A study commissioned by the Food Standards Agency (FSA) of the United
Kingdom was published to help provide an understanding of how selected
non-European Union (EU) countries regulate novel foods andgenetically
modifies organisms(GMOs) as compared to the EU. It also aimed to
identify different regulatory approaches and processes deployed by
non-EU countries and to assess how these differences in regulation
affect trade.

The report was divided into several parts, the first of which deals with
the regulation and authorization of novel foods inAustralia, Canada,
Japan, and the United States(US) and compares it to the EU system. The
report states that Japan and the US have no equivalent regulatory
concept for novel foods and these are not addressed in legislation.
Australia and Canada, on the other hand, have a regulatory regimen that
is close to EU's position as both countries require approval before
novel foods are released to the market.

The second part of the report discusses the difference of howArgentina,
Australia,Brasil, Canada, and the US regulate and authorize GMOs as
compared to the EU. The report highlighted that EU and Australia
emphasized on the process used to derive a product, while Argentina,
Canada, and the US may not regulate a product as a GMO if it is
substantially equivalent to a product developed through conventional
methods. This allows for a more flexible approach to accommodate new
techniques since the focus is on the final product rather than on the
process used to develop it. As for food labeling, the report mentioned
that Argentina and Canada have no mandatory requirements for labeling GM
content in foods. However, this is mandatory in Australia, Brazil, and
the EU with substantial differences in rules. The US also recently
introduced mandatory labeling for bioengineered food.

The last part of the report takes into account the international trade
agreements in the establishment and operation of regulations concerning
novel foods or foods derived from GMOs. A review of significant global
agreements showed that there was no reference to both. Rather, in the
absence of specific provisions, the World Trade Organization Agreement
on the Application of Sanitary and Phytosanitary Measures (SPS
Agreement) was found relevant in establishing the parameters within food
safety without becoming a trade barrier. Under the agreement, each
country can take measures to prioritize the protection of human, animal,
and plant health over trade as long as the measures are science-based
and do not discriminate between countries. Further attempts were made to
assess the effects of various trade agreements on the GM crop trade.
However, these were unsuccessful due to the absence of tariff codes,
particularly for GM varieties.

Comparing international approaches to food safety regulation of GM and
Novel Foods | Food Standards Agency
[www.food.gov.uk]