A draft legislation on Tunisia’s biotechnology regulations that was put together before the start of the Tunisian revolution has been indefinitely postponed.
THIS REPORT CONTAINS ASSESSMENTS OF COMMODITY AND TRADE ISSUES MADE BY
USDA STAFF AND NOT NECESSARILY STATEMENTS OF OFFICIAL U.S. GOVERNMENT
Required Report - public distribution
GAIN Report Number: TS1205
Agricultural Biotechnology Annual
2012 Agricultural Biotechnology Annual
Hassan F. Ahmed, U.S. Embassy, Tunis
Youssef Chahed, Agricultural specialist. Tunis
A draft legislation on Tunisia’s biotechnology regulations that was put together before the start of the
Tunisian revolution has been indefinitely postponed. Approval of the proposed biotech law is not
expected until a new constitution is adopted and the election of a new parliament in spring 2013.
Meanwhile, imports of biotech products into Tunisia will continue to be handled in a similar manner to
that of conventional agricultural products. FAS/Tunis continues to assist in building Tunisia’s
biotechnology research capacity through exchange programs and technical workshops, when
Section I. Executive Summary:
Tunisia still has no legal framework dealing with the introduction, use and marketing of agricultural
biotechnology. New legislation on biotech products that was expected to be finalized and adopted by the
Tunisian parliament before the end of 2010 has been indefinitely postponed. In 2011 Tunisia underwent
a historic revolution that spread to several Arab countries and changed the picture of the Middle East
and North African region. Today, Tunisia is in a recovery phase after the revolution and is trying to
build democratic institutions and implement a new system of government through the writing of a new
constitution. It is unlikely under the current environment and with the long list of priorities for the
government that new biotech legislation would be reviewed or approved until the election of a new
parliament in Spring 2013 and a new constitution is adopted.
Currently, there is no debate on the GMO in Tunisia since public awareness of this issue is very low. In
the coming year, however, intense discussions concerning the pros and cons of the GMO are expected
to take place, and would be likely influenced by the EU policy position regarding biotechnology issues.
Meanwhile, imports of biotech products into Tunisia will continue to be handled in a similar manner to
conventional agricultural products. Although Tunisian officials recognize the existence of GMO
materials in imported animal feed products, the dependence of Tunisia’s agriculture on these imports as
well as the increased international acceptance of GMO products have allowed the import of these
biotech products to continue.
Tunisia’s agricultural biotechnology activities continue to be restricted to the research level, mostly
covering applications related to plants, animals and insects. There is government support provided to
several biotechnology research institutes that have emerged in Tunisia in recent years allowing the
improvement of Tunisia’s understanding of biotechnology issues at the researchers’ level.
During the past few years, FAS/Tunis carried out several activities aimed at building close working
relationships with key players dealing with biotechnology issues in Tunisia. Post sponsored several
conferences and supported Cochran and Borlaug programs’ participants in biotech activities. Post also
conducted successful outreach activity targeted at policy makers, opinion leaders, legislatures, and civil
societies in Tunisia in order to help guide the process of establishing viable biotechnology legislation in
Section II. Plant Biotechnology Trade and Production:
Tunisia's primary trading partners are France, Italy, Germany, Belgium, Luxembourg, and the Maghreb
countries. In 2011, the U.S. was Tunisia’s seventh largest trading partner, with the U.S.-Tunisian trade
declining by 4 percent, to $938 million, down from $977 million in 2010. Tunisia has been a net
importer of agricultural products, with a negative food trade balance in the last two decades. Leading
agricultural imports in 2011 were wheat ($520 million), corn ($267 million), vegetable oils ($465
million). Leading exports were olive oil and products ($287 million), fishery products, dates, and citrus.
Tunisia is one of the world’s major exporters of olive oil, a fact that is largely overlooked as much of its
production is exported in bulk to EU countries (Italy, Spain) to be refined, bottled, and marketed as
exported from the EU.
In 2011, U.S. Agricultural exports accounted for 53 percent of all total exports to Tunisia. In 2011, U.S.
agricultural exports reached a record high at $311 million, with corn oil, oilseeds, coarse grain, and
wheat exports accounting for the bulk of these exports. Tunisia’s agricultural exports to the United
States in 2011 totaled $86 million, of which olive oil accounted for $74 million. Tunisian olive oil
export shipments enter the U.S. market with a preferential access under the framework of the General
System of Preference (GSP). In 2011, the U.S. ranked as the second largest destination, after the EU
market, for the Tunisian olive oil exports absorbing about 25 percent of Tunisia's olive oil exports.
Tunisia agricultural biotechnologies uses are limited to three domains of application: plants, animals
and insects. The activities involving biotechnologies such as the production of GMOs and recombinant
DNA are restricted to the structures of research. Field-testing and, a fortiori commercial use, are on hold
pending the enactment of national biosafety regulations.
Concerning the trade, there is no segregation as both biotech and non-biotech products are handled the
same way and no existing law restricts, controls or authorizes biotech products trade. A recent study
published by the Tunisian Ministry of Health demonstrated that human alimentation in Tunisia was free
of GMO while animal feed contains a high level of GMO principally imported corn and soybean meal.
Section III. Plant Biotechnology Policy:
Tunisia has been a signatory country of the Cartagena protocol since 2003. However, currently there is
no legal framework dealing with the use and release of products of agricultural biotechnology in
Tunisia. Two ministries are involved in GMO issues as the focal point, the Ministry of Agriculture and
the Ministry of Environment and Sustainable Development. The Ministry of Health is also involved via
the Agency for Sanitary and Environmental Controls of Imported Products, ANCSEP. .
Tunisia is at a crossroads on biotechnology policy. Most of the Tunisian policy-makers see agricultural
biotechnologies as useful in addressing the country’s chronic agricultural problems such as crop disease,
weed control, and drought tolerance crops. A draft law currently under consideration would establish a
legal framework for the importation, commercialization, and use of biotechnology in agriculture.
However, this effort may be compromised by skepticism on the use of biotechnology, a reflection of
Tunisia's close ties with Europe. The draft of Tunisia’s biosafety regulations is not yet a public
document. However, it is reportedly made up of two laws (a draft law related to the confined use,
deliberate release and commercialization of biotech products and a draft law related to the import and
transit of biotech products), three decrees and three ministerial orders. One of the main provisions of
these draft regulations would be the obligation to apply for an authorization prior to importing biotech
products into Tunisia. Several laboratories seems to have the potential to carry out GMO testing using
PCR-based detection methods, once legislation is in place. It is worth noting that Tunisia is receiving
technical assistance from the EU to establish its GMOs testing capacity and that the International
Service for the Acquisition of Agri-biotech Application (ISAAA) is planning to open a regional
Biotechnology Information Center (BIC) to be hosted by the ICARDA's office in Tunis. Concerning
labeling, it should be noted that Tunisia published a decree in September 3, 2008 (Art. 7) that makes
labeling mandatory for all foods products and food ingredients containing GMO.
On the research side, GOT implemented a fully supportive policy for Agricultural biotechnology. In
2008 a national laboratory for GMO detection and a research center to assess the risks of using GMO
were established. Moreover, GOT’s encouragement of biotechnological research contributed to the
development of the state of knowledge of Tunisian laboratories’ teams. Today, a dozen major institutes
conduct biotech research. They are either institutes working under the umbrella of IRESA (Institution of
Research and Higher Education) of the Ministry of Agriculture such as INRAT (Institut National de
Recherche Agronomique de Tunisie) or under the jurisdiction of the Ministry of Scientific Research and
Technology, such as the Center of Biotechnology in Sfax (CBS) or the Center of Biotechnology of Borj
Cedria (CBBC). New molecular biology technologies as viral genome isolation, gene cloning,
transformation methods and functional genomics are now established in these laboratories. Several
agricultural biotechnologies either at the experimental stage or at the commercial stage, such as micro-
propagation techniques, are now used. The latter are widely used to generate disease-free or salinity
tolerant planting material mainly for wheat, citrus, date palm and grapevine. FAS/Tunis maintains a
close contact with all the above mentioned laboratories and regularly engages them in outreach activities
and scientific exchange programs of mutual interest.
Section IV. Plant Biotechnology Marketing Issues:
There are no significant market acceptance issues related to the sale of biotech products in Tunisia due
to the non-existence of GMO food-use on one hand, and the absence of strong consumer movements
pushing trade-restrictive agendas on the other hand. However, it is mandatory to inform consumers
when genetically engineered (GE) methods of production are involved. According to the September 3,
2008 decree, labeling of food products and food ingredients containing GE organisms is mandatory.
However, this obligation is not sufficiently clear and does not provide details on the type of products
involved, the percentage of GE material authorized and the authority in charge of the enforcement.
Consumers continue to be largely unaware of the controversial debate between proponents and
opponents of biotech at the international level. The biotech debate has not yet reached the public arena
although we see from time to time newspaper articles conveying the EU concerns about modern
biotechnology. A recent local inquiry showed that only 4percent of the Tunisians has heard about GMO
Who might be drawn to use GMOs in Tunisia?
Large scale farmers in Tunisia would be interested by GMOs since their adoption will reduce the costs
brought by the use of pesticides and irrigation. Moreover the use of GM plants resistant to diseases,
salinity or drought would be profitable considering that a reduction of the cost of treatments and an
improvement of the yield would be obtained. However the question arises for the small-scale farming
(less than 20 ha) which represents a majority of the total number of the farms in Tunisia. In such farm,
cereal seeds are simply taken out of the previous harvest and no pesticide or herbicide treatments are
applied because of their costs. Consequently the use of GMOs would be possible only through
governmental support by subsiding transgenic seeds for example.
Section V. Plant Biotechnology Capacity Building and Outreach:
The FAS/Tunis office under an overall regional strategy supports local interest in biotechnology by
developing several activities. Post activities have been focused on identifying key players and on
advocating science-based biotech risk assessments and trade-friendly regulations. We have been
successful in establishing relationships with key officials, some of whom are influential members of the
National Biosafety Committee. AgTunis will continue promoting exposure and increased familiarity of
Tunisian regulators and scientists with biotechnology.
Outreach Activity: The Contributions of Plant Biotechnology in Confronting Climate Change"
In October 2010, FAS/Tunis, in cooperation with the Department of State, organized a well attended
workshop targeted at 200 policy makers, opinion leaders, legislatures, and civil societies in Tunisia in
order to help guide the process of establishing viable biotechnology legislation in Tunisia. The
successful workshop, presented by four U.S. experts from Cornell University, University of California
Berkeley, and University of Nevada, addressed several issues related to the contributions of plant
biotechnology in confronting climate change and focused on biotech role in addressing plant disease,
mitigating global warming, and adapting crops to marginal soils. The successful event generated wide
positive media coverage and gave the scientific community an opportunity to engage in the policy
debate over various biotechnology subjects in Tunisia.
Norman E. Borlaug Fellowship program
In 2009, a Tunisian researcher from the Center of Biotechnology of Borj Cedria (CBBC) participated in
June 2009 in a six-week training program at Oklahoma State University under the Norman Borlaug
Program, this training should help in building Tunisia’s researcher capacity and to improve its
knowledge of small grain production and to gain exposure to latest weed management practices. In
addition the program will provide the opportunity for Tunisian scientists and policymakers to establish
long-term contacts with U.S. scientists and apply the newly gained knowledge from U.S. laboratories to
their research and development programs.
The Cochran Fellowship Program
Post implemented several Cochran programs in the last 10 years focusing on providing several key
government officials with training courses in order to enhance their understanding of commercial and
technical applications of U.S. agricultural biotechnology. This has helped prevent creating an anti
biotech culture in Tunisia and imposing more restrictive measures on trade of biotech products
Conferences and others activities
Post sponsored several conferences and workshops which have led, among other outcomes, to
supportive articles in local media. An article, for instance, posted in a widely circulated daily
newspaper featured a headline mirroring the US position in using modern biotech to alleviate
hunger and malnutrition.
The Agricultural Specialist led a delegation of 10 Tunisian risk assessors to attend a 3-day risk
assessment workshop in Morocco.
Post placed a cleared op-ed in local media under the ambassador’s signature explaining reasons
having led the U.S. to file a WTO case against the EU’s moratorium on approving agricultural
Section VI. Animal Biotechnology:
Animal biotechnologies are at their early stages except for basic reproductive biotechnologies such as
artificial insemination. Embryo transfer, although technically feasible, has not yet gained a significant
uptake in the livestock sector.
Section VII. Appendix I
Following are the main regulations governing the import of (1) seeds and seedlings, (2) unprocessed
food and feed, (3) consumer-oriented products and (4) GMO labeling:
(1) Seeds and seedlings imports must comply with Decree # 2002-621 dated March 19th, 2002. This
decree sets rules to import all seeds and seedlings. Apart from the phytosanitary aspects, the main
provisions of this decree are the obligation for the importer to apply for a license, to have a minimum
storage capacity and to keep records for its inventories. Seeds and seedlings covered by this decree are:
potato, citrus, strawberry, pulses, horticultural seeds, forages, cereals and vine.
(2) Unprocessed food and feed: the existing sanitary and phytosanitary rules do not refer to the
biotechnology aspects. In Tunisia, phytosanitary control of imported food and feed is regulated by the
Law # 92-72 dated August 3rd 1992, while sanitary control is covered by the Law # 99-24 dated March
9th, 1999. The enforcing authorities are the DGPCQPA (Direction Generale de la Protection et du
Controle de la Qualite des Produits Agricoles) and DGSV (Direction Generale des Services
Veterinaires), both departments within the Ministry of Agriculture.
(3) Consumer-oriented food products: Apart from the sanitary and phytosanitary laws that apply also to
this type of product, consumer-oriented products must comply with the decree dated July, 1985
validating Tunisian standard NT 15-23 (1983) which applies to pre-packed food commodities labeling
and presentation. The enforcing authority is the DQPC (Direction Generale de la Protection du
Consommateur) of the Ministry of Commerce.
(4) Food labeling: Article 8 of the decree published by the Ministry of trade in 2008 concerning labeling
of Foods and Food Ingredients oblige producers to mention clearly in the label GMO presence in the
product. This article is not clear since there is no GMO production in Tunisia.