Two states separated by the same food culture

Commentary: President Bush is going to take issue with the EU over its GM food ban when he visits Europe shortly for the G8 …

Commentary: President Bush is going to take issue with the EU over its GM food ban when he visits Europe shortly for the G8 summit. Donal Nugent in Washington examines the different cultures behind the dispute

You don't have to be Oscar Wilde to figure out that the EU and the US are two states separated by the same food culture. We dine at the same table but with an increasing look of incomprehension at what the other has ordered.

The US government's formal complaint to the WTO about EU heel-dragging in the licensing of genetically modified (GM) foods has highlighted the gulf between the two. While many Europeans will be bristling with indignation, in the US, most consumers will scratch their head wondering what the fuss is about.

The supermarket is the forum of American sensibility. In the aisles, products jostle with each other in sizes, flavours and claims that make European food stores look like the work of misanthropic minimalists.

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Amid the hard sell, though, one label you'll never see, even in the small print, is "contains genetically modified organisms". Not because they aren't there. The US Food and Drug Administration (FDA) takes the view that because GM crops are "not materially different" from conventional varieties there is no need for their origin to be identified (if testing should prove them different, then this must be clearly stated).

For almost a decade genetically modified foods such as corn, soy, canola (rapeseed oil) and tomatoes have been part of the American diet. Some 70 per cent of products on US supermarket shelves are estimated to contain GM products. What would bring down governments in Europe is greeted with supreme indifference by most Americans.

Of course, Europeans, even the most GM-phobic, visit the US in their millions every year. It is safe to assume that bombardment with genetically modified organisms is a low concern as they queue for Disney rides and Washington museums.

They also eat and drink European cheeses and beers which have been produced with genetically modified enzymes. These enzymes, because they are used in food processing, rather than being actual ingredients, do not require a GM label. European regulators can justify this with arguments which could get them headhunted to the Vatican's theology department, but Americans roll their eyes at what they see as patent subterfuge.

American consumers' confidence in the FDA is a relationship that Brussels would love to replicate, but it is the product of a different mindset and a different history.

Since the BSE crisis, safe food has been bolted into the top priority slot in Europe's food industry. The loss of confidence by EU consumers in scientific and regulatory bodies that accompanied the crisis has clearly exacerbated the problem. Europe, Americans would argue, has overcompensated with the precautionary principle, a desire to guarantee to the nth degree the safety of everything we eat.

Since everything we do carries risks, the Americans argue that the search for safety should be about demonstrating "a reasonable certainty of no harm" in the use of, say, a pesticide, or a plant genetically modified to control pests, rather than in the search for the Holy Grail of absolute guarantees.

Europeans would shudder but American consumers clearly have confidence in this approach. Recent history has shown them to be no less susceptible to food scares than any one else, but their ability to navigate them without the sackcloth and ashes Europe has endured can be attributed to confidence in their regulatory regime. Americans don't expect to live in a perfect world but they do expect agencies like the FDA or their Environmental Protection Agency to intervene immediately and authoritatively on their behalf.

The balancing of powers that is a hallmark of the American administrative approach is in marked contrast to the European tradition of centralised bureaucracy. Ireland, in fact, has led the way in emulating the US approach in the food industry, with the establishment of independent bodies such as the Food Safety Authority of Ireland.

For America, EU acceptance of GM foods is a breach to be bridged. For Europe, it is salt in a very sensitive wound. The EU Commissioner for Health and Food Safety, David Byrne, has argued that Europe is already regulating for the licensing of GM crops and that a complaint is therefore unwarranted. America, however, cites growing frustration at what it sees as lack of real movement on the issue.

The story of a new GM wheat strain hit the headlines in the US recently. Farmers were reluctant to grow roundup resistant variety produced by Monsanto, the GM seed producer, because of the adamant refusal of European buyers to handle it. The US has decided it is time to take a stand and Europe is unlikely to concede a centimetre.

For two continents that trade their cultures so keenly, the standoff on food has become an unlikely but increasingly heart-felt battle about cultural autonomy and perhaps even supremacy. In the short term, certainly, no easy resolution looks likely.

What began as a scientific debate is one increasingly to do about attitude. Attitude makes for good copy but is rather difficult to legislate for. The WTO looks set to become a Jerry Springer-style set where, rather than shaking them in agreement, America and Europe will find themselves encouraged to talk to each other's hands.

Donal Nugent is a former editor of Irish Food and science journalism fellow with the Council for Agricultural Science and Technology