COGEM issues both unsolicited advice and advice at the request of the minister. Advice issued in response to a ministerial request is often linked to specific cases or notifications.
Three different notification categories are recognised: contained use, deliberate release into the environment, and placing on the market of a GMO.
‘Contained use’ are activities involving the use of GMOs in laboratories, production facilities, greenhouses or animal houses. COGEM is on a case by case requested by the GMO office or the ministry to give advice on new or major revisions or existing permits.
‘Deliberate release’ means any intentional introduction of a GMO into the environment for which no specific containment measures are used to limit the contact of the GMO with the environment. These are mainly field experiments with GMOs, like field experiments with genetically modified plants or clinical gene therapy experiments. In all cases of notifications for deliberate release of GMOs COGEM is requested to advise on the environmental risks by the ministry.
‘Placing on the market’ (market authorisation) means making GMOs available to third parties, whether in return for payment or free of charge. Placing on the market of GMOs is regulated in a centralised European procedure. However, the member states are given the opportunity to carry out their own risk analysis. In the case of notifications for cultivation of GM plants it is even mandatory that the initial environmental risk analysis is carried out by a member state. In the Netherlands COGEM is requested by the Ministry of Infrastructure and Water Management to advise on every market authorisation, both for import and cultivation of GM plants.
The advice of COGEM is not binding and the minister can decide to deviate from the content of the advice.