Submitted to the Forest Stewardship Council by Lucy Sharratt for the Canadian Biotechnology Action Network, September 2, 2025.

RE: “Consultation on the interpretation of genetically modified organism (GMO) definition (INT-STD-01-001_19).” https://consultation-platform.fsc.org/en/consultations

The Canadian Biotechnology Action Network (CBAN) is writing to support the answer given by FSC to the question: Are trees whose genome has been edited using CRISPR-based technologies falling under the FSC definition of ‘Genetically Modified Organism”? The answer provided is correct and sufficient. The processes of gene editing (genome editing) are genetic engineering and the use of these techniques result in genetically modified organisms (GMOs). Genetic engineering is a set of laboratory techniques that are used to change the characteristics of organisms, resulting in GMOs. Genetic engineering makes changes to an organism by directly intervening in its genetic make-up, without mating. For example, with the genome editing technique of CRISPR, scientists can intentionally cut strands of DNA within cells, to initiate changes.

The term “plant breeding” has been increasingly and incorrectly used in association with genome editing but, although modern plant breeding increasingly incorporates genetic tools and molecular techniques, it remains fundamentally different from approaches that employ gene editing. Genome-edited plants receive genetic changes through direct genomic modification, whereas classically bred plants receive genetic changes through human-facilitated selection and crossing. With the new techniques, humans can make even deeper and more complex changes to the genetic makeup of living organisms. For example, with genome editing, genetic sequences that are otherwise carefully protected by an organism against random mutations, can now be targeted and modified. Genome editing can also be used to change all the copies of one gene or many different DNA sequences at once.

Despite various terms and definitions emerging in national regulation around the world, there is no dispute in the scientific community that genome editing is genetic engineering. For example, Jennifer Doudna, one of the developers of the genome editing CRISPR/Cas-9 method, refers to CRISPR/Cas as “genome engineering.” (Joy Y. Wang and Jennifer A. Doudna, CRISPR technology: A decade of genome editing is only the beginning. Science 379, eadd8643. 2023.)

It is clear that there are efforts underway to exclude genome editing from a definition of genetic engineering for the purposes of securing weaker regulation and increased public acceptance of genome-edited GMOs. For example, there is an attempt to redefine genetic engineering, and the public controversy over it, as limited to those GMOs that have foreign DNA (are transgenic) i.e. GMOs that are not produced via genome editing. For example, Hoengenaert et al conclude their 2025 paper on experimental genome-edited poplar with reference to these goals: “Through whole-genome sequencing, we demonstrated the absence of foreign DNA in the genome of the gene-edited plant, facilitating the public acceptance and deregulation of such gene-edited trees.” (Hoengenaert, L., Anders, C., Van Doorsselaere, J., Vanholme, R. and Boerjan, W. (2025), Transgene-free genome editing in poplar. New Phytol, 247: 224-232.) This is a superficial and cynical public relations strategy that ignores the science and the critical need to pay attention to possible impacts from the processes of genetic engineering itself.

It is correct that the FSC’s response refers to both the processes of genomic technologies and the products – “the definition’s element of ‘altered in a way that does not occur naturally’ is understood to refer both to the resulting genome change as well as to the process to induce it” – because the processes of genetic engineering are the origin of risk questions.

The processes of genetic engineering often result in unanticipated changes, and this includes gene editing which is often incorrectly described as precise. Genome editing is often said to be more precise than earlier methods because the changes occur to target DNA sequences whereas earlier techniques led to the insertion of genes at random places. However, gene editing can create genetic errors in the GMO either due to the action of the DNA-cutters or due to the other processes involved. These effects can lead to unexpected and unpredictable outcomes, such as changes in protein composition and altered behaviour in and of the organism. With trees, the potential for unexpected genetic outcomes and environmental effects would increase and multiply over the long life of trees, because of the environmental extremes trees face, and because so many species interact with trees.

While genetic engineering gives humans unprecedented power to make changes directly to the genome of an organism, our knowledge and understanding of genetics and organisms is incomplete and still growing. There are many gaps in our knowledge. The interactions between the genes themselves, as well as the interactions between genes and the cell, the organism and the wider environment, are highly complex and still poorly understood. There are many changing factors that make the outcomes and consequences of genetic engineering, for the genetically modified organism as well as for the environment, unpredictable.

The risks associated with the use of genetic technologies extend to the new techniques of genome editing and their use raises the same environmental, social, economic and ethical concerns. Genetically engineered trees are a threat to a sustainable future. Genetic engineering provides a distraction from real solutions and its deployment would pose a concrete danger to forest ecosystems. Using genetically engineered trees in plantations, and even releasing GM trees into the wild, is still being proposed despite the serious risks and vast uncertainties. The release of genetically engineered trees would be a threat to forests and forest ecosystems, with impacts on many local communities and Indigenous peoples. The potential negative impacts could be profound and irreversible.

The FSC’s policy to prohibit the use of GM trees from FSC-certified areas and not allow association with organizations that are directly or indirectly involved in commercial deployment is vital for the protection of forest ecosystems. This clear position against the use of GM trees is also critical to the integrity of forest product certification and the global reputation of FSC. To strengthen the FSC position on this critical risk, we ask FSC to consider revoking the permission of GM tree field trials by FSC-certified operations in non-certified areas.

We refer you to our report Genome Editing in Food and Farming: Risks and Unexpected Consequences (2020)  https://cban.ca/wp-content/uploads/Genome-Editing-Report-2020.pdf (in French https://rcab.ca/genome-editing-in-food-and-farming-risks-and-unexpected-consequences) and our report The Global Status of Genetically Engineered Tree Development (2022) https://stopgetrees.org/wp-content/uploads/2022/09/The-Global-Status-of-Genetically-Engineered-Tree-Development-EN.pdf (in Spanish https://stopgetrees.org/wp-content/uploads/2022/09/The-Global-Status-of-Genetically-Engineered-Tree-Development-ES.pdf) as well as the resource Gene Editing Myths and Reality (2022) https://extranet.greens-efa.eu/public/media/file/9065/6768  from the Greens in the European Parliament (in French https://extranet.greens-efa.eu/public/media/file/9065/8601 ).

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• Click here to read our background document on genome editing
• Read more about GM trees at cban.ca/trees