stop biodiversity loss and secure the competitiveness of the UK economy. Behind these promises is the suggestion that complex societal, political and economic problems are rooted in plant and animal breeding and can be ‘fixed’ by ‘tweaking’ the genes of living organisms. The problems of agriculture are more complex and systemic than that and continuing to pin our hopes on short-term technofixes is one of the things preventing real systemic change.

Transparency and the removal of essential protections

People everywhere want to know what they are eating. They want to know that it is safe and has been produced in ways that do not harm people, animals or the environment. Regulation is an essential safeguard ensuring that everyone plays by the rules. This consultation is part of an ongoing government campaign to obscure where our food comes from and how it was produced while giving risky new technologies free rein within the food system.

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