September 23, 2026
For twenty-five years, the Cartagena Protocol on Biosafety has been the main international instrument ensuring that living modified organisms (LMOs) crossing borders are identified, documented and safely managed. Today, that framework faces a quiet but consequential test: how should it treat plants created through New Genomic Techniques (NGTs)?
The Protocol’s own Compliance Committee has already flagged concerns about diverging interpretations of what counts as an LMO, and about the growing gap between national approaches to new techniques of genetic modification like genome editing. At COP-MOP 11, held in Cali in 2024, this concern reached the negotiating floor. The European Union backed further scrutiny of the issue, while Panama, Brazil, Uruguay, Paraguay and Ecuador argued it went beyond the Compliance Committee’s mandate. New Zealand and Peru, while comfortable with the LMO definition itself, questioned how “modern biotechnology” should be understood in the context of gene editing. The result was a compromise. Under Decision CP-11/1, the Executive Secretary has been tasked with compiling the information submitted by Parties on their national measures, regulations and guidelines concerning new developments in modern biotechnology for consideration at COP-MOP 12.
The EU was an historical weight in this space. It took part in the negotiations from the mid-1990s, signed the Protocol in 2000, and later built one of the world’s most influential GMO regulatory systems, one built explicitly on risk assessment, traceability and the precautionary principle. That system helped shape how many countries think about biosafety governance today.
It is precisely this legacy that makes the EU’s new approach to NGTs so significant. Under its proposed framework, plants obtained through certain NGTs, so-called “Category 1”, would be treated as equivalent to conventionally bred plants, exempt from GMO-specific identification and documentation requirements. For a jurisdiction that helped define what rigorous biosafety oversight looks like, stepping away from identification requirements sends a powerful signal, that other Parties may follow.
The risk is systemic, not hypothetical. The Cartagena Protocol only works if Parties can reliably tell which organisms fall within its scope when they cross borders. If a major exporting jurisdiction stops documenting a whole category of genetically modified organisms, importing countries, often those with fewer laboratories and less technical capacity, may lose the information they need to apply their own biosafety obligations. Seed systems, gene banks, distributors, farmers’ ability to know what they are planting, and consumers right to know what they are eating could all be affected.
IPC believes this is exactly the kind of question multilateral biosafety governance was built to answer: consumers, farmers, Indigenous Peoples, their seed systems and biodiversity have the most to lose if it goes unanswered. The IPC position paper examines in detail what an exclusion of plants that are genetically modified with NGTs from the scope of Cartagena Protocol could mean for third countries, and calls for a clear, consistent international approach to identifying the organisms that cross our borders.
Download the IPC position paper to learn more