Croatia is a net food importer and government policy is geared towards raising agricultural productivity and, to a lesser extent, limiting imports.
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GAIN Report Number: HR1111
Agricultural Biotechnology Annual
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Croatia is a net food importer and government policy is geared towards raising agricultural productivity
and, to a lesser extent, limiting imports. EU membership is also a priority for the Croatian government,
and new laws and agricultural policies increasingly mirror those of the EU. The Croatian public remains
very skeptical about agricultural biotechnology. There has also been a general demonization of U.S.
food products as "Frankenstein Foods." In Croatia, several pieces of legislation have been introduced to
regulate the importation and cultivation of biotech crops and foods.
Section I. Executive Summary:
Croatia is a net food importer. The primary goal of agricultural policy is to increase productivity, and to
a lesser extent, limiting imports. EU membership is also a priority for the Croatian government, and
new laws and agricultural policies increasingly mirror those of the EU.
The Croatian public remains very skeptical about agricultural biotechnology and consumers often
consider U.S. food products to be ?Frankenstein Foods.?
In 2004, the government randomly tested samples of foodstuffs and seed taken from the market for
biotech traces, which resulted in the withdrawal of some products due to improperly labeling of
products containing biotech. The Croatian Government then penalized the importers.
The government is considering several pieces of legislation to regulate the importation and cultivation
of biotech crops and foods. The laws regulating biotechnology include the Food Act and the Law on
Genetically Modified Organisms. Additional important legal documents on biotechnology include
Government Ordinances on GMO Levels in Products Under Which Products Placed on the Market Do
Not Have to be Labeled as Products Containing GMO passed on July 31, 2008 (Governmental Gazette
92/2008), March 18, 2009 (Governmental Gazette 36/2009) and March 11, 2010 (Governmental Gazette
33/2010). These list the trace amounts of biotech ingredients that can be contained in a product.
Section II. Plant Biotechnology Trade and Production:
a. Croatia does not commercially produce biotech crops or seeds.
b. Croatia is not developing any biotech crops.
c. In Croatia there are no approved biotech crops for food or feed, but there is a 0.9% threshold level
for biotech events in food and feed that are on the official list (Section III) of permitted GMO events
(the list is created from the list of biotech events previously tested and licensed in the EU and was
published in Croatia as Ordinance in 2008 with amendments in 2009 and 2010). If the biotech event is
on the list and is present in the product up to 0.9%, it does not need to be labeled for sale on the
Croatian market. However, if the biotech content is above 0.9%, the product must be labeled as GM.
The biotech threshold level drops to 0.0% for biotech products that are not on the list of permitted
events. The same applies to feed. Officially Croatia does not import biotech crops/products because
GM labeling is mandatory and currently there are no GM labeled products on the market.
d. Croatia is not a food aid recipient.
e. Croatia does not produce any biotech crops developed outside of the United States or any biotech
crops in general.
Section III. Plant Biotechnology Policy:
a. Agricultural biotechnology regulatory framework:
The Food Act governs the possible importation, licensing, and labeling of any foods/feed containing
biotech ingredients. Parliament approved the latest Food Act on April 25, 2007 and published in
Government Gazette number 46 on May 7, 2007. This law outlines many regulations that would enable
biotech products to enter the market and be labeled. Publication of many of those regulations was on
hold until recently when, due to the approaching Croatian EU accession, many regulations had/have to
be published. The three new government ordinances that regulate the labeling threshold for biotech
content (?GMO Levels in Products Under Which Products Placed on the Market Do Not Have to be
Labeled as Products Containing GMO?) passed on July 31, 2008, (Governmental Gazette 92/2008);
March 18, 2009 (Governmental Gazette 36/2009); and March 11, 2010 (Governmental Gazette
33/2010) (see section IIIbi for additional details). Penalties for companies violating the "novel food"
provisions of the Food Law concerning placing novel foods on the market and/or labeling them range
from Kn 100,000 to Kn 500,000($ 19,408 ? $ 97,037), with responsible individuals fined from Kn
5,000 to Kn 10,000 ($ 970 ? $ 1,941).
The Law on Genetically Modified Organisms (Law on GMOs) is an overarching law for
biotechnology. The Law on Genetically Modified Organisms (Governmental Gazette 70/2005,
137/2009) together with the Food Act and subsequent regulations regulate the importation,
transshipment, production, usage, and sale of products of agricultural biotechnology (all food, feed, and
seed). This Law established a testing and licensing regime that is very restrictive. The highest
penalties for breaching the provisions of this Law range from Kn 500,000 to Kn 1,000,000 ($ 97,037 ?
$ 194,076) for the responsible company and from Kn 20,000 to Kn 70,000 ($ 3,882 - $ 13,585) for the
responsible employee in the company.
i. Responsible Ministries and Their Roles:
Ministry of Science (MOS), Education and Sport: According to the Law on GMOs, the MOS is
responsible for the limited and contained use of GMOs.
Ministry of Health and Social Welfare (MOHSW): According to the Food Act, the MOWSW is
responsible for all the issues regarding food, foodstuff, and feed containing biotechnology content and
inspections. Additionally, the Law on GMOs proscribes that MOWSW is responsible for the usage and
inspection of the GMO products in cosmetics, pharmaceutical products, and products for human health
protection. According to the Law on GMOs, the MOHSW is the umbrella ministry and coordinating
body for all biotechnology issues.
Ministry of Culture (MOC) - Environment Protection Directorate: According to the Law on GMOs the
MOC is responsible for the intentional introduction of GMOs into the environment.
Ministry of Agriculture, Fishery (MOAF) and Rural Development: According to the Food Act, the
Ministry of Agriculture is the central body of the Government responsible for food/feed safety, quality,
and hygiene. This Ministry is also a contact point for the EU for related issues. The Ministry of
Agriculture and the Ministry of Health have joint responsibility concerning all issues regarding food,
foodstuff, and feed containing plant or animal biotechnology content and their inspections. According
to the Law on GMOs, the MOAF has responsibility for inspections of biotech feed; biotech
reproduction material in agriculture and veterinary medicine; and drugs in veterinary medicine and
pesticides. Furthermore, the MOAF is responsible for giving its consent for the intentional release of
biotech products into the environment.
Ministry of Regional Development, Forestry (MRDF) and Water Management: According to the Law
on GMOs, the MRDF has responsibility for inspections of biotech reproduction material in forestry.
State Inspectorate: According to the Law on GMOs, the State Inspectorate has responsibility for
inspecting GMO labeling.
ii. Role and Membership of Biosafety Committee (if any):
The Law on GMOs required the establishment of a Council for GMOs with the specific task of assisting
governmental bodies to apply the Law. The Council has 17 members appointed by the Government of
Croatia based on nominations from the pertinent Ministries. Council membership lasts for four years.
The Council?s work is independent and public. According to the Law, the Council?s tasks include:
tracking gene technology development and usage, tracking scientific breakthroughs and giving opinion
and incentives for usage of gene technology and GMOs, giving opinions on social, ethical, technical,
scientific, and other conditions of GMO use, advising responsible institutions on GMO and gene
technology issues, informing the public on GMO and gene technology development, and presenting
viewpoints and opinions.
The Law on GMOs also calls for establishing a Board for Limited Usage of GMOs with 11 members
composed of scientists from the fields of microbiology, genetics, medicine, biochemistry, molecular
biology, pharmacy, biotechnology, agriculture, forestry, veterinary medicine, nature and environmental
protection, and occupational protection. In addition, the Law on GMOs requires the establishment of a
board for the introduction of biotech products into the environment that consists of nine scientists from
the fields of: genetics, ecology, nature protection, environmental protection, agriculture, forestry,
veterinary medicine, biochemistry, molecular biology, microbiology, and medicine. The tasks of these
boards include: giving opinions on biotech usage in terms of legal procedures as outlined by the Law on
GMOs; giving opinions and proposals for preparing other legislation on GMO usage; and giving
opinions and proposals to responsible ministries on biotech usage issues and other expert work as
outlined by the GMO Law and related regulations. According to the law, these two boards should
report to the GMO Council once a year.
The old and new Food Act/s called for the establishment of the Croatian Food Agency, which began its
work in 2004. The Agency?s work consists of providing scientific and technical support to legislators
as well as providing scientific advice in all areas that have direct and indirect influence on food and
feed safety. Additionally, the Food Agency is required to work on many other issues concerned with
feed, food, and nutrition and provides scientific opinions to the Ministry of Health and Social Welfare
and the Ministry of Agriculture, Fishery, and Rural Development regarding the placement of GMO
food and/or feed on the market.
iii. Assessment of political factors that may influence regulatory decisions related to agricultural
Although EU membership is a priority for the Croatian government and the country?s new laws and
agricultural policies increasingly mirror those of the EU, biotech opponents in Croatia have been
emboldened by the perceived success of Austria and Slovenia in standing up to the European
Commission on biotech approvals. Thus, complying with EU regulations has little meaning as long as
Croatia positions itself within a regional group of ?healthy,? GMO-free countries.
Currently, Croatia clearly sees its future as a ?niche market for healthy food? (NOTE: In Croatia, the
word ?healthy? encompasses everything from conventional and organic to non-biotech products), and
biotech seed imports are not necessary for Croatia given a lack of agricultural demand for biotech
products to combat drought, pests, or soil problems. Government officials acknowledge the legal
obligation to open their agricultural market to foreign imports and openly acknowledge that Croatia is
positioning itself as a GMO-free, ?healthy? tourist destination. The Croatian public is generally very
opposed to biotech products.
iv. Distinctions between the regulatory treatment of approval for food, feed, processing, and
environmental release are the following:
There are similar long and complicated procedures to approve food and feed products, but the approval
process for environmental release is different. At the end of the regulatory procedure for food and feed,
biotech products must gain special permission to market the product. All agricultural seed varieties
(biotech and conventional), however, must first go through a variety registration process. After the
Croatian Seed and Seedlings Institute registers the variety, it is placed on the list of seed varieties that
can be marketed in Croatia. Biotech seeds, in additional to variety registration, require special
permission to be placed on the market, including permission for the intentional environmental release of
b. Biotechnology crops approved for:
i. Food, processing and feed:
Croatia has not approved any biotech crops for food or feed use in Croatia, but there is a 0.9% threshold
level for some biotech events in food and feed. Under a special ordinance from 2008 and its
amendments from 2009 and 2010 the threshold for biotech content in food depends upon whether or not
the biotech event is on the Ordinance?s list of permitted GMO events (the list is created from the list of
biotech events previously tested and licensed in the EU). If the biotech event is on the Ordinance?s list,
it does not need to be labeled for sale on the Croatian market--provided separate tests within Croatia
confirm that the product contains up to 0.9% biotech content (for products that consist of more than one
ingredient, the 0.9% threshold is permitted per product?s ingredient). However, if the biotech content is
above 0.9%, the product must be labeled. The biotech threshold level drops to 0.0% for biotech
products that are not on the Ordinance?s list. The same applies to feed.
List of GMOs allowed up to the 0.9% threshold level:
Num. Code Plant Producer Modification Possible Usage
1. Carnation carnation Florigene Ltd flower color
2. Carnation carnation Florigene Ltd flower color
C cultivating 3. arnation carnation Florigene Ltd long life
4. Carnation carnation Florigene Ltd flower color import and
5. 1507 corn Pioneer/Dow insect resistance
AgroScience and herbicide food and feed
6. 59122 corn Pioneer Hi- insect resistance
Bred/Mycogen and herbicide
7. 1507 X NK603 corn Pioneer Hi- insect resistance
Bred/Mycogen and herbicide
8. MON863 corn Monsanto insect resistance
food, feed and
9. GA21 corn Syngenta herbicide processing
10. MON863X corn Monsanto insect
food, feed and
11. NK603 corn Monsanto herbicide
food and feed
12. Bt11 corn Syngenta insect
13. MON810 corn Monsanto herbicide
14. T25 corn Monsanto herbicide
15. MON863 X corn Monsanto insect resistance
NK603 and herbicide
16. NK603 X corn Monsanto insect resistance
MON810 and herbicide
17. MON1445 cotton Monsanto herbicide
18. MON531 cotton Monsanto insect
19. MON15985 cotton Monsanto herbicide
20. MON15985 X cotton Monsanto insect resistance
MON1445 and herbicide
21. MON531 X cotton Monsanto insect resistance
MON1445 and herbicide
22. MON40-3-2 soybean Monsanto herbicide food, feed,
tolerance cultivating and
23. MS8 X RF3 canola Bayer sterility,
CropScience herbicide food, feed, import
resistance and processing
24. GT73 canola Monsanto herbicide
25. T45 canola Bayer herbicide
CropScience resistance food and feed
26. H7-1 sugar KWS Saat herbicide food, food
beet AG/Monsanto resistance ingredient and
27. * food, food A2704-12 soybean CropScience resistance ingredient and
C Bayer herbicide feed 28. LL otton 25 cotton CropScience resistance * products
Monsanto herbicide different than food
29. MON-89788-1 soybean Europe S.A resistance and feed with and
Bayer herbicide exception of
30. T45 canola CropScience tolerance cultivation
Monsanto insect resistance
31. MON 88017 corn Eur and herbicide ope SA
Pioneer insect resistance
32. 59122xNK603 corn Overseas and herbicide
33. MON 89034 corn Eur insect resistance ope SA
34. M SyngeIR604 corn (Diabrotica
Croatia has not approved any biotech seed variety for planting. In addition, there are no seed varieties
in the process of approval. Thus, currently, there is a de facto ban on biotech seed plantings in Croatia
with a biotech seed threshold level in regular varieties of 0.0%.
c. Situation for within-country biotech crop field-tests:
According to the Law on GMOs and consequent Regulations, field tests of biotech crops are allowed
after all the conditions prescribed by the Law and Regulations are satisfied. However, such tests are not
conducted in Croatia.
d. Treatment of stacked events:
To date, Croatian legislation does not specifically deal with or specifically outline the treatment of
stacked events. Future regulations may address this issue.
e. Additional product registration required, above and beyond approval, prior to use:
Biotech food and feed products require special permission as GMO products to be placed on the market
and permission as GMO food and/or feed products to be placed on the market. Additionally, all
agricultural seed varieties (regular and biotech) must go through a variety registration process before
they are placed on the list of seeds that can be marketed in Croatia. Biotech seeds, in addition to variety
registration, require special permission to be placed on the market, including permission for the
intentional environmental release of GMOs.
f. Legal framework for coexistence between biotech and non-biotech crops:
Details on coexistence between biotech and non-biotech crops will be defined in the Croatian National
Strategy for Coexistence of GMO Crops, Conventional and Ecological Agricultural Plant Production.
However, the Law on GMOs forbids planting of registered biotech crops in nature-protected areas,
ecological areas, areas for organic agricultural production or eco-tourism, in protected areas (i.e. as
defined as protection impact zones with previously enlisted zones), and in areas that were defined by
local government as GMO-free zones.
In addition, biotech crop plantings for reproduction are allowed only in the areas that are designated by
the Ministry of Agriculture, Fishery, and Rural Development and the Ministry of Culture (Environment
Protection Directorate) and approved by the Croatian Government in a special ordinance.
g. Labeling of packaged foods or feeds:
According to the Food Act, food and feed containing agricultural biotechnology ingredients must have
special, additional information on the label that informs consumers of all of its characteristics.
h. Biosafety Protocol:
Croatia signed and ratified the Cartagena Biosafety Protocol. Officially, there is no trade in biotech
products, especially not in seeds. However, it is currently difficult to tell whether the Biosafety
Protocol is being applied and working in practice.
i. Croatia is a member of the International Plant Protection Convention (IPPC), Codex Alimentarius
(Codex), and the World Organization for Animal Health (OIE), but Croatia does not appear to take an
active position regarding plant biotechnology in these organizations.
j. The Croatian legislative framework for biotechnology is very strict and Croatian consumers are very
negative towards modern, biotech foods.
k. Beyond current legislation, there is no additional pending, plant-biotechnology legislation with
potential to affect U.S. exports. A potential future exception could be legislation regarding
l. Biotech crops are not planted commercially in Croatia. Croatia has intellectual property rights
legislation in place and is a member of The International Union for the Protection of New Varieties of
Section IV. Plant Biotechnology Marketing Issues:
a. Market acceptance issues:
The average Croatian consumer views food derived from biotech crops negatively. Farmers are afraid
to grow biotech crops. There is a feeling that biotechnology is something unnatural and that food
should be natural. These negative opinions are based largely on emotions.
b. Country-Specific Studies on Acceptance of Biotechnology:
A Croatian market research agency carried out a study in 2009 on ?consumers? recognition of healthy
food? that among other things researched the opinions and knowledge of Croatian consumers on
GMOs. In this study, 51% of respondents said that they would not eat GMO food products under any
circumstances and 29% of respondents thought that they did not know enough about GM foodstuffs.
The study showed that 90% of respondents thought that GM foodstuffs should be clearly labeled on the
The same agency did a study in 2005and 2008 on public opinion on GMOs. In this study, 67% (2005)
and 58% (2008) of respondents said that they would not eat GM food products under any circumstances
and only 16% (2005) and 26% (2008) of respondents thought that they didn?t know enough about GM
Section V. Plant Biotechnology Capacity Building and Outreach:
a. List of the U.S. Government / USDA funded capacity-building / outreach activities that have been
carried out in Croatia over the past two years:
2011: Sponsorship of a speaker for a feed conference (KRMIVA): The topic of the conference was
Animal Feed and FAS Zagreb provided a speaker on the topic of ?Asynchronous Authorization and the
Low-level Presence of Unauthorized GMOs and GM-derived Materials in Imports of Feed Commodity
Crops from outside the European Union?.
2009: Sponsorship for of a speaker a feed conference (KRMIVA): The topic of the conference was
Biotechnology in Feed for which U.S. Grains Council (funding) and USDA (logistics) sponsored a
Section VI. Animal Biotechnology:
I. Development and Use:
a. Genetic engineering and cloning are not practiced in Croatia for the development of agricultural
b. There are no genetically engineered animals or products derived from the animals intended for or
currently in commercial production in Croatia.
a. Croatia does not have in place any legislation specifically related to the development, commercial use
and/or import of these animals or products. However, last amendment to the Law on GMOs
(Governmental Gazette 137/2009) mentions briefly that it is forbidden to plant registered biotech crops
or breed registered biotech animals in nature-protected areas, ecological areas, areas for organic
agricultural production or eco-tourism, in protected areas (i.e. as defined as protection impact zones
with previously enlisted zones) and in areas that were by local government defined as GMO-free zones.
Additionally the Law on GMOs mentions that The Ministry of Agriculture, Fisheries, and Rural
Development and the Ministry of Health and Social Welfare have joint responsibility concerning all
issues regarding food, foodstuff, and feed containing plant or animal biotechnology content and their
b. Currently, the FAS office in Croatia is not aware of any discussions of related regulatory or research
policies on these technologies.
c. Government entities that would likely regulate these technologies, regarding both food and
environmental safety issues related to research on or commercial use of these animals, include: Ministry
of Agriculture, Fisheries, and Rural Development; Ministry of Health and Social Welfare; Ministry of
Culture (Environment Protection Department); Ministry of Science, Education and Sport; Croatian Food
Agency, and Council for GMOs.
e. Labeling and/or traceability of these animals or products is expected to be an issue in Croatia. There
are indications that the Croatian Government might require mandatory labeling of products derived
from GE or cloned animals.
III. Stakeholder/Public Opinions:
f. There are active organizations that lobby against the genetic engineering or cloning of agricultural
animals. In addition, the Croatian press is expected to actively oppose this technology.
g. In Croatia, it can be expected that the market would reject these products.
IV. International Organizations:
a. We are not aware that Croatia actively participates in discussions in international organizations
related to the genetic engineering of agricultural animals.
V. Outreach, Needs, and Strategies:
Croatia is strongly opposed to bioengineering in plants and efforts to promote animal biotechnology are
unlikely to succeed.
Section VII. Author Defined:
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