Codex Alimentarius and GM Food Guidelines

Monday, February 4, 2013

Codex Alimentarius and GM Food Guidelines, Pt. 1

Updated excerpt from Codex Alimentarius — The End of Health Freedom

Brandon Turbeville
Activist Post

Over the last two years, I have written extensively about the Codex Alimentarius guidelines and how they relate specifically to vitamin and mineral supplementsfood irradiation, and the use of Recombinant Bovine Growth Hormone (rBGH).

I have also detailed the history and workings of the international organization as well as many of the current day to day manifestations of Codex guidelines as they appear in domestic policy.

However, there is yet another area in which Codex guidelines will play a major role in the development of food policy – namely, the proliferation of Genetically Modified Food.

The Codex committee that serves as the main battleground for the consideration of GM food is the Codex Committee on Food Labeling. This committee is extremely relevant due to the fact that it can effectively reduce the power of the consumer to virtually nothing if it decides not to force companies or countries to label their GM food, thus removing the ability of the consumer to boycott and/or avoid those products. While it is well-known that public sentiment is unimportant to those at the top, governments and corporations tend to pay more attention when votes and sales reflect that sentiment. However, if Codex continues on its’ way to allowing unlabelled GM food onto the international market, the repercussions of consumer reaction will be entirely neutralized.

A brief discussion of the history of Codex in terms of GM food is necessary here to understand the direction that the organization is moving towards in regards to it.

For most of the seventeen years that Codex member countries have debated the safety of genetic modification of the food supply, the result has been little or no progress for one side or the other.
In 1993, at the behest of the Codex Commission, the CCFL agreed to begin working on the labeling aspect of GM food. Interestingly enough, the CCFL asked the United States, the country that was the most militant in its support of genetic modification, to develop a paper that would guide the committee’s discussion at the following session. When this session arrived, there was a flurry of opinions tossed around from several different countries. The most sensible position was that all GM foods should be labeled under any circumstances. Yet other countries, especially the pro-Gm ones, argued that labeling should only be required when there is the introduction of health or safety concerns, allergens, or when the food is significantly different from its traditional counterpart.[1] This is a debate that largely continues until this day.
The concept of “substantial equivalence” versus “process-based” labeling has also become one of the most hotly contested issues within the Codex GM food labeling debate. Process-based labeling simply means that the driving factor behind the labeling guidelines is the process by which the food is created, grown, or otherwise produced. Therefore, the qualifying factor for labeling GM food would be the process of genetic modification itself, forcing all GM food to be labeled as such. This is essentially the mandatory labeling of all GM food. When this concept was first introduced in 2001, it was supported by such countries as the European Union, India, and Norway. Its staunchest opponents, of course, were the United States and Canada.[2] Although this method of labeling standards was by far the most sensible if one were concerned about food safety and consumer rights of choice, it has been all but abandoned since the brief discussion at its introduction. The attention then has necessarily turned to the competing set of standards known as “substantial equivalence.”

“Substantial equivalence” guidelines are by far the most onerous means by which to label GM food outside of the scheme of voluntary labeling (such as what Canada has already pushed for).[3]

This set of standards not only provides loopholes through which GM food may enter the food supply, but also opens the door to total acceptance of GM food absolutely free of labeling. The idea behind the substantial equivalence labeling method is that the GM food will be compared to its conventional counterpart in terms of safety and composition.[4]

The food would then only require a label if it was found that there was a substantial difference between the GM product and the natural food or there were an introduction of a common allergen through the process of genetic modification. While at first it may seem that there is a legitimate consideration of safety under these principles, such an impression is far from the truth.

Several problems exist with the concept of substantial equivalence. First, as is often the case with government and bureaucratic initiatives, the semantics of the term “substantial equivalence” leaves the door open to the possible acceptance of virtually all GM food. While I will discuss this aspect further in future articles where the accepted Codex guidelines for testing GM food is mentioned, brief mention is still required early on in order to understand the dangers of the use of this labeling standard.

In order for a food to require labeling, it must do one of two things – introduce a new allergen or be significantly different from its “traditional counterpart.”[5] The former requirement refers to the introduction of something along the lines of the peanut gene or the introduction of another common allergy to a food, thereby causing a potential allergic reaction to the food after consuming it. However, there are thousands of food allergies besides peanuts. Codex itself admits in its GM food test protocol that the determination of what may be an allergy is a very difficult procedure. It says “At present, there is no definitive test that can be relied upon to predict allergic response in humans to a newly expressed protein.”[6]

Although the guidelines go on to say that these potential allergens should be tested on a case-by-case basis, it is clear that the testing mechanisms being recommended are not necessarily geared for determining the potential allergenicity of newly introduced GM foods. Especially on the scale that is needed to deal with the immense diversity of GM prototypes being introduced and the even greater variety of individual allergies that exist in the population.

It should also be noted that while there is some discussion of known allergens, there is no in-depth discussion of the very real possibility of new and previously unknown allergens being introduced due to the process of genetic modification. Indeed, the monitoring of the food once it enters the food chain is only occasionally mentioned throughout the Codex “Foods Derived From Modern Biotechnology” document and those mentions are vague and open-ended.[7] So the question that follows is whether or not all of these potential allergens will be labeled as such, or if only the most common ones will be considered.

Second, the requirement that a food must be compared and found substantially equivalent to its “traditional counterpart” (natural food) is misleading as well. To begin with, one must ask the question of what exactly “substantial equivalence” means. Quite obviously, the term does not mean that the GM product must be identical. This, in itself would negate the process of genetic modification.

Therefore, differences must necessarily be accepted. However, it is not at all clear just to what level these differences may exist and still be considered equivalent and/or safe. Nowhere is “substantial equivalence” clearly defined. The criterion for what is substantial and what is not is left completely open and subjective.

The closest thing there is to a definition is made by Nick Tomlinson of the UK Food Standards Agency in his report, “Joint FAO/WHO Expert Consultation on Foods Derived from Biotechnology” where he references the 1996 expert consultation where substantial equivalence was defined as “being established by a demonstration that the characteristics assessed for the genetically modified organism, or the specific food product derived there from, are equivalent to the same characteristics of the conventional comparator.”[8]

Here again the term equivalence is used with the connotation that equivalent does not translate into identical or same. Tomlinson makes this clear when he says:

The levels and variation for characteristics in the genetically modified organism must be within the natural range of variation for those characteristics considered in the comparator and be based upon an appropriate analysis of data.[9]

By not exactly being descriptive as to how wide a range this “natural range of variation” may be, it is apparent that substantial equivalence does not correlate to identical or even anything that would remotely be considered the “same.” Indeed, the very nature of genetic modification precludes this as a possibility to begin with.

The concept of substantial equivalence is unfortunately the theory of labeling requirements adopted by Codex. It is also very similar to the criteria used in the United States and Canada.

As to be expected in such pro-GM countries as the United States, the GM labeling requirements are even less restrictive than those of Codex. For the most part, labeling of GM foods in the United States and Canada is completely voluntary.

This voluntary labeling scheme based on the concept of substantial equivalence is both a prime example of the weakness of both standards as well as a dark omen as to the direction of Codex guidelines as they continue to be developed.[10]


[1] MacKenzie, Anne. A. “The Process of Developing Labeling Standards For GM Foods In The Codex Alimentarius.” AgBioForum, Vol.3, Number 4, 2000. pp. 203-208. Accessed May 24, 2010.

[2] “Canadians Deserve To Know What They Are Eating: Food Safety Must Come Before Trade.” Canadian Health Coalition, Media Advisory, May 1-4, 2001.

[3] Ibid.

[4] “Safety aspects of genetically modified foods of plant origin, a joint FAO/WHO consultation on foods derived from biotechnology, Geneva, Switzerland 29 May – 2 June 2000”. World Health Organization.

[5] MacKenzie, Anne. A. “The Process of Developing Labeling Standards For GM Foods In The Codex Alimentarius.” AgBioForum, Vol.3, Number 4, 2000. pp. 203-208. May 24, 2010.

[6] “Food Derived From Modern Biotechnology.” Codex Alimentarius 2nd Edition. P.20

[7] Ibid.

[8] Tomlinson, Nick. “Joint FAO/WHO Expert Consultation on Foods Derived from Biotechnology.” 2003. Accessed May 24, 2010.

[9] Ibid.

[10] “Guidance For Industry: Voluntary Labeling Indicating Whether Foods Have or Have Not Been Developed Using Biotengineering: Draft Guidance.” Food and Drug Administration. January 2001.

Wednesday, February 6, 2013

Codex Alimentarius and GM Food Guidelines, Pt. 2Updated excerpt from Codex Alimentarius — The End of Health Freedom

Brandon Turbeville
Activist Post

In my last article, I discussed the Codex Alimentarius position on the proliferation of Genetically Modified food in the world’s food supply – particularly the concept of substantial equivalence which uses circular and faulty logic in order to allow greater saturation of the food supply with genetically modified food.

“Substantial equivalence,” is an approach that seeks to approve the use and consumption of GM food based upon the idea that it is “substantially equivalent” to its traditional counterpart, thus, GM proponents claim, it is safe to consume and requires no extra labeling. This approach to GM food is easily dismantled and I encourage the reader to access my article on the subject in order to understand the weaknesses and dangers of using the substantial equivalence model for GM food in any context.

The concept of substantial equivalence is unfortunately the theory of labeling requirements adopted by Codex. It is also very similar to the criteria used in the United States and Canada. As to be expected in such pro-GM countries as the United States, the GM labeling requirements are even less restrictive than those of Codex.

For the most part, labeling of GM foods in the United States and Canada is completely voluntary. This voluntary labeling scheme based on the concept of substantial equivalence is both a prime example of the weakness of both standards, as well as a dark omen as to the direction of Codex guidelines as they continue to be developed.[1]

The FDA does not require GM foods to be labeled unless they meet one of four rather severe criteria. Even then, the labeling refers only to the issue at hand, not the process from which the food was created. The criteria for labeling are as follows:
1.) If a bioengineered food is significantly different from its traditional counterpart such that the common or usual name no longer adequately describes the new food.
2.) If an issue exists for the food or a constituent of the food regarding how the food is used or consequences of its use, a statement must be made on the label to describe the issue.
3.) If a bioengineered food has a significantly different nutritional property, its label must reflect the difference.
4.) If a new food includes an allergen that consumers would not expect to be present based on the name of the food, the presence of that allergen must be disclosed on the label.[2]

So, as these recommendations suggest, a GM food must only be labeled when it is so different from its “conventional counterpart” that it cannot even be considered the same food, is the cause of reactions or consequences that the natural version of it would not have caused, has a “significant” difference in nutritional composition, or if it introduces an allergen that would not otherwise have been present.

It should be noted, like the Codex guidelines for substantial equivalence mentioned earlier, that “significant” difference in nutritional composition is not clearly defined. So what some may consider to be truly significant might not even be considered worthy of any concern by the FDA, and certainly not by the manufacturing company.

Also, as mentioned earlier, there is no discussion of whether or not the inclusion of allergens to a food includes those less common allergies or just the most popular such as peanuts. Yet even meeting these criteria does not necessarily draw the label of “genetically modified” – merely a labeling of the potential side effects of consuming these foods.[3]

Only when one of these four criteria has been met must companies label their products in a manner that may suggest genetic modification and, even then, only in a subtle manner. In all other instances, however, the labeling is completely voluntary.

Just as disconcerting as voluntary labeling is the fact that the alleged “safety testing” is not even conducted by the FDA or any other regulatory agency, but by the food producers themselves. The FDA merely takes for granted the truth of whatever is provided them by industry. That is, if anything is provided to them at all.[4]

As stated in the federal register as far back as 1992, the FDA says,

FDA has traditionally encouraged producers of new food ingredients to consult with FDA when there is a question about an ingredient’s regulatory status, and firms routinely do so, even though such consultation is not legally required.[5]

It is certainly concerning to know that, at best, firms are encouraged to consult with the FDA but are not required to do so. Interestingly enough, this is not the position taken in regards to proven safe and effective natural and herbal supplements.

Adding to absurdity of the voluntary labeling policy held by the FDA, the regulatory agency works on the premise that GM foods are safe to begin with and that there is no difference between GM food and natural food.[6]

In the 1992 FDA Federal Register, the agency makes the claim,

In most cases, the substances expected to become components of food as a result of genetic modification of a plant will be the same as or substantially similar to substances commonly found in food, such as proteins, fats and oils, and carbohydrates.[7]

Notice the similar terminology of “substantially similar” as compared with the “substantial equivalence” of Codex. This adds even more credibility to the idea that the Codex model of GM food regulation is based on that used by the pro-GM FDA. Not only that, although the difference between the wording might seem unimportant to some, the term “similar” is even more open-ended than the Codex “equivalent.”

But how did the FDA come to these conclusions?

The agency admits that there is no premarket testing by the FDA itself; merely relying on industry to voluntarily consult with the FDA only when the industry feels there might be a problem with the product. [8]

Yet the agency still maintains, through basic assumption, that GM foods are not different from the natural versions. In the same Federal Register it says,

Under this policy, foods, such as fruits, vegetables, grains, and their byproducts, derived from plant varieties developed by the new methods of genetic modification are regulated within the existing framework of the act, FDA’s implementing regulations, and current practice, utilizing an approach identical in principle to that applied to foods developed by traditional plant breeding. The regulatory status of a food, irrespective of the method by which it is developed, is dependent upon objective characteristics of the food and the intended use of the food (or its components). The method by which food is produced or developed may in some cases help to understand the safety or nutritional characteristics of the finished food. However, the key factors in reviewing safety concerns should be the characteristics of the food product, rather than the fact that the new methods are used.[9]

The FDA here is claiming that the process of genetic modification, even though it has not evaluated it thoroughly, is not only safe but, for the most part, irrelevant to the question of food safety.

Of course, this is merely manufacturing conclusions out of thin air. The FDA asserts the safety of GM food because there is “substantial equivalence” between the two. However, there is “substantial equivalence” only because the FDA claims that this is the case. There is a massive lack of evidence to support any of these claims.

The FDA also claims that genetic engineering is no different from “traditional plant breeding,” an argument that is often made within the pro-GM community. Such is the belief (or argument) that traditional means of plant breeding such as grafting and cross-pollination are essentially the same as removal and insertion of DNA from one life form to another. In reality, nothing could be further from the truth.

This argument would be akin to claiming that breeding of humans of different ethnic backgrounds is the same as breeding between humans and horses.

Additionally, the question of how the FDA would know this — since it has not conducted any scientific experiments regarding this claim — arises yet again. Still, it continues to blend the two very different methods together by defining genetic engineering as the “alteration of the genotype of a plant using any technique, new or traditional.”[10]

Thus, the FDA puts the insertion of a pig gene into a tomato into the same category as natural birth, since genes change and develop with each generation. If there were any doubt as to whether or not this is the FDA’s position their claim that “Most, if not all, cultivated food crops have been genetically modified,” should easily remove it. [11] This claim is only true if one accepts the FDA’s definition of natural reproduction as genetic engineering.

As in most cases involving the FDA, the biotech food industry, and Codex Alimentarius, the boundaries of logic are not only pushed to the breaking point in order to justify and promote the proliferation of GM food, those boundaries are regularly crossed.

Indeed, these mental gymnastics used create an environment in which toxic GM food is virtually unregulated while healthy organic substances are annihilated by force and regulation are a feat in their own right.

[1] “Guidance For Industry: Voluntary Labeling Indicating Whether Foods Have or Have Not Been Developed Using Biotengineering: Draft Guidance.” Food and Drug Administration. January 2001.

[2] Ibid.

[3] Ibid.

[4] “Statement of Food Policy – Foods Derived From New Plant Varieties,” FDA Federal Register Vol. 57. 1992. Accessed May 24, 2010.

[5] Ibid.

[6] Ibid.

[7] Ibid.

[8] Ibid. p. 5.

[9] Ibid p. 4.

[10] Ibid. 




Friday, February 8, 2013

Codex Alimentarius and GM Food Guidelines, Pt. 3

Updated excerpt from Codex Alimentarius — The End of Health Freedom

Activist Post
Brandon Turbeville

In my last article, “Codex Alimentarius and GM Food Guidelines Pt. 2,” I wrote extensively about the position assumed by the FDA in regards to genetically modified food and the methodology used to assess its safety before it is released into the general food supply. Needless to say, the FDA, which is notorious for its corruption andrevolving door with Big Agricultural Corporations like Monsanto, takes an unbelievably hands-off approach to the regulation of GM food.

Yet, unfortunately, the approach taken by the FDA toward GM Food is only unbelievable if one expects the agency to apply science, logic, and reason to their decision-making process.

However, when one begins evaluating the FDA position on GM food in the context of the position held by Codex Alimentarius, one can easily see an agenda taking shape whose ultimate goal is the total proliferation of GM food the world over.

For instance, in the early 1990s, around the time the FDA was announcing its own policy toward GM food, the debate within Codex was heating up as well. Most of the arguments were taken up by the Codex Committee on Food Labeling (CCFL) and, for the most part, pitted the United States and Canada against the European Union, India, and Norway.

In 1996, because little could be agreed upon, the CCFL asked for guidance from the Codex Alimentarius Commission (CAC) on how labeling guidelines might be developed. In 1997 the CAC produced a document for that purpose. These recommendations were that foods not “equivalent” to natural foods in nutritional value, intended use, or composition should be labeled.

Yet this was not accepted into Codex guidelines as Australia, New Zealand, Peru, and Brazil joined with Canada and the United States in opposing these recommendations. Definitions of terms also became an issue at the meeting.[1]

At the 27th CCFL session in 1999, it was decided that the Proposed Draft Recommendations for GM food labeling be reconsidered and rewritten. For this purpose, Codex created the Ad Hoc Working Group. Their stated mission was to more fully define “biotechnology-derived foods” and to revise the options considered for labeling between process-based and substantial equivalence methods. The Working Group also agreed to consider establishing a maximum level of GM ingredients in a food as well as a minimum level for accidental inclusion of GM ingredients or food within a food.

As mentioned earlier, substantial equivalence has emerged as the most favored method of labeling within Codex, in an almost identical fashion to the FDA and Health Canada model.

Indeed, it is easily understood why this is the case when one takes a closer look at the Working Group developed to evaluate and rewrite labeling recommendations. While certain instances may seem harmless when viewed separately, when taken together they reveal a rather obvious attempt to stack the odds in favor of pro-GM sentiment by the CCFL.

First, Canada, perhaps the most pro-GM Codex member country besides the United States, was selected to chair the Group as well as coordinate the Group’s direction.

Also, a smaller Drafting Group was created under the Working Group to “hold the pen.” It was this group that would do much of the actual work in terms of hammering out the Recommendations document. However, five of the six countries represented in the Drafting Group were pro-GM countries.[2] Clearly, it would be difficult for a non-favorable view of GM food to win out in a situation such as this.

In 2000, an attempt was made by the CCFL to direct the Working Group to streamline the two different methods of labeling (process-based and substantial equivalence) into a Codex Guideline as well as other key issues involving GM food labeling. A document of this nature was subsequently produced by the United States. Yet, despite the packing of the Drafting and Working Groups, the CCFL was still unable to approve the guidelines that the groups produced.

However, the Committee was able to approve the use of three definitions related to GM food.[3] They are as follows:

  1. Food and food ingredients obtained through certain techniques of genetic modification/genetic engineering – food and food ingredients composed of or containing genetically modified/engineered organisms obtained through modern biotechnology, or food and food ingredients produced from, but not containing genetically modified/engineered organisms obtained through modern biotechnology.
  2. Genetically modified/engineered organism – an organism in which the genetic material has been changed through modern biotechnology in a way that does not occur naturally by multiplication and/or natural recombination.
  3. Modern Biotechnology – the application of:

a. In vitro nucleic acid techniques, including recombinant deoxyribonucleic acid (DNA) and the direct injection of nucleic acid into cells or organelles

b. Fusion of cells beyond the taxonomic family, that overcome natural physiological, reproductive, or recombination barriers and that are not techniques used in traditional breeding and selection.[4]

When one looks at the definitions agreed upon at the 29th session of Codex, it can be seen that there is a move toward using the term “modern biotechnology” in place of “genetic engineering/modification.” This is largely an attempt to use semantics in an effort to reduce, through ignorance, the apprehension of the public to the consumption of GMO’s.

However, in the face of such controversy, in 2003 Codex did produce and approve a set of Guidelines for the assessment of the safety of GM food. Entitled “Codex Principles and Guidelines On Foods Derived From Biotechnology,” the Guidelines do not deal with labeling concerns at all, but with the standards for the science used to assess these foods for safety.

The “Codex Principles and Guidelines On Foods Derived From Biotechnology” is made up of four sections, two of which deal with GM plants while the other sections deal with GM organisms in general and GM animals respectively. Similar to the “Guidelines for Vitamins and Mineral Supplements,” these guidelines are not only unscientific but carefully crafted to allow the approval of dangerous GM foods. The game, in essence, is clearly rigged.

When looking at the first section of the guidelines one is able to see a very real correlation to those designated for vitamins and minerals. Using a form of risk analysis to determine the safety of GM food, Codex seeks to explain the reason for its choice of methodology. It states

While risk analysis has been used over a long period of time to address chemical hazards (e.g. residues of pesticides, contaminants, food additives and processing aids), and it is being increasingly used to address microbiological hazards and nutritional factors, the principles were not elaborated specifically for whole foods.[5]

This is an interesting statement considering the fact that risk analysis was indeed considered adequate for the safety examination of vitamins, minerals, and nutritional supplements. However, for whole foods, GM foods in particular, Codex has decided that risk analysis is not appropriate.

The very next section of the Introduction admits that while risk analysis can in fact be applied to foods (including GM food) “in general terms”, “it is recognized that this approach must be modified when applied to a whole food rather than to a discrete hazard that may be present in food.”[6] One can gain an understanding of how the process is adapted to suit the needs of Codex by reading through the guidelines as a whole. However, suffice it to say that this modification is generally the removal of all standards and qualifications that might illuminate the vast amount of safety concerns present within GM foods.[7]

Another disturbing statement made in the introduction to the document casts even more doubt upon the scientific validity of Codex’s guidelines. The Guidelines state,

Where appropriate, the results of a risk assessment undertaken by other regulatory authorities may be used to assist in the risk analysis and avoid duplication of work.[8]

While on its face, this statement appears only to be a call for labor efficiency, at its best it assumes the objectivity of the regulatory authorities doing the testing. However, what is most concerning about this policy is that risk assessment “conclusions” reached by regulatory agencies such as the FDA and Health Canada may be accepted in place of an independent examination.

Truthfully, the likelihood of a legitimately independent assessment made possible by Codex is almost nonexistent. However, in the case of GMO’s, the odds are even less so for the FDA and Health Canada, two agencies that have been largely bought and paid for by Monsanto and other large agri-business corporations. Indeed, as far as GM foods go, the FDA assessments have largely been completed since the time that the agency has claimed that there is no difference between genetic modification and traditional plant breeding.[9] This agency has also made it clear that safety testing is to be conducted by the manufacturer of the product rather than the agency itself, relying solely on the company’s scientific and moral standards. In effect, as mentioned earlier, the science determining the safety of GM foods comes straight from the manufacturer itself.[10]

With this in mind, one can clearly see that the same line of ascension exists in Codex Alimentarius. If Codex is willing to accept the safety assessments of regulatory agencies without independent testing of its own and regulatory agencies are willing to accept the safety assessments of corporations without independent testing of their own, then Codex is willing to accept the safety assessments of corporations without independent safety testing of their own. Indeed, this syllogism adequately reflects the reality of the relationship between Codex, corporations, and the future of GM foods.

Another issue of great concern is the definition of “conventional counterpart.” Because Codex uses the concept of substantial equivalence[11], this seemingly requires that the GM product be compared to its natural counterpart.

However, the definition of conventional counterpart, according to Codex, is “a related organism/variety, its components and/or products for which there is experience of establishing safety based on common use as food.”[12] This definition poses a potential problem because it does not make clear (in the body of the text) that the conventional counterpart must be the natural version of the food. In a footnote, the statement is made that “It is recognized that, for the foreseeable future, foods derived from modern biotechnology will not be used as conventional counterparts.”[13]

The phrase, “for the foreseeable future” raises its own difficulties, because it provides a potential loophole. “Foreseeable future” does not set a timeline for the current policy to run out, but it does leave open the possibility of allowing a change in the current practice.

Allowing GM products to be compared to other GM products for substantial equivalence is an enormous blow to the environment, human health, and consumer choice. Such an action would completely undercut the already weak and ridiculous method of substantial equivalence and would turn the entire nature of our food supply upside down. One would be comparing a dangerous product to another dangerous product but labeling it safe because it was substantially equivalent to the first dangerous product.

Like the situation involving vitamins and minerals, this is the Twilight Zone reality produced by Codex once it gains power of the food supply.


[1] MacKenzie, Anne. A. “The Process of Developing Labeling Standards For GM Foods In The Codex Alimentarius.” AgBioForum, Vol.3, Number 4, 2000. pp. 203-208. May 24, 2010.

[2] Ibid.

Please Note:

While it is true that the European Union had two representatives on the panel, it also true that the EU speaks with one voice. Even if one were to argue that this would give them extra representation, pro-GM nations still outnumber anti-GM nations.

[3] MacKenzie, Anne. A. “The Process of Developing Labeling Standards For GM Foods In The Codex Alimentarius.” AgBioForum, Vol.3, Number 4, 2000. pp. 203-208. May 24, 2010.

[4] Ibid.

[5] “Foods Derived From Modern Biotechnology,” 2nd edition. Codex Alimentarius. P.1 Accessed May 24, 2010.

[6] Ibid.

[7] Ibid.

[8] Ibid.

[9] “Statement of Food Policy – Foods Derived From New Plant Varieties,” FDA Federal Register Vol. 57. 1992. Accessed May 24, 2010.

[10] Ibid.

[11] “Foods Derived From Modern Biotechnology,” 2nd edition. Codex Alimentarius. P. 9 Accessed May 24, 2010.

[12] Ibid. p.2

[13] Ibid.

[11] Ibid. 

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