The African Centre for Biosafety (ACB) has a long track record in monitoring and interrogating GMO permits in South Africa, providing independent analysis and lobbying for greater public participation in decision making. In this letter we respectfully call on you to use your discretionary powers to request an Environmental Impact Assessment (EIA) for Syngenta’s application for commercial release of genetically modified maize, GA21, in terms of Section 78 of the Biodiversity Act. We also appeal to the Executive Council: GMO Act, to exercise their discretionary powers in terms of the GMO Act to call for an EIA for this event.

South Africa is the only country in the world to have allowed the genetic modification of a staple food. The ACB respectfully submits that the general release of this new event, along with recent amendments in the law should trigger an EIA as the crop poses potential risks to the environment and to human health.

• The molecular characterisation of the event indicates several irregularities, including open reading frames and a truncated constructs which could give rise to unintended gene effects


• The transfer of the herbicide-tolerant trait to weeds could result in increased herbicide application. The potential for economically important weeds developing herbicide tolerance is a cause for concern


• Glyphosate use has resulted in several unwanted effects on aquatic systems and terrestrial organisms and ecosystems


• The US experience of Roundup Ready field trials has shown a marked increase in herbicide usage, particularly glyphosate


• In the Argentinean experience, the large scale uptake of Roundup Ready Soya has had devastating impacts on food security and the environment


• Syngenta’s reliance on the assessments of European Food Safety Authority (EFSA) is fraught with problems given the criticisms and contradictions inherent within EFSA especially in respect of its methodologies and perceived pro-industry stance,  which it is itself grappling with


• The claims of the increased yield performance of GM crops are unsubstantiated


• The literature cited in support of Syngenta’s claims is derived from industry sources that have a financial connection with the agri-biotech industry and are not from independent peer-reviewed sources


• It is disingenuous of Syngenta to suggest that planting of GM crops will contribute to mitigating the impacts of climate change


• Food security is not enhanced by planting of GM crops; ensuring food security requires and multi-pronged, agro-ecological approach to agriculture


• In a country like South Africa where job creation is a driving economic and social imperative, technologies that are likely to recue jobs to the benefit only of the developer of the technology must be adopted with caution


• Technologies requiring additional inputs place additional burdens on farmers


• The GA21 technology requires a level of agricultural and functional literacy and access to information which cannot be assured for some sections of the community to whom it will be readily available – no information campaign accompanies the proposed release