Accompanying letter with research report ‘The possible role of honey bees in the spread of pollen from field trials’

The judgment of the European Court of Justice about the presence of pollen from genetically modified (GM) plants in honey has placed this topic high on the European political agenda. The Court concluded that pollen should be considered a component of honey. This means that GM pollen in honey falls under the labelling requirement. The judgment has important consequences for the import of honey from countries where GM crops that are not admitted to Europe are cultivated and for field trials in the European Union when these lead to the presence of GM pollen in honey. The use of GM pollen as a component in food is also not included in some older European permits and therefore the trading of honey containing such GM pollen is not permitted at the moment.

In view of the recent developments surrounding bees and GM crops COGEM had a study conducted to look at the various aspects involved. The study collected background information which is relevant to this topic, such as the distances covered by bees while foraging, the transport of pollen by bees, the amount of pollen found in honey and the origin of the pollen found in Dutch honey samples. The study was carried out by Ameco Environmental Services (S.J. van Keulen MSc and drs. H.A.W. Kleinjans) and bees@wur (Dr. T. Blacquière, Dr. ir. C.J.H. Booij et al.) and resulted in the research report ‘The possible role of honey bees in the spread of pollen from field trials’.

In the letter accompanying the research report, COGEM reaches the following conclusions:

• Honey contains extremely small quantities of pollen, i.e. around 43 to 670 µg per gram honey. As a result the possible exposure to transgenic protein through the consumption of honey is exceptionally small and the presence of GM pollen in general will not constitute a food safety risk.
• Any risks due to the presence of GM pollen in honey will be sufficiently covered by the risk assessment carried out in the context of an application for market admittance.
• In permit applications for field trials the risks of incidental consumption of the GM crop are evaluated. Any risks due to the consumption of GM pollen in honey will thus be adequately assessed.
• The presence of pollen in honey is not included in some older permits for GM crops, as a result of which trading honey with such GM pollen is not permitted. The trading of GM pollen from field trials is also not permitted. Because in older permits the use of these GM crops for other applications in Europe is included and the food safety of these GM crops has been assessed for these applications, this creates a legal problem in this case which could further lead to trade issues.
• Because the consumer is exposed to only a minute amount of transgenic protein through honey and the assessment of any risks due to the presence of GM pollen forms part of the permit procedure(s), the presence of GM pollen in honey is primarily a problem of co-existence or freedom of choice.

COGEM would like to convey the importance of the rapid development of European policy in the area of GM pollen and honey, in which amendment of the Directive relating to honey (2001/110/EC) or amendment of the Regulation on GM food and feed (1829/2003/EC) may offer a possible solution to the issues outlined in this letter.