by Phil Bereano

Why are people in the United States seemingly untroubled by a technology that causes Europeans so many difficulties?
— Science, 16 July 1999

On March 26, 2003, with bombs falling in Baghdad and relations between the United States and Europe at their worst in decades, a group of US Congressmen urged President Bush to file a dispute against the European Union in the World Trade Organization. These legislators, led by Illinois Republican Dennis Hastert and representing the nation’s largest agricultural biotechnology interests, had chafed for four years at the Europeans’ refusal to import genetically modified crops. With the public distracted and nationalism at a fever pitch, Hastert blasted the EU’s regulations as unscientific and unfair —a clear and present threat to the future of US farming.

Hastert’s exhortations were the latest in a series of Congressional attempts — led at one time by then-Senator John Ashcroft of Missouri, where Monsanto is headquartered — to have the Administration push for “success in world markets” by “removing unfair trade barriers” to bioengineered foods in Europe. In the months preceding the war, a group of Congressmen, led by Iowa Senator Charles Grassley, undiplomatically told the Bush administration “to get off its duff and make a decision.”

The North Atlantic clash over genetically modified (GM) foods highlights some of the economic, cultural, and political differences between the United States and the European Union. The E.U.’s de facto moratorium on approving genetically modified foods, and its requirement for labeling such foods, contrasts sharply with the US position that the foods are safe and need no special markings.

“In Europe, across the whole food technology front, confusion and hysteria have displaced reason and economics, with incalculable costs to those who are trying to bring new and beneficial innovations to the market,” editorialized the Wall Street Journal in 1998. Europeans, needless to say, do not take kindly to these patronizing characterizations. As David Bryne, European Commissioner for Health and Consumer Protection, recently warned: “If consumers see that something is done to force a situation that they do not want, I think the effects would be adverse.”

Proponents of GM crops have also been quick to exploit tragedy for their own gain, characterizing the refusal of famine-stricken Southern African countries to import modified maize as the result of anti-GM activist manipulation, as if Africans were incapable of deciding what is in their own best interest. “This is a trade issue,” testified one of Hastert’s accomplices, Republican Congressman Frank Wolf, “but more importantly, it’s an issue of life and death.”

The Charges

Jim Murphy, a former Assistant US Trade Representative attributed European timidity to old-world conservatism: “They are culturally risk-averse to trying new things,” he said, adding that he jokes to his European friends that “the definition of an American is a risk-taking European.” The New York Times dismissed the EU’s stance as “agricultural protectionism.” Others have been equally patronizing about their technical capabilities. According to Dan Glickman, the Clinton Administration’s Secretary of Agriculture, Europeans “just don’t have, really, the same kind of sophisticated mechanism to scientifically examine food products and determine if they’re safe that we do” — ignoring the reality that, despite such vaunted regulatory vigor, 76 million Americans are food poisoned every year.

In the 1980s, the Republican Administration decided that the new technology of genetic engineering should be handled by existing regulatory statutes rather than — as in Europe — going to the legislature for comprehensive new laws. As a result, there was little public discussion. The resulting US “regulatory” scheme is makeshift, full of absurdities and loopholes. The bioindustry and US government officials have united in denying that genetically engineered foods are significantly different from natural ones. They call this the doctrine of “substantial equivalence.” 

“A tomato is a tomato is a tomato,” said Brian Sansoni of the Grocery Manufacturers of America, evoking the image of Gertrude Stein plopping down to a summer salad.

As the EU recognizes, substantial equivalence is nothing more than the notion of analogy, rather than a scientific proof. Indeed, the Codex Alimentarius — a UN agency jointly administered by the World Health Organization and the Food and Agricultural Organization and charged with recommending international food safety guidelines — has recently taken the position that if substantial equivalence is to be relied upon at all, it should merely be the beginning of a scientific safety assessment. Europeans know that the US regulatory process has never been based on government scientific oversight. As an expert seminar of the World Health Organization noted three years ago, “hazards to human health may arise from the release of genetically modified organisms in the environment, (and) therefore there is a need for risk analysis before release.”

The United States’ industry-friendly policy was authored in May 1992 by a legacy of the Reagan administration, the Council on Competitiveness. The official FDA document asserted that “the agency is not aware of any information showing that foods derived by these new methods differ from other foods in any meaningful or uniform way.” Of course, the very fact that the government allows industry to patent modified organisms implies that these foods are substantially different from those found in nature. 

Under records uncovered in the course of legal action, we now know that the US government ignored the advice of its own FDA scientists, who believed genetically modified foods should be specially evaluated because the uniqueness of their manufacture meant that one could not predict their safety. One wrote that “there is a profound difference between the types of unexpected effects from traditional breeding and genetic engineering, which is just glanced over in this document.” He added that aspects of genetic engineering “may be more hazardous” than traditional breeding. Yet the FDA requires no publicly accessible pre-market safety assessment, as was recently advocated by a committee of the Codex Alimentarius. Europeans recognize the scientific uncertainties, and require their governments to undertake such open tests — hence the paucity of their approvals.

Dan Glickman railed against the EU’s apprehensions, saying that “we will not be pushed into allowing political science to govern these concerns.” One former US Ambassador to the EU chided Europeans to “separate science-based risk assessment and regulations from the political process.” And in the fall of 1999, three top officials of the US Commerce Department told Europeans to stop their “irrational and collective fear” and adopt a process “based on science and not on anxiety.” Yet it is the US government that has hypocritically elevated politics and economics above a reasoned scientific assessment of genetically modified foods.

Fueled by regulatory screwups, most prominently the mixture of Starlink corn — unapproved for human consumption — with the nation’s food supply, public concern about the applications of new biotechnologies has grown in the United States. Yet these sentiments — for example, according to bioindustry giant Novartis, up to 92% of US consumers want GE foods to be labeled — have had little effect on US policy. Dick Morris, former policy director in the Clinton White House, explains it bluntly: government officials ignore such majorities to pursue the goals of elite minorities, “just as they ignore the 72% who want to increase taxes on the wealthy, and the 77% who feel that corporations have too much power, and the 64% who want guaranteed health care for all.”

US-EU Societal Differences 

The underlying dynamics for these trans-Atlantic differences can be identified. Unlike in Europe, a very large proportion of US consumers are ignorant about the extent to which genetic engineering is affecting the foods they already eat. In the United States, there has been active corporate/governmental collusion, with the media cooperating to pacify the development and expression of any such concerns. In addition, US political culture provides a limited range of possibilities for such concerns to be expressed and debated.

While North Atlantic culture is highly homogeneous when contrasted with other portions of the globe, there are still considerable differences between Europe and the United States. However, the explanations for their biotech policy differences are not those offered by official industry and government apologists attempting to justify the United States’ failure to provide oversight. Five areas provide significant explanatory factors: existing political mechanisms, the role of industry in the political economy, the role of the media, geography, and history and culture.

Politics. In Europe, the governmental system is parliamentary. Most electoral systems are based on proportional representation; like-minded groups, such as the environmentalists who formed the Green parties, are represented in the legislative bodies as long as they attract a sufficient number of votes to cross a relatively low threshold (normally about five percent). From this position, they have been able to insert genetic engineering concerns into public discourse. However, due to the United States’ “winner take all” system, even near parities of 49% (and their issues) can be ignored by legislative representatives.

While most European officials are career bureaucrats, the US government commonly features, to a striking degree, industry personnel temporarily occupying government positions. The reverse is also true. Monsanto, which makes large donations to both the Democratic and Republican parties and to congressional legislators on food-safety committees, became a virtual retirement home for members of the Clinton Administration. Trade and environmental protection administrators and other Clinton appointees left to take up lucrative positions on Monsanto’s board, while Monsanto and other biotech executives pass through the same revolving door to take up positions in the administration and its regulatory bodies. In the Bush administration, the corporate-political revolving door is even more porous.

The range of opinions reflected in US media is also limited, and coverage of biotech issues has been sporadic and generally uncritical. As Max Frankel of the New York Timeseditorial board put it, “a corporate plutocracy dominates political speech in America.” Ironically, the Times’ coverage of GE agriculture has been particularly one-sided in favor 
of industry.

The choice and coverage of topics in the media appears strongly dependent upon two factors: corporate ownership patterns and interlocking boards of directors, and sources of advertising revenues. Furthermore, the companies controlling US media have steadily consolidated during the last decades — and the FCC, under the right-wing Michael Powell, is pushing the trend even further. In Europe it is nearly impossible to have such a concentration of media power in the hands of a few companies.

Cultural and Historical Factors. Compared to agribusiness in the US, farmland in Europe is much more integrated into citizens’ daily lives. Government planning provides sharp urban boundaries where farms exist, and commuters often pass livestock daily, rather than move through endless suburban sprawl. Europeans have more contact with farming, in part because many of them actually live in smaller communities and more of their relatives still live in rural areas. There is heightened awareness in Europe of the way food is produced; it is not visible only as output, wrapped in plastic on supermarket shelves. Europe’s farms are also significantly smaller than their overseas counterparts; rare are the vast industrial operations that now characterize US farming.

Every American traveler to Europe is aware of the fact that food occupies a place of high importance in the European lifestyle, far beyond what is common in this country. Major European cities are still full of small markets and specialty food shops. In contrast to the homogenization fostered by US multinationals, Europeans prize the diversity of local foods; Churchill once referred to France as a “nation of 350 cheeses.” For many foodstuffs, national laws are in place to intricately regulate the wording on their labels — Appenzeller cheese is only from one place in the world, as is Chateau Neuf-du-Pape wine.

In recent decades, Europe has experienced a series of food catastrophes — such as Mad Cow disease — from the use of modern food technologies, a fact which undoubtedly plays some role in shaping its attitudes. This European caution is often chided as childish anxiety by US critics, rather than seen as a mature willingness to learn from experience. The modification of agricultural products in foods to create “super organisms” also evokes for Europeans the memory of the Nazi plan to create a “super race” by genetic selection. 

Despite the spin put on it by US officials, “it’s wrong to view consumer resistance as just anti-science hysteria.” So says Gillian K. Hadfield, a professor of law at the University of Toronto. “Many people make food choices based on ethical considerations, deciding not to eat veal, or mass-produced chickens or non-organic produce. If biotechnology raises ethical and environmental concerns for them, it is not irrational for them to act on these.” The fundamental ideology in Europe is not “timidity” but rather the Precautionary Principle. Europeans prefer to step back in the face of uncertainty, acting prudently rather than recklessly. 

The US once abided by this approach in public policy, but has increasingly abandoned it under pressure from powerful corporations seeking short-term profits. 


After contentious negotiations, the Cartagena Biosafety Protocol is due to come into effect this year. It embodies a precautionary procedure regarding the trans-border movements of engineered organisms — such as GM food shipments — insisted upon by the EU and most developing countries, which harbor most of the world’s biodiversity. The recent fiasco in Mexico, where ancient corn types were contaminated with engineered genes, apparently via cross-pollination from imported US grains, shows one of the dangers posed by GM to the world’s gene pool. 

It may be unlikely for President Bush to take the EU to the WTO on these matters, since even if it were to win the US would not get Europe to change its practices. The EU would rather suffer economic penalties, as it has during its continuing refusal of hormone-laden US beef, than capitulate. However, the Bush administration is nothing if not stubborn, and a victory would enable the US to terrorize other less wealthy countries — something it did successfully when Croatia and Thailand tried to label genetically modified foods. This is probably the main motivation behind the United States’ aggressive language and posturing. Europe only represents ten percent of US agricultural exports — the real prize may well be other ninety percent, especially Asia. 

In democratic societies, citizens ought to have the right to protect themselves from having risks thrust upon them for the economic benefits of others. “Look before you leap” — requiring adequate risk assessments of genetically altered foods, assigning proponents of these technologies the burden of proving their safety, and requiring labeling so that citizens can make informed choices — these are reasonable public policies on both sides of the ocean. Unfortunately, until US popular activism on these issues approaches European levels, we may not be able to enjoy these basic consumer benefits.


Philip L. Bereano, JD, is Professor of Engineering (technology and public policy) at the University of Washington. He is the former Director of the University’s Program in Social Management of Technology, a founding member of the Washington Biotechnology Action Council, and serves on the national board of the American Civil Liberties Union.

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