Dear Director,



I write in support of the allowance of the above proposal which appeared, for public comment, in section C2 of the Manila Standard on 25 July 2017.




Vitamin A deficiency remains, in the Philippines as in many other countries, a serious cause of mortality and morbidity, including blindness, for young children, despite current interventions and improving living standards. The deficiency is a nutritionally acquired immune deficiency syndrome, and the most significant cause of under 5 years child mortality as well as the most important cause of childhood blindness.


Provitamin A Biofortified GR2E Rice, also known as Golden Rice, has the proven capacity to provide an additional intervention to combat vitamin A deficiency, with minimal cultural change.   Every grain of Golden Rice is labelled with its colour, instantly ‘readable’ by any level of literacy in any language.   The technology has been donated by its inventors for use in developing countries and in public owned rice varieties, and there are no limitations, except export sale, on the use of Golden Rice harvest, which can be locally sold, or replanted by growers. The terms of the licenses in place in The Philippines, and elsewhere, ensure that Golden Rice will cost no more than the white rice variety the nutritional trait has been introduced to.  Growers or consumers have no obligation to sign anything, or pay anything for the extra nutrition.  The agronomy of the varieties is unaffected by the introduction of the nutritional trait.




Should the regulatory authorities in the Philippines find the science in the regulatory submission to prove Provitamin A Biofortified GR2E Rice to be safe to humans and animals, as whole or processed rice, the Proposal should be allowed. 




This will, in time, allow Philippine consumers the choice to consume Provitamin A Biofortified GR2E Rice, or not. 




Yours sincerely,




Prof. Dr. Klaus-Dieter Jany





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Subject: Plea for coherent decision-making in the EU




Dear President Juncker,


All institutions of the European Union should be measured by the way they comply with democratic and legal principles and follow the rules and regulations laid down by the Community itself, i.e. the Member States and the EU-Parliament.


This applies also to the forthcoming decision of the Commission on the approval for commercial cultivation of three genetically modified maize lines (1507, Bt11 and MON810). On 28 March 2017, the representatives of the 28 Member States did not come to an agreement on such approval. According to EU rules, this should lead to the following: The Commission must now take the decision to authorize commercial cultivation of the three maize lines, in accordance with Regulation (EU) No 182/2001, Directive 2001/18/EC and Regulation (EC) 1829/2003. Additional justification for the Commission’s approval for cultivation of the above-mentioned three genetically modified maize lines is set forth below:


        The European Food Safety Authority (EFSA), responsible for the risk assessment of genetically modified plants has performed a risk assessment of the genetically modified plants. After thorough scientific examination, no risks for human health and to the environment have been identified.


        The EU Commission is obliged to comply with its own regulations. According to the principle of supra-nationality within the European Union, the Member States are standing down from exercising their national sovereignty and jointly carrying it out on a European level. The directives and regulations adopted are obligatory for all


In addition, the principle of legal compliance applies. To prevent arbitrariness the EU system can only work if all Member States adhere to the rules previously agreed by all.


        Such a decision will send a strong signal to such individual Member States that prefer to transfer their responsibility to the EU Commission. In addition, it will respect the decision of the Member States who voted in favor of cultivation.


Those members of the EU who by their voting behavior repeatedly refuse to make clear and binding decisions - knowing that according to the legal regulations the EU Commission is subsequently obliged to make a decision - do not live up to the responsibility assigned to them. Instead, they actually make the procedure both time-consuming and cost-intensive by “hiding” instead of taking responsibility. Such practices, which meanwhile have unfortunately been established and are common regarding genetic modification and herbicides, not only diminish the confidence in the work of the European Union, but are also an expression of disregard for common democratic principles.


We therefore kindly ask you to act according to the democratic principles applicable to all EU members and take a timely decision to authorize the three genetically modified maize varieties.




Prof. Dr. Klaus-Dieter Jany,

Wissenschaftlerkreis Grüne Gentechnik e.V. (WGG)

Ricardo Serra Arias,

President of ASAJA Andalucía

Philippe Dumont,

Association Française des Biotechnologies Végétales

Pedro Barato Triguero

President of ASAJA España


Prof. Hon. Emeritus Klaus Ammann, University of Bern, Switzerland


Prof. Erik Andreasson, Unit of Resistance Biology, Department of Plant Protection Biology, Swedish University of Agricultural Sciences, Alnarp, Sweden


Eugénia de Andrade, PhD, Independent Researcher, Lisbon, Portugal


Prof. Geert Angenon, Laboratory of Plant Genetics, Faculty of Science and Bioengineering Sciences Vrije Universiteit Brussel (VUB),Belgium


Assoc. Prof. Bojin Bojinov, Head, Department of Genetics and Plant breeding, Agricultural University of Plovdiv, Bulgaria


Prof. Dr. Borut Bohanec, Head of Chair of Genetics, Biotechnology, Statistics and Plant Breeding at Biotechnical faculty, University of Ljubljana, Slovenia


Jose Ignacio Cubero, Emeritus professor Plant Genetics and breeding, University of Cordoba


Sylvie De Buck, PhD, VIB-International Plant Biotechnology Outreach (IPBO), Belgium


John Davison, Research Director (retired), French National Institute for Agricultural Research, Versailles, France


Roberto Defez, Tenured staff scientist, IBBR, National Research Council Italy


Geert De Jaeger ,Associate Department Director, Functional Interactomics, VIB-UGent Center for Plant Systems Biology, Ghent University, Belgium


Dennis Eriksson, Researcher, Department of Plant Breeding, Swedish University of Agricultural Sciences (SLU), Alnarp, Sweden


Prof. G. Gheysen, Head Department Molecular Biotechnology, Faculty of BioScience Engineering, Ghent University, Belgium


Prof. Jonathan Gressel, Plant & Environmental Sciences, Weizmann Institute of Science, Rehovot, Israel


Nicolae Hristea, Agrobiotechrom, USAMV Bucharest, Romania


Dr Penny Hundleby, Senior Plant Scientist, UK


Drew L. Kershen, Professor of Law Emeritus, University of Oklahoma, Norman, USA


Dr. Harry A. Kuiper, former chair of the EFSA GMO Panel, formerly RIKILT, Institute of Food Safety Wageningen University & Research Center, Wageningen, Netherlands


Prof. Alan McHughen, University of California, Riverside, Ca, USA


Dr. Piero Morandini, Assistant professor in Plant Physiology, Department of Biosciences, University of Milan,Italy


Prof. Reinhard Renneberg, Hong Kong University of Science and Technology, SAR Hong Kong, China


Rodomiro Ortiz, PhD, Faculty Professor, Genetics & Plant Breeding, Swedish University of Agricultural Sciences (SLU), Alnarp, Sweden


Dr Agnès Ricroch , University of Paris Sud, President of the Life Sciences Section of the French Academy of Agriculture, France


Anneli Ritala-Nurmi, Principal Scientist, Project Manager, VTT Technical Research Centre of Finland Ltd, Solutions for Natural Resources and Environment


Dr. Anne-Christine Ritschkoff, Executive Vice President, Strategic Research, VTT Technical Research Centre of Finland Ltd.


Angelo Santino, Senior Scientist, ISPA, National Research Council Ital.


Giovanni Tagliabue, Independent researcher, Carugo (Como), Italia


Prof. Tomasz Twardowski, Head of Protein Biosynthesis Department, Institute of Bioorganic Chemistry, Polish Academy of Sciences, Poznań, Poland


Tomas Vanek, PhD Head of Laboratory of Plant Biotechnologies of Institute of Experimental Botany AS CR, Prague, Czech Republic


Prof. Nathalie Verbruggen, Interfaculty School of Bioengineering, Free University of Brussels (ULB)


Prof. Li-Hua Zhu, Department of Plant Breeding, Swedish University of Agricultural Sciences, Alnarp, Sweden



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