The NCC and Cotton Council International (CCI) have prepared a statement for use by Turkish importers that should allow U.S. cotton to avoid genetically modified organisms (GMOs) analysis in gaining custom clearances.
A memo from the General Directorate of Protection and Control within Turkey’s Ministry of Agriculture and Rural Affairs instructed ports that GMO analysis should not be conducted on imported cotton fiber, provided that importers produce a letter of undertaking which declares that the imported cotton fiber does not contain GMOs. This approach was taken by the Directorate, because protein and DNA cannot be extracted from fiber unless there is sufficient plant material or whole seed or seed parts present in the sample.
Turkey’s law on biosafety, dated March 26, 2010 and its related regulations, require GMO analysis on “GMOs” and “GMOs and products thereof.” The law and regulations define GMOs as “living beings…” and that products thereof “partly or completely consist of GMOs.” Cotton fiber would fall under the definition of “Products obtained from GMOs” as the fiber is partly or completely obtained from GMOs but does not contain or consist of GMOs.
Based on these definitions, a statement satisfying the Directorate’s instructions to importers has been provided to Turkish importers of US cotton fiber. Additionally, as a longer term approach, the NCC is developing a technical information package to use in applying for a cotton fiber exemption from the Law on Biosafety and its associated regulations requiring GMO analysis.