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Frankfurt am Main and Paris, 10 February 2020





Open Letter to Commission President von der Leyen, Executive Vice President for the European Green Deal Timmermans, Commissioner for Health Kyriakides, Commissioner for Agriculture Wojciechowski, Commissioner for Innovation and Youth Gabriel, and Commissioner for Environment, Oceans and Fisheries Sinkevičius




Follow-up request to Open Letters dated 18 July 2018 and 17 October 2018



Dear President von der Leyen, Dear Executive Vice President Timmermans, Dear Commissioners,


This is a follow-up to our prior letters dated 18 July 2018 and 17 October 2018 requesting that the Commission quickly take action to enable the use of genome editing technologies in agriculture.


We have noted that Council Decision (EU) 2019/1904 now provides the Commission with the necessary authority and support to undertake a study on the status of new genome editing techniques following the decision of the European Court of Justice and to make a proposal as appropriate before the end of April 2021.


In our prior letters we have noted the need to review and update Directive 2001/18/EC in light of new technical progress and scientific knowledge, something which has not been done in the last 19 years.  That process needs to occur independently of the genome editing question which requires urgent action: if we truly wish to address climate change, protect our environment and reduce the use of phytosanitary products in the agricultural context, we must permit our plant breeders to use genome editing tools to adapt our plants more quickly and more precisely.


To assist you in the mission requested by Council Decision (EU) 2019/1904, please find enclosed an Explanatory Note and a proposal for a draft directive to amend Directive 2001/18/EC.


For genome editing in agriculture, we believe that small modifications to (i) two articles of Directive 2001/18/EC, (ii) Annex I A and (iii) the addition of a new Annex I C (and with corresponding changes to be made to other GMO regulations) will suffice to permit plant breeders to work with these technologies in a serene environment and bring to market products that are extremely similar to those that could be obtained with traditional breeding techniques.


We remain at your disposal to answer any questions you may have regarding the matters raised in the attached documents. In that regard, if convenient to any interested persons within the Commission’s departments and services concerned by this topic, we are happy to come to Brussels at your convenience and provide briefing sessions to explain our proposal.


In line with prior recommendations of Commissioner Andriukaitis we are informing competent authorities of France and Germany of this proposal.



Very Respectfully,




Prof. Dr. Klaus-Dieter Jany,                              Georges Freyssinet


Wissenschaftlerkreis Grüne Gentechnik e.V (WGG)     Association Française des Biotechnologies


                                                                                   végétales (AFBV)





Annexes:             1             Explanatory note


                           2            Draft Amendment to the Directive


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AFBV_WGG_Draft Amendment_ 2020.pdf
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