Investment, regulation, and uncertainty: managing new plant breeding techniques

Risk-appropriate regulations for gene-editing technologies

This paper explores the scope for the newly emerging technologies, based on gene editing (GE) contributing to addressing the global challenges that we face. These challenges relate to food security, climate change and biodiversity depletion. In particular, it examines the science and evidence behind the most appropriate forms of agricultural production to meet these challenges, the targets set in the Global Biodiversity Framework (GBF) agreed to at the end of 2022 and the possible role of GE technologies in contributing to meeting these targets. It then examines the most risk-appropriate regulatory environment required to best facilitate the adoption of GE technology, drawing on the experiences of the impact of regulatory systems for other innovations used in agricultural and food production systems such as genetically modified organisms (GMOs).

An assessment of the linkages between GM crop biotechnology and climate change mitigation

This article provides an analysis and evaluation of peer-reviewed evidence on the contribution of crop biotechnology to climate change mitigation and adaption. While there is a range of agricultural technologies and products that contribute to climate change mitigation, this literature landscape analysis focuses on the development of genetically modified traits, their use and adoption in major commodity crops and responsive changes in production techniques. Jointly, these technologies and products are contributing to climate change mitigation, yet the technology, the literature and evidence is still evolving as more sophisticated research methods are used with greater consistency. The literature analysis is undertaken with consideration of the consequential impact that regulatory regimes have on technology development. This assessment utilizes the Maryland Scientific Methods Scale and citation analysis, concluding that GM crops provide benefits that contribute to climate change mitigation.

The economics and policy of genome editing in crop improvement

In this review article we analyze the economics of genome editing and its potential long-term effect on crop improvement and agriculture. We describe the emergence of genome editing as a novel platform for crop improvement, distinct from the existing platforms of plant breeding and genetic engineering. We review key technical characteristics of genome editing and describe how it enables faster trait development, lower research and development costs, and the development of novel traits not possible through previous crop improvement methods. Given these fundamental technical and economic advantages, we describe how genome editing can greatly increase the productivity and broaden the scope of crop improvement with potential outsized economic effects. We further discuss how the global regulatory policy environment, which is still emerging, can shape the ultimate path of genome editing innovation, its effect on crop improvement, and its overall socioeconomic benefits to society.

New genomic techniques and their European Union reform. Potential policy changes and their implications

The article discusses amendment options (no significant change, lowering of administrative burdens or exemption of certain products from the legislation) for the European Union (EU) authorization procedures of New Genomic Techniques’ (NGT) products and their consequences for the sector and research institutions, particularly in the context of internal functioning, placing products on the market and international trade. A reform of the EU regulatory system requires a change in the procedures for the authorization of NGT products, otherwise EU researchers and investors may still be at a competitive disadvantage (as compared to Argentina, Brazil, Canada, United States or the United Kingdom) due to the inefficiency of the current system and the committee procedure for authorization. New legislation, currently being adopted in the United Kingdom is also presented for comparison.

The future of CRISPR gene editing according to plant scientists

This study surveyed 669 plant scientists globally to elicit how (which outcomes of gene editing), where (which continent) and what (which crops) are most likely to benefit from CRISPR research and if there is a consensus about specific barriers to commercial adoption in agriculture. Further, we disaggregated public and private plant scientists to see if there was heterogeneity in their views of the future of CRISPR research. Our findings suggest that maize and soybeans are anticipated to benefit the most from CRISPR technology with fungus and virus resistance the most common vehicle for its implementation. Across the board, plant scientists viewed consumer perception/knowledge gap to be the most impeding barrier of CRISPR adoption. Although CRISPR has been hailed as a technology that can help alleviate food insecurity and improve agricultural sustainability, our study has shown that plant scientists believe there are some large concerns about the consumer perceptions of CRISPR.

Opportunities for Orphan Crops: Expected Economic Benefits From Biotechnology

An enabling, evidence-based decision-making framework is critical to support agricultural biotechnology innovation, and to ensure farmers' access to genetically modified (GM) crops, including orphan crop varieties. A key element, and often a challenge in the decision-making process, involves the balancing of identified potential risks with expected economic benefits from GM crops. The latter is particularly challenging in the case of orphan crops, for which solid economic data is scarce. To address this challenge, the International Food Policy Research Institute (IFPRI) in collaboration with local economists analyzed the expected economic benefits to farmers and consumers from the adoption of GM crops in 5 sub-Saharan African countries. This paper focuses on case studies involving insect-resistant cowpea in Nigeria and Ghana; disease-resistant cassava in Uganda and Tanzania; and disease-resistant banana in Uganda. Estimations from these case studies show substantial economic benefits to farmers and consumers from the timely adoption and planting in farmers' fields of GM orphan crops. Our analysis also shows how the benefits would significantly be reduced by regulatory or other delays that affect the timely release of these crops. These findings underscore the importance of having an enabling policy environment and regulatory system-covering, among other elements, biosafety and food/feed safety assessment, and varietal release registration-that is efficient, predictable, and transparent to ensure that the projected economic benefits are delivered and realized in a timely manner.

Regulatory Barriers to Innovative Plant Breeding in Canada

The regulation of plant breeding is gaining increasing scrutiny, particularly as it pertains to the regulation of gene editing and other new breeding technologies. Genome editing is used worldwide in both public and private plant breeding laboratories and there is considerable uncertainty about the ability of regulatory agencies to match the rapid scientific pace being set. This research focuses on Canada, where advances in plant breeding technology are constrained by the boundaries of the regulatory system established in the early 1990's. This research presents the results of a survey of 93 public and private plant breeders and their views on the existing Canadian regulatory framework regarding conventional breeding and genome editing techniques for plants with novel traits (PNTs). The results contribute to the ongoing debate regarding how, or whether, to regulate products of genome-edited plant breeding, beyond the existing agronomic and safety requirements. Plant breeders identify the level of Canadian crop research competitiveness and quantify the impacts of novelty within Canada's regulatory system for PNTs. One significant finding is that PNT regulations in Canada have created an innovation barrier in terms of applying genome editing technologies to the development of new varieties, particularly in public sector research.

Regulatory approaches for genome edited agricultural plants in select countries and jurisdictions around the world

Genome editing in agriculture and food is leading to new, improved crops and other products. Depending on the regulatory approach taken in each country or region, commercialization of these crops and products may or may not require approval from the respective regulatory authorities. This paper describes the regulatory landscape governing genome edited agriculture and food products in a selection of countries and regions.

CRISPR-Cas9 Application in Canadian Public and Private Plant Breeding

Plant-breeding technologies have expanded, accelerating breeding research beyond the confines of current regulations. The application of genome editing, such as CRISPR-Cas9, do not neatly fit into existing regulatory frameworks, creating uncertainty as to whether they can be regarded as conventionally developed varieties without further regulation. This research presents the current views of Canadian plant breeders based on a national survey of plant breeders. There is evidence that a review of existing regulations is required, as >60% anticipate the use of genome-editing technologies in the next few years. This paper reviews plant-breeding practices under the context of present plants with novel trait (PNT) regulations and where plant breeders place the use of CRISPR-Cas9 within the suite of available genome-editing options. This paper establishes when and why, or why not, breeders choose to introduce CRISPR-Cas9 into their research over other plant-breeding applications.

Legal and practical challenges to authorization of gene edited plants in the EU

According to a predominant interpretation of the C-528/16 judgment of the Court of Justice of the European Union, mutants resulting from gene editing, even those featuring only single nucleotide variants, should be subject to the authorization procedures designed for organisms developed through genetic modification (i.e. insertion of large DNA fragments). In this article, we illustrate practical problems with the authorization of products of gene editing in the EU. On the basis of these problems, we analyze the influence of the current interpretation of EU legislation and judgment on the practical ability to authorize and detect such products on the EU market. We show that the predominant interpretation of the judgment leads to legally unacceptable consequences, in particular to the violation of the principle of proportionality with regard to individuals who wish to develop and market products of gene editing. As a result of our considerations, we show that the C-528/16 judgment did not need to be interpreted in the dominant way.

Regulatory barriers to improving global food security

Crop agriculture and food production constantly face climactic challenges to the supply of safe, nutritious food. These challenges highlight the importance of innovation resulting in improved crop technologies, capable of providing consistently increasing yields in the face of abiotic and biotic stresses. This article addresses the challenge that regulatory barriers are, and can, have on the adoption of innovative crop and food technologies that improve food security. Evidence of increased crop yield and the potential for increased yields, are presented from innovative plant breeding technologies, especially gene editing. Recent advances from the use of gene editing in the pharmaceutical field may offer opportunities to reduce regulatory burdens.

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The EU regulatory framework for GM crops is in gridlock with no signs of ending.

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The CJEU 2018 gene editing ruling has resulted in a decline in EU R&D investment.

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Gene editing regulation in the EU will have spillover effects in Africa and Asia.

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Covid-19 vaccines may require regulation as equivalent to GMOs, delaying approval.

Current risk assessment approaches for environmental and food and feed safety assessment

Foundational activities at the international level underlie current risk and safety assessment approaches for genetically engineered/modified organisms (GEOs/GMOs). Early risk assessment considerations beginning with the OECD 'Blue Book' established risk/safety assessment as the characterization of the organism and its environmental release; establishment and persistence in the environment; and human and ecological effects, analyzed in principle through existing methods. Important in this context was recognition that GEOs/GMOs as a class did not represent new risks relative to products of traditional plant breeding and that any incremental risk would need to be established on a stepwise case-by-case comparative basis with existing crops and derived-foods as the baseline. Accordingly, concepts of familiarity and substantial equivalence were advanced by OECD and WHO as ways to establish a risk analysis baseline for determining whether and to what extent risk/safety assessment was needed. Regulatory implementations of this paradigm have skewed to increasingly complex portfolios of studies rather than adhering to analysis which is formulated to fit the risk/safety questions relevant to a given case. Plants produced through genome editing technology will benefit from risk analysis that implements sound problem formulation to guide the need for and nature of risk/safety assessments.

Problem Formulation for Off-Target Effects of Externally Applied Double-Stranded RNA-Based Products for Pest Control

Externally applied dsRNA-based biocontrol products may lead to off-target degradation of messenger RNA in target and non-target organisms. For the purposes of regulatory risk assessment of such products, producing a comprehensive catalog of any off-target effects using profiling methods is unnecessary and would be ineffective in supporting decision-making. Instead, problem formulation should derive criteria that indicate acceptable risk and devise a plan to test the hypothesis that the product meets those criteria. The key to effective risk assessment of dsRNA-based biocontrols is determining whether their properties indicate acceptable or unacceptable risk, not whether they arise from on- or off-target effects of dsRNA.

Occurrence, toxicity, production and detection of Fusarium mycotoxin: a review

Fusarium mycotoxin contamination of both foods and feeds is an inevitable phenomenon worldwide. Deoxynivalenol, nivalenol, zearalenone, T-2 toxin and fumonisin B1 are the most studied Fusarium mycotoxins. Co-contamination of mycotoxins has also been studied frequently. Fusarium mycotoxins occur frequently in foods at very low concentrations, so there is a need to provide sensitive and reliable methods for their early detection. The present review provides insight on the types, toxicology and occurrence of Fusarium mycotoxins. It further elucidates various detection methods of mycotoxin production from Fusarium strains, with a special focus on chromatographic and immunochemical techniques.

Certain new plant breeding techniques and their marketability in the context of EU GMO legislation - recent developments

The comparatively low adoption rate of GMO products in the European Union (EU) market seems to be connected with the strictness of authorization regulations and inefficiency of the authorization process itself. These problems will apply to any product deemed to be a GMO that could potentially be marketable in the EU. Since modern methods of plant breeding involving oligonucleotide-directed mutagenesis (ODMs) or site-directed nucleases (SDNs), including Clustered Regularly Interspaced Short Palindromic Repeats (CRISPR), are becoming ever more popular, it is crucial to establish whether the products of such new breeding techniques (NBTs), in particular those which involve precise methods of mutagenesis, are exempted from the EU legislation on GMOs or not. Legal uncertainty as to their status may result in reluctance to invest in such methods and develop them further. Here, developments are presented in the legal classification of certain NBTs products in the context of recent decisions and jurisprudence. The socioeconomic aspects of GMO adoption in both global and European contexts are discussed. The legal and practical landscape of GMO regulation in the EU is presented and how it may pose an obstacle to investment and the development of new products. The latest jurisprudence (e.g., Case C-528/16) [1] on the interpretation of the legal concept of GMOs and the scope of the legislation are analyzed, with the conclusion that the strict regulations will probably also apply to products of the NBTs involving precise methods of mutagenesis. This in turn will probably result in the restriction of their application in the development of new plant varieties in the EU.

Policy and Governance Perspectives for Regulation of Genome Edited Crops in the United States

Genome editing for crop improvement lies at the leading edge of disruptive bioengineering technologies that will challenge existing regulatory paradigms for products of biotechnology and which will elicit widespread public interest. Regulation of products of biotechnology through the US Coordinated Framework for Biotechnology is predicated on requiring burden of proof that regulation is warranted. Although driven by considerations of newly emerging processes for product development, regulation has, for the most part, focused on characteristics of the biotechnology product itself and not the process used for its development per se. This standard of evidence and product focus has been maintained to date in regulatory considerations of genome edited crops. Those genome edited crops lacking recombinant DNA (rDNA) in the product intended for environmental release, lacking plant pest or pesticidal activity, or showing no food safety attributes different from those of traditionally bred crops are not deemed subject to regulatory evaluation. Regardless, societal uncertainties regarding genome editing are leading regulators to seek ways whereby these uncertainties may be addressed through redefinition of those products of biotechnology that may be subject to regulatory assessments. Within US law prior statutory history, language and regulatory action have significant influence on decision making; therefore, the administrative law and jurisprudence underlying the current Coordinated Framework strongly inform policy and governance when considering new plant breeding technologies such as genome editing.

Agriculture R&D Implications of the CJEU's Gene-Specific Mutagenesis Ruling

On 25 July 2018, the Court of Justice of the European Union (CJEU) ruled that gene-specific mutagenesis must be regulated as genetically modified organism (GMO) technologies. However, the costs to agricultural research and development (R&D) innovation will be staggering, not to mention the brain drain to other countries. As a result, Europe can now be known as the deathplace of agricultural breeding innovations.

CRISPR-based tools for plant genome engineering

Molecular tools adapted from bacterial CRISPR (clustered regulatory interspaced short palindromic repeat) adaptive immune systems have been demonstrated in an increasingly wide range of plant species. They have been applied for the induction of targeted mutations in one or more genes as well as for directing the integration of new DNA to specific genomic loci. The construction of molecular tools for multiplexed CRISPR-mediated editing in plants has been facilitated by cloning techniques that allow multiple sequences to be assembled together in a single cloning reaction. Modifications of the canonical Cas9 protein from Streptococcus pyogenes and the use of nucleases from other bacteria have increased the diversity of genomic sequences that can be targeted and allow the delivery of protein cargos such as transcriptional activators and repressors. Furthermore, the direct delivery of protein-RNA complexes to plant cells and tissues has enabled the production of engineered plants without the delivery or genomic integration of foreign DNA. Here, we review toolkits derived from bacterial CRISPR systems for targeted mutagenesis, gene delivery and modulation of gene expression in plants, focusing on their composition and the strategies employed to reprogramme them for the recognition of specific genomic targets.

Safety, Security, and Policy Considerations for Plant Genome Editing

Genome editing with engineered nucleases (GEEN) is increasingly used as a tool for gene discovery and trait development in crops through generation of targeted changes in endogenous genes. The development of the CRISPR-Cas9 system (clustered regularly interspaced short palindromic repeats with associated Cas9 protein), in particular, has enabled widespread use of genome editing. Research to date has not comprehensively addressed genome-editing specificity and off-target mismatches that may result in unintended changes within plant genomes or the potential for gene drive initiation. Governance and regulatory considerations for bioengineered crops derived from using GEEN will require greater clarity as to target specificity, the potential for mismatched edits, unanticipated downstream effects of off-target mutations, and assurance that genome reagents do not occur in finished products. Since governance and regulatory decision making involves robust standards of evidence extending from the laboratory to the postcommercial marketplace, developers of genome-edited crops must anticipate significant engagement and investment to address questions of regulators and civil society.

The Regulatory Status of Genome-edited Crops

Genome editing with engineered nucleases (GEEN) represents a highly specific and efficient tool for crop improvement with the potential to rapidly generate useful novel phenotypes/traits. Genome editing techniques initiate specifically targeted double strand breaks facilitating DNA-repair pathways that lead to base additions or deletions by non-homologous end joining as well as targeted gene replacements or transgene insertions involving homology-directed repair mechanisms. Many of these techniques and the ancillary processes they employ generate phenotypic variation that is indistinguishable from that obtained through natural means or conventional mutagenesis; and therefore, they do not readily fit current definitions of genetically engineered or genetically modified used within most regulatory regimes. Addressing ambiguities regarding the regulatory status of genome editing techniques is critical to their application for development of economically useful crop traits. Continued regulatory focus on the process used, rather than the nature of the novel phenotype developed, results in confusion on the part of regulators, product developers, and the public alike and creates uncertainty as of the use of genome engineering tools for crop improvement.