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Research project

Comparing international approaches to food safety regulation of GM and Novel Foods

The study explored several aspects of food safety regulation, including definitions, underlying legislation, authorisation processes and production standards.

Last updated: 10 August 2021


The global area of genetically modified (GM) crop production has considerably increased over the past two decades, with GM crops now cultivated in about 28 countries, accounting for over 10% of the world’s arable land.

A 'novel food' is any food or substance that has not been used for human consumption to a significant degree within the EU before 15 May 1997. Since then, there has been over 90 novel foods authorisations approved for use by the EU.

Novel foods and genetically modified organisms (GMOs) are subject to a large variation in regulatory approaches around the world, for which many countries have specifically developed their own regulatory frameworks to control the placement of such products on their markets.

Research approach

A qualitative assessment was carried out on how the regulation of novel foods and GMOs in selected non-EU countries differs from those current requirements in the United Kingdom. Countries of interest for novel foods that were selected for review included Australia, Canada, Japan, and the United States; to focus on their approach to 'novelty' determination, authorisation processes, differences in terminology, safety standards, and evidence-based requirements. In the regulatory approaches for GMOs, the countries selected were Argentina, Australia, Brazil, Canada, and the United States, as best representing key differences.

Systems were also identified which regulate the international trade of such commodities, by considering relevant treaties that operate at a global level., These systems included the General Agreement on Tariffs and Trade (GATT), the World Trade Organisation (WTO) Agreement on the Application of Sanitary and Phytosanitary Measures (SPS Agreement), and the WTO Agreement on Technical Barriers to Trade (TBT Agreement). Elements of free trade agreements between the signatories of two or more jurisdictions were also considered in this report.

Research report