Dear FSC Member,

I am writing to ask you to send a brief comment to contribute to a short but important Forest Stewardship Council consultation. The consultation question is straight-forward but has important implications for the FSC policy that bans the use of genetically modified trees. 

Please participate in the “Consultation on the interpretation of genetically modified organism (GMO) definition (INT-STD-01-001_19).” Comments are due by Sepetember 28, 2025.

We are asking you to write to support the FSC’s response to the question: “Are trees whose genome has been edited using CRISPR-based technologies falling under the FSC definition of ‘Genetically Modified Organism”?” FSC has correctly answered “yes” to this question, confirming that the definition of GMO includes CRISPR-based gene editing technologies. The FSC’s full answer is: “Yes, the definition of Genetically Modified Organism covers also organisms in which the genetic material has been altered using modern, CRISPR-based gene editing technologies. 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, hence any genetic engineering technology falls within the scope of the GMO definition.”

FSC’s answer is correct, and it is important to affirm this answer because some pulp companies and biotechnology researchers are lobbying to change the definition of genetic modification (genetic engineering) so that they can get approval to release gene-edited trees as non-GMO.
There is a global strategy by the biotechnology industry to categorize the new genetic engineering techniques of gene editing, also called genome editing, as “non-GMO” in order to secure less government regulation and to gain public acceptance. For example, Sofia Valenzuela, a leading GM tree researcher in Chile has stated the importance of using gene editing to advance the commercialization of GM trees: “It has been a long battle to have GM trees commercially, after almost three decades we haven‘t succeeded in authorizing their use. I see that the genome editing opens a new door for us to have these trees in commercial plantations.” https://allianceforscience.org/blog/2019/09/interview-global-potential-forest-biotechnology/
However, just as FSC has stated, gene editing is genetic modification. Please see our attached introduction that describes how gene editing is genetic modification.

As you know, the FSC prohibits the use of genetically modified trees from FSC-certified areas and will not allow association with organizations that are directly or indirectly involved in the commercial deployment of GM trees. This is an important policy that protects forest ecosystems from the unknown risks posed by GMOs, including those produced through gene editing.

The risks associated with genetically modifying trees extend to the new techniques of gene editing. The processes of genetic modification, including those of gene editing, often result in unanticipated changes and unpredictable consequences. The release of GM trees would pose serious threats to forests and other ecosystems, as well as to many local communities and Indigenous peoples. The environmental impacts could be irreversible. GM contamination is living pollution that can self-replicate and, once GM contamination in forests begins, it may not be possible to stop its spread.

We reiterate that the FSC’s clear position against the use of GM trees is is vital for the protection of forest ecosystems. We reject biotechnology industry attempts to genetically engineer trees and call for a halt in this unnecessary and dangerous research.

We are pleased to answer questions or discuss at any time.

Thank you for considering sending your comment to FSC in this consultation. Best regards, Lucy Sharratt

The Canadian Biotechnology Action Network (CBAN) is home to diverse, extensive experience monitoring and evaluating the environmental and social justice issues raised by the use of genetic engineering. CBAN brings together 15 groups from across Canada, to research, monitor and raise awareness about the impacts of genetic engineering on food sovereignty and environmental justice. CBAN members include farmer associations, environmental and social justice organizations, and regional coalitions of grassroots groups, and works in partnership with many allied groups internationally. CBAN is a project on the shared platform of MakeWay, a registered charity in Canada. www.cban.ca/trees