Biosafety mess: regularize trade!

The term ‘ostrich effect’ is often used as a pejorative – synonymous for burying head in sand in face of adversity. But on occasion it may prove cost-effective to ignore problems than to proactively pre-empt them. In fact, the ostrich algorithm in mathematics “is a strategy of ignoring problems because they may be exceedingly rare”.

The operative part, of course, is ‘cost-effectiveness of ignoring a problem’. The National Biosafety Committee faces a similar dilemma w.r.t import of genetically engineered products. Conservative estimates show that Pakistan imports $2 billion worth of GM-based products annually which includes cotton, oilseeds, edible oils, and distillers’ grains – without any certification declaring the GM-origins of the goods.

Is the certification necessary? Yes, because under Cartagena Protocol on Biosafety (2000) to which Pakistan is a signatory, exporters are required to label shipments containing genetically altered products. Second, under the National Biosafety Rules (2005), trading of genetically altered organisms or products made thereof must be licensed by National Biosafety Committee. And third, the prescribed Application form for Plant Protection Release Order (PPRO) required under procedures of Department of Plant Protection for clearance of imported plants/plant products mandates a declaration whether the commodity is GMO-based.

Are there any lacunas that hinder issuance of PPRO certification? None, except that prior to allowing import of any genetically altered product, the commercial party must seek approval from National Biosafety Committee. According to established rules of the game, the biosafety committee will be in its full rights to accord such approval; except, “licensing” imported GMO for commercial use/marketing risks opening the floodgates of “GMO for food” nightmare.

Thus, the biosafety committee takes refuge in the argument that in absence of approved guidelines for “Food, Feed & Processing” under NBR, and lack of pest-risk assessment analysis, it cannot issue approvals for imported GMO products. In turn, the Plant Protection Department takes the position that since biosafety committee is the relevant forum for according such approvals, it can only issue approvals for non-GMO products.

Beyond the obvious fact that such import may be at risk of violating procedural guidelines, why is it a problem? Annual volume of global trade in GMO and products thereof exceeds hundred of billion dollars, dominated by trade in cotton, corn, soybean and canola – used in production of yarn, animal feed, cooking oil, and food products such as cereals. Majority of Pakistan’s GMO imports are sourced from USA, Brazil, and India, global leaders in production of major GM commodities, and come with exporters’ certificate confirming safety for human consumption and/or release in environment.

Does this mean the problem is worth ignoring? Maybe. Afterall, value chains of several major domestic industries from textile, poultry and animal feed, to edible oil are dependent on imported GMO raw material. And putting a sudden stop on import due to absence of approvals risks causing a major and prolonged disruption in domestic production while importers look for alternate non-GMO origins, never mind that their cost-feasibility may be questionable.

But consider that the ostrich strategy is now coming at the cost of exports as well. In the aftermath of US-China trade war, opportunity knocked on Pakistan’s door to become a serious contender for animal feed export to its northern neighbour, which incidentally is also world’s largest poultry consumer.

Except, Chinese customs regulations – as is normal for any signatory to Cartagena Protocol – require that exports from Pakistan certify that the products include GM ingredients. This puts Pakistan’s customs in an impossible predicament. After all, local rules say that Pakistan ‘does not import or produces any GMO products for commercial use’.

Interestingly, China itself does not allow domestic cultivation of any GMO crops for food use to protects its traditional varieties. But has a more flexible approach when it comes to import for food, feed and processing purposes.

This is to say that if policymakers are so afraid of opening the “domestic GMO cultivation” pandora’s box due to political considerations and compulsions, they could still follow in Chinese footsteps and regularize the GMO trade framework and capitalize on the export opportunity. The trade front is also easier to address in comparison, considering commerce is purely a federal subject. This means that the challenges of jurisdiction faced in approval of GMO cultivation will not arise.

But for that to happen, the ostrich strategy must be given up. If GMO truly poses a danger to human health, irregular import of GMOs does nothing to protect the domestic population. Pakistan must make up its mind about GMOs and fast before another export opportunity bites the dust.