Is the caretaker government about to compromise Pakistan’s agri exports?

 After more than 18 months of consistent back-and-forth involving permissions and all kinds of bureaucratic red-taping the caretaker government is set to allow the import of Genetically Modified Organisms (GMO) oilseeds. 

This means trouble. 

As a direct result of this decision Pakistan’s food exporters might find it difficult to export their commodities to many different markets around the globe. So what exactly is the big deal? 

The oilseed saga

It all started with a technicality — but a technicality that was being ignored for a few years. On October 20, last year, two shipments were stopped at Port Qasim in Karachi. The shipments contained GMO oilseeds worth some $100 million on board. And despite the very vocal protestations of the importers that had paid for the consignments, they stayed stuck at the port pending a single certification from the ministry of climate change.

In the months that followed, more vessels joined the two stuck at Karachi and the value of the oilseeds piling up at the port grew over $300 million. The most important thing to understand is one term — oilseeds.  When most people hear the term oilseed, they think it is a seed that is to be sown in the ground and harvested for the production of edible oil. Oilseeds is actually a term for the seeds or ‘fruit’ that certain crops produce that are then pressed to get edible oil. So, for example, olives are an oilseed and so are the fruits produced by palm plants and soybeans since all of these are pressed and used to extract oil. Another example of an oilseed is cotton, the seeds from which are pressed and the oil extracted from them.

Pakistan is heavily dependent on these oilseeds for its edible oil. According to a report of the central bank, Pakistan’s palm and soybean-related imports stood at US$ 4 billion in FY21, rising by 47% year-on-year, compared to compound average growth of 12.3% in the last 20 years. And in addition to edible oil, these seeds fulfill another crucial purpose: providing feed for livestock including for chickens.

Why is everyone afraid of GMOs? 

Now, it is worth pointing out here why the shipments of GMO oilseeds were stopped. Pakistan is party to the Cartagena Protocol on Biosafety to the Convention on Biological Diversity, signed in 2001 and rectified in 2009. The Cartagena Protocol is an international treaty governing the movements of living modified organisms (LMOs) resulting from modern biotechnology from one country to another.

Its purpose is simple. One of the observations scientists had after genetically modifying different crops was that when certain modified plant varieties are introduced to new environments, the results can be disastrous for the local ecology. As a result, to make sure there is no unchecked introduction of GMOs to new environments, the Cartagena Protocol monitors this. And as part of the Pakistan Biosafety Rules of 2005, the ministry of climate change needs to give approval to any new GMO shipments coming into the country.

For the past few years solvent extractors had been importing GMO soybean oilseeds mostly from the United States. However, they had been getting away with it since the climate change ministry had not been paying attention to the issue. In 2022 the ministry refused to grant the required approval triggering the crisis.

What you eat is what you are

That is because beyond the Cartagena protocol people are also generally afraid of the concept of GMOs. Exactly a year ago in December 2022, the then food minister Tariq Bashir Cheema declared people should stop eating chicken as it was harmful to health. His reasoning? The poultry in the country was being fed with seeds that had been genetically modified. As a result, the meat from these birds was toxic. “The GMO soybeans are toxic, and any product coming from them is dangerous to health. They can cause serious diseases like cancer,” the minister thundered. “I don’t eat chicken anymore. In fact, I don’t eat meat at all. I only eat vegetables,” he explained. It’s funny when you think about it. Tall, domineering, and a seasoned political operator — one would think there isn’t much Cheema is afraid of. Particularly, not some bird. Yet when Cheema and others like him look at these chickens, they see a threat to the health of an entire nation.

So what inspires a government to tell its people what to eat and what not to eat? The answer is fear. The fear that there are certain foods that will affect the health and productivity of a nation. The fear of sickness and the unknown. At the core of a very basic evolutionary fear — that of poison.

In some ways, it makes sense. There is a lot behind the maxim of “you are what you eat.” Food is the most basic fuel necessary for human survival. And more even than the air that we breathe, food has a direct relationship with culture, religion, and identity. What we consume, what we put in our bodies, has a singular, laser-focused relation to who we are as people and how we define ourselves. In its rawest form, food serves as the border between nature and culture, between human and non-human.

And that is why there is so much anxiety about what we eat and the effects it has on us. Claims that crops that are Genetically Modified Organisms (GMOs) are a danger to human health have been rife globally for decades now. Time and again, scientific evidence has failed to prove that GMOs are cancerous or hazardous to health in any way. They have, however, played a vital role in helping agricultural productivity keep up with the rising global population.

Not bad for the health but possibly bad for exports? 

Let’s get a few things straight here. The GMOs that are being talked about here are not for sowing. The oilseeds being imported are simply pressed and their oil extracted. The mulch that is left behind is used to create ‘cakes’ that are then fed to poultry. So the Cartagena Protocol really doesn’t have any involvement here.For more details about GMOs and what they mean you can find more details in older pieces by Profit. 

READ MORE: Why is the government chickening away from chicken? 

What matters here is not so much whether GMOs are good or bad but what this means for Pakistan’s exports. 

You see the change being proposed by the caretaker government involves permitting the import of Genetically Modified Organism (GMO) – Living Modified Organisms (LMO) oil seeds for consumption and processing. This swift policy shift formally includes Pakistan in the GMO countries but lacks proper consultation and approval from the Technical Advisory Committee and National Biosafety Committee under the Ministry of Climate Change, as mandated by the Pakistan Biosafety Rules.

This decision has raised concerns as it may undermine Pakistan’s export of non-GMO commodities to countries that do not accept GMO products. Moreover, it could potentially impact Pakistan’s biodiversity, environment, and the health of both humans and animals. Because of all the suspicion surrounding GMOs, they are considered to have potential threats to agricultural products of a non-GMO territory. That is why due tests, inspection, and certification is needed to avoid such threats. 

Allowing these imports without implementing adequate biosafety and biosecurity measures is seen as risky. In this particular case the government seems to be allowing the import without particularly looking at the biosafety rules. This, of course, is because oil pressers and the poultry industry have been running from pillar to post complaining about their consignments being stopped. As we’ve mentioned, they have a point too. The GMO oilseeds are not to be sown in Pakistan and cannot have an effect on other crops in the country and hence shouldn’t affect our exports or status as a non-GMO country. In fact, Pakistan has been using GMO seeds for cotton since 2005 but since there is no cross-contamination with food it does not have any serious problems as a result of biodiversity. On top of this, as we’ve mentioned before, GMO seeds are also used to make cooking oil and feed livestock such as chicken so the population of the country already eats plenty of GMO products. 

The only problem here is that until last year even a government with the backing of parliament had simply allowed the stopped consignments to be released over a course of months. In this case a caretaker government is now taking a policy decision that may well go far beyond its mandate. 

The right way to go about it

The situation demands thorough discussions involving the general public, researchers, universities, provincial governments, infrastructure, manpower, and regulations. Neglecting suitable biosafety and biosecurity measures could not only affect Pakistan’s agricultural exports to over 70 non-GMO countries but also lead to contamination of Pakistan’s biodiversity, environment, and public health.

It’s particularly surprising that the matter of a policy shift has bypassed the Technical Advisory Committee (TAC) and National Biosafety Committee (NBC) and has been forwarded directly to the Cabinet Committee for Disposal of Legislative Cases (CCLC). The Ministry of National Food Security and Research, which houses the relevant technical bodies encompassing representation from all relevant spheres, usually addresses discussions, formulates suggestions for biosafety measures, proposes amendments to the Pakistan Biosafety Rules 2005, and oversees the regulation of GMO/LMO import and release in Pakistan.

Strangely, despite past reluctance from relevant ministries such as the Ministry of National Food Security and Research (NFS&R), Ministry of Climate Change, and the Federal Cabinet to authorize GMO/LMO deliberate release without adhering to proper procedures and biosafety measures, there appears to be a haste in granting approval for GMO/LMO import in Pakistan. Official sources confirmed that this is occurring without consultations with the TAC, NBC, or the general public, with the subsequent approval expected from CCLC and the cabinet. Notably, the beneficiaries—importers—recently published an elaborate advertisement in a leading newspaper, expressing gratitude to the concerned ministers for their support in approving the draft policy aimed at facilitating GMO Soybean imports.

TAC and NBC are the main forum to deal with GMO. It recommends what needs to be done with imported GMO products. These bodies have representatives of all concerned officials, experts etc. The government, mainly the ministry, is bypassing such forums and directly trying to get the nod from the CCLC and cabinet. 

A case of successfully lobbying? 

Meanwhile, other stakeholders in the name of “Sectoral Council for Meat, Poultry, Fish and Seafood, Milk and Dairy Products” has also published on December 4, 2023 thanking prime minister and ministers of food security, climate change and commerce for their role in allowing import of GM & LM Soybean in Pakistan exempting Biosafety and Biosecurity Measures. Interestingly, the Secretary NFS&R Captain (r) Muhammad Mahmood confirmed that the matter is now with CCLC and the importers were celebrating it in advance.

Insiders suggest that influential importers might be using tactics to influence the process. However, it’s crucial for Pakistan to approach this matter carefully, seeking input from the Technical Advisory Committee (TAC) and National Biosafety Committee (NBC). This consultation is essential as the decision could potentially harm the general public’s health, biodiversity, local agriculture, environment, and natural resources. It might also affect Pakistan’s limited exports of agricultural commodities to countries that only accept non-GMO products. 

Pakistan became a party to the Cartagena Protocol on Biosafety (CPB) to the Convention on Biological Diversity (CBD) on May 31, 2009. This agreement mandates the regulation of GMOs/LMOs and their related activities. Therefore, a cautious and consultative approach in line with these international obligations is necessary.

Reliable sources informed that the pressure to ensure uninterrupted import of GMO Soybean into Pakistan stems from the substantial reliance on imports from the USA. Last year, concerns arose regarding GMO oilseed imports when relevant ministries, alerted by Customs, discovered that soybean imports were being misrepresented as non-GMO. This prompted intentions to test the commodities for GMO content and halted the release of imported GMO oilseeds until their compliance with non-GMO regulations was confirmed.

Interestingly the draft recommendations prepared by concerned ministry and shared with CCLC are as following:

1. Implement a traceability record requirement for imported grains to prevent leakage. This will be a part of the license terms for biosafety clearance.
2. Importers/technology developers must present cases for deregulating genetic events related to imported grains to the NBC. These cases should be accompanied by comprehensive certified risk assessment reports from the country of origin.
3. Accept certified risk assessment reports for imported grains meant for Food, Feed, and processing, issued by relevant agencies in the country of origin. Avoid the need for re-testing in Pakistan.
4. Have PARC conduct GM testing by screening soybean candidate lines submitted in the national uniform yield trial.
5. Note that large-scale devitalization of soybean grains isn’t currently feasible. This practice isn’t observed in major exporting (USA, Brazil) or importing nations.

Analysis of the above recommendations

When the recommendations were shared with experts and concerned stakeholders, it surprisingly came to know that the recommendations have neither been given by the Technical Advisory Committee (TAC) nor National Biosafety Committee (NBC) as mandatory in accordance with Rule 5 and 7 of Pakistan Biosafety Rules 2005 respectively. As the committee does not have authorization to give these recommendations, these recommendations neither have legal footing nor can be implemented as such without approval of the TAC and the NBC.

As per experts, the grains are transported from port to the processing facilities across the country in open trucks that even could not pass the road test. Seeds pilferage and seed dispersal through birds is common and routine during transportation when they are transported in such open trucks. Thus, deliberate release of GMO or LMO commodities arriving for consumption and processing in Pakistan cannot be hindered unless the grains or seeds are transported in closed containers from port to facilities, but the committee did not give any such recommendation either due to collusion or incompetency. Further, the traceability record maintained by the importer can not detect routine pilferage and seed dispersal by birds nor the importer will pay heed to it due to lack of regulation in this regard nor the regulator can check this kind of release because simply the importers shall submit the same quantity for biosafety clearance as they imported.

Second and third recommendation appear suitable when the Environmental Protection Agency (EPA) Pakistan has no proper infrastructure, workforce, and system of risk assessment but it does not mean that the caretaker government should allow import of GMO or LMO oil seeds in Pakistan without establishment of prerequisite infrastructure, manpower, regulations for suitable biosafety measures to protect and securing local agriculture, biodiversity, ecosystem, environment, natural resources and trade benefit. 

Screening of GMO lines falls within the order of EPA Pakistan and the Ministry of Climate Change and not PARC and MNFSR and hence, it cannot be made without referral by the TAC and the NBC empowered for it. MNFSR aggressiveness and reliance more on import of oil seeds on the pity ground to control dearness by reducing prices of poultry meal, though, there is no big change in prices due to this reason, it is rather due to devaluation of rupees than to make policy and implement fitting measures to increase cultivation and production of local oil seeds crops in coordination with agriculture departments of the provinces mainly with Punjab and Sindh main ground to cultivate oil seed crops to fulfill native requirements and reduce over one billion dollar import bill.  

As per the industry sources, there is quite misunderstanding and misperception on the part of so-called technical experts sitting on higher posts in PARC due to deficiency of expertise in quarantine matters and non-technical bureaucratic bully that devitalization of grains is done for GMO – LMO commodities in order to avoid its release in the environment.

Essentially, revitalization of grain or seed is a phytosanitary and biosecurity measure by which seeds or grains are made non-viable. 

It is not correct that the practice of devitalization of soybean grains does not exist currently in both major exporting nations (USA, Brazil) and importing nations. Devitalization of seeds and grains is done with heat treatment, irradiation, and fumigation and all these biosecurity measures exists in both USA and Brazil and they are signatory of International Plant Protection Convention (IPPC) and International Standards for Phytosanitary Measures (ISPMs) which provide devitalization as one of the biosecurity measures for import of agri. commodities to prevent insects, diseases, and weeds. Unfortunately, the top brass has made the fumigation of imported merchandise contentious in Pakistan just for personal gains and vested interests. The devitalization is implemented all over the world, particularly Australia, India, USA, Japan, Korea, China, Thailand, Russia, New Zealand, Mexico, Vietnam. 

Further, another argument is what if any biosecurity measure does not exist in the country of export to eradicate the associated pests with the commodities, it does not mean that Pakistan removes such conditions and allows freely aliens pests of exporting country to enter and spread in Pakistan and play havoc with local agriculture and biodiversity and elevate Pakistan’s import bill of pesticides to control such harmful organisms. Would the concerned ministries and departments like to place on record names of those just three countries including USA, Brazil who allowed Pakistani commodities to import in their by exempting their conditions because such measures were not available in Pakistan?

Post GMO saga:

Insiders report that these importers are urging the ministry to allow imports without adhering to the required registration and testing mechanism of the TAC and the NBC for genetically or living modified seeds, as mandated by existing laws.

At the behest of the importers, who are members of the All Pakistan Solvent Extractors Association (APSEA), the Ministry of National Food Security recently convened a meeting of stakeholders to explore the possibilities of importing GMO seeds, claiming they are used in various parts of the world. However, insiders have noted that the Ministry of Climate Change was not invited to this meeting, even though the GMO subject falls under the domain of the Environmental Protection Agency (EPA), an attached department of the Ministry of Climate Change. Major catalyst, insiders claim, behind this meeting is an ex-chairman PARC who is consultant of APSEA as well as bridge between the APSEA and MNFSR for the move of this haste policy and facilitation deal.

Nonetheless, the Food Ministry, in a statement released after the meeting, emphasized its commitment to upholding stringent regulations concerning seed imports. Caretaker Federal Minister Dr. Kausar Abdullah Malik reaffirmed that no seeds, including GMOs, would be permitted into the country without complying with prescribed Plant Quarantine Regulations and seed regulations. These regulations entail rigorous screening, adaptability trials, and registration processes to ensure the highest standards of safety and security for all imported seeds.

Reports reveal that APSEA and the Poultry Association have been actively lobbying the Ministry of National Food Security and Research, advocating for GMO soybean and canola seed imports within Pakistan since 2014. Their representatives, sources inform, tried to convince the participants of the meeting that GMO seeds were being used worldwide, with no harm attached to the modified seeds.

However, an official source claims that the importers’ efforts aim to bypass the required risk analysis for genetically modified and living modified organisms agricultural commodities, mandated by the National Food Safety Authority and the EPA of Pakistan, following Cartagena Protocol guidelines.

In pursuit of their goal, APSEA has reportedly enlisted the services of the former Chairman of the Pakistan Agriculture Research Council (PARC) as a consultant, with significant consultancy fees. This move intends to secure approval for GMO and LMO soybean and canola seed imports for consumption and processing.

Meanwhile, the US Department of Agriculture has written a letter through the US embassy in Islamabad stating that germination testing of Soybean for Export to Pakistan was not needed.

However, experts in food safety and agriculture express concerns about importing GMO seeds without proper risk analysis. They argue that this practice may introduce invasive weeds, insect pests, health hazards, and negatively impact biodiversity and the environment. Allegations have surfaced that importers have misdeclared these seeds as non-GMO to circumvent regulations.

Despite these challenges, APSEA persists in pushing for GMO soybean and canola seed imports in Pakistan. While their efforts have reportedly targeted the interim federal minister, the authority for such imports lies with the EPA under the Ministry of Climate Change. The Ministry of National Food Security and Research may recommend imports to the Ministry of Climate Change, provided they do not endanger domestic agriculture and natural resources.

When contacted for comments, Shehad Ali Khan, the founder of APSEA, did not respond to phone calls.