Following the implementation of the Biosafety Law on September 26, 2010, three soybean events and 16 corn events were approved for import for feed use only.
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:
Agricultural Biotechnology Annual
Clay Hamilton, Agricultural Counselor
Yasemin Erkut, Agricultural Specialist
Following the implementation of the Biosafety Law on September 26, 2010, three soybean events
and 16 corn events were approved for import for feed use only. Currently applications for
import of EU approved corn and canola events as well as soybean events for food use are being
reviewed. A threshold for unapproved events is established as 0.1% for feed.
Section I. Executive Summary:
Public opposition to agricultural biotechnology increased significantly in 2011 mostly due to
campaigns run by NGOs via print and visual media. A number of pseudo- science documents
were published by media in 2011. In Turkey, biotechnology is not well understood.
The Biosafety Law went into effect on September 26, 2011. Since the publication of the Law, the
Ministry of Food, Agriculture and Livestock established an independent Biosafety Board,
consisting of mostly bureaucrats and some academicians. To date importers of agricultural
products submitted applications for approval for food and feed of 22 corn, 3 soybean, 3 canola,
one sugar beet and one potato starch transgenic events (all currently approved in the EU).
Approval for feed and food use must be applied for separately. Of these events, the Board has
approved usage for only 3 soybean and 16 corn events for feed use. The rest of the applications
are still under review.
The EU recently adopted a 0.1% threshold for unapproved* events in feed material. In September
2011, the Biosafety Board adopted the same threshold for feed.
*Unapproved events refer to events that are not approved but that are currently being reviewed by the
Section II. Plant Biotechnology Trade and Production:
The Turkish Grand National Assembly adopted the Biosafety Law (Law No: 5977) on March 26,
2010. The law included a transition period of 6 months, so it was implemented on September 26,
According to Article-5 of the Law, production of genetically modified animals and plants is
banned. Importation of transgenic seeds is also forbidden by Law and by the seed circular,
published usually in January of every year by Ministry of Food, Agriculture and Livestock
Production of transgenic crops was never allowed in Turkey, but there are rumors that some
producers acquired transgenic seeds (mostly cotton and corn) and planted them illegally in the
past. However, following the enforcement of the law, unauthorized plantation became more risky
since the punishments for unauthorized planting included in the Law are severe.
The Law also mandates that for any research on biotech carried out in Turkey, the researcher
needs to apply to the Biosafety Board in advance for permission to carry on the research. Many
academicians voiced concerns about this issue. Although MINFAL has stated that the Law will not
discourage research, it seems to already be affecting willingness of the private and public sector to
pursue further research in this area. Turkish companies and universities have so far not
developed any transgenic seeds.
Turkey continued to be an importer of bulk and semi- processed commodities in 2011. With $1.2
billion in value, cotton was again the top export commodity from the US to Turkey in 2011 as
well. Soybeans were the third largest export commodity in 2011. The United States is among the
top suppliers to the Turkish market.
Due to insufficient domestic production and increasing demand, Turkey imports significant
quantities of feed crops for its poultry and livestock sectors.
In 2010, the Turkish Feed Millers Association submitted dossiers for approval of three soybean
events (feed use only) that are already approved in the European Union. These were: A2704-12,
MON89788 and MON40-3-2. Due to the urgent need for these products by the animal sector, the
Biosafety Board decided to review the applications under the simplified procedure, which is an
expedited process designed to reach a conclusion within 90 days as opposed to the 270 days
allowed under the regular review.
Finally the Biosafety Board approved the above mentioned soybean events to be used as feed.
Following the publishing of the final approval decision on January 26, 2011 on the Official Gazette,
imports of soybean resumed again in February 2011.
In January of 2011, the Feed Millers Association also applied for feed use approval for the 22 EU
approved corn events. In December 2011, and April 2012, approvals for feed use were given for
16 out of 22 corn events with the remaining 6 events being rejected. As a result of the rejections,
trade did not resume for corn and corn by-products due to the difficulty in segregating the biotech
events in the supply chain.
Trade in other higher valued products such as supplements and pet food have also been
negatively impacted by the Law and there have been rejections of some products due to their
transgenic product content or very low presence of transgenic crops.
Section III. Plant Biotechnology Policy:
Unfortunately, in Turkey agricultural biotechnology is not well understood. The major reason for
it is because massive anti-GMO campaigns run by some NGOs with the support of media. This fear
was exacerbated by early attempts by the Ministry of Agriculture to regulate the technology in
Implementation of the Biosafety Law began on September 26, 2011. Following implementation of
the Law and the related implementing regulations, import of transgenic agricultural products are
only allowed after approval of each event.
Approval can only be granted after a detailed application (dossier) is submitted and reviewed by
the Biosafety Board, its sub-committees, and then approved by the Ministry of Food, Agriculture
and Livestock (MINFAL)
Following the adoption of the Biosafety Law, MINFAL’s General Directorate of Agricultural
Research and Development established a Biosafety Board. The Board has nine members and is
the independent authority in charge of reviewing applications for importation of transgenic
events. Most of the Board members are high- level bureaucrats from the Ministry of Agriculture,
Ministry of Health, Ministry of Industry and Trade, Ministry of Environment and the Ministry of
Economy. It also includes academicians from Ankara University.
For every application, the Board establishes Risk Assessment, Socio- Economic and Ethical
Committees from a “List of Experts”. The members of the committees are kept secret. However,
the List of Experts is public and contains approximately 180 experts from Turkish academia. Each
committee can review several applications at the same time.
MINFAL published two implementing regulations of the Biosafety Law on August 13, 2010. These
were “Regulation on GMO and Products” and “Regulation on Working Principles of the Biosafety
Board and the Committees”.
According to the Law, either the gene owning technology companies or importers of transgenic
crops are allowed to submit applications for the approval of a transgenic event. The reviews are
to be completed within 270 days, or 90 days under the expedited procedure. The Biosafety Board
determines which time line to use. Prior to implementation of the law, the Turkish Ministry of
Food, Agriculture and Livestock pressured the international companies that have developed
agricultural biotech events to submit applications under the new Law as quickly as possible in
order to avoid trade problems, however these companies expressed concerns about the severe yet
unclear liability provisions in the Law as well as the vagueness of the application procedures. To
date none of the technology owning companies submitted any applications to be reviewed by the
Biosafety Board. Since Turkish feed millers depend on imported ingredients, the Turkish Feed
Millers Association immediately submitted applications for the import of three EU approved
soybean events for feed use only in October, 2010.
Without the support of the seed companies, the Feed Millers’ Association’s dossiers mainly
contained documents that were available online. The dossiers were reviewed under the
Simplified Procedure as stated in the Law (expedited) due to the urgent need to import protein for
the animal sector. Following the review process, three soybean events (A2704-12, MON40-3-2,
and MON89788) were officially approved via the Official Gazette on January 26, 2011.
In January of 2011, applications for 22 corn events were submitted to the Biosafety Board for feed
use only by the Feed Miller’s Association. All of these events are already approved in the
European Union. These applications were reviewed under regular procedure. As a result of the
review, the Biosafety Board approved 16 corn events on December 24, 2011 and on April 21,
2012. The Board rejected 6 corn events. Please see below table for full list of approvals and
Table-2: Status of Applications for Soybean and Corn for food and feed use
Status of Application/ FEED Status of Application/ FOOD
Commodity Event USE USE
Soybean A2704-12 Accepted Under review
Soybean MON89788 Accepted Under review
Soybean MON40-3-2 Accepted Under review
Corn Bt11 Accepted Under review
Corn DAS1507 Accepted Under review
Corn DAS59122 Accepted Under review
Corn DAS1507xNK603 Accepted Under review
Corn NK603 Accepted Under review
Corn NK603xMON810 Accepted Under review
Corn MON88017 Accepted Under review
Corn DAS59122xNK603 Accepted Under review
Corn GA21 Accepted Under review
Corn MON 810 Accepted Under review
Corn MON 863 Rejected Under review
Corn MON 863x NK603 Rejected Under review
Corn MON 863xMON810 Rejected Under review
Corn MON 89034 Accepted Under review
Corn MIR604 Rejected Under review
MON 863x Rejected Under review
Corn MON89034 x NK603 Accepted Under review
Corn Bt11 x GA21 Accepted Under review
Corn 59122 x 1507 x NK603 Accepted Under review
Corn MON88017 x MON810 Accepted Under review
Corn DAS1507 x 59122 Accepted Under review
Corn T25 Rejected Under review
In January, 2011, the Federation of the Food and Beverages Associations also submitted
applications for all EU approved soybean, corn, canola and potato events for food use only.
Currently the Risk Assessment and Socio-Economic Committees of the Board are reviewing these
applications. The Board decided to review all these applications under the regular procedure.
The reason for the decision to use the regular as opposed to the simplified procedure was not
The Board is under pressure from the food industry to set a low level presence threshold for
existence of unapproved varieties in food. In September, 2011, the Board adopted a rule very
similar to the new threshold adopted by the EU’s 0.1% threshold for unapproved events in feed
material. It is significant to mention that “unapproved” refers only to events that are already
submitted to the Biosafety Board for review and no decision is made yet.
Currently there is no threshold for presence of unapproved transgenic events in food. As a result,
trade has been severely restricted out of concerns that dust or minor contamination of identity
preserved (IP) products will lead to rejection of shipments.
The liability provisions of the Law include harsh penalties including lengthy jail terms for
unspecified “related parties”. The Law also does not give explicit guidance about what documents
are required and how they will be evaluated. The Law also bans inclusion of biotech ingredients
in baby food or food supplements for young children, bans planting of biotech seeds, and contains
onerous labeling and traceability once the product does arrives in Turkey. It also does not allow
an application to be submitted in Turkey until it is already approved in the country of production,
which guarantees asynchronous approvals.
The Law is not expected to be revised any time soon, as the topic is too controversial and any
change to the Law would require debate and voting in the Parliament. The implementing
regulations connected to the Law are rather easy for MINFAL to amend; however, they may not
conflict with any provisions of the Law.
Section IV. Plant Biotechnology Marketing Issues:
The fear of biotechnology by the general Turkish public, producers, retailers and consumers
continues. This is mainly due to successful anti-GMO campaigns run by local and international
NGOs such as Chamber of Agricultural Engineers, Greenpeace and the Friends of the Earth since
According to the Biosafety law and regulations, any imported biotech food or feed above the
labeling threshold set by the Ministry (In January 2011 this threshold was given as .9% via an
internal Agriculture Ministerial Directive) must be labeled. Traceability clauses in the Law and
implementing regulations require that records to be kept for a minimum of 20 years detailing the
unique identifier of the GMO, quantity, supplier, and purpose of use, each time a product is
processed or handled, from the time of import to the time of distribution to the market.
The implementing regulations also require that “GMOs and products thereof are processed and
stored in separate lines. In the event that this is not possible, the production lines and storage
facilities must be cleaned by the interested parties in a manner to prevent any contamination with
GMOs and products thereof and the circumstance must be committed to records.”
Section VI. Animal Biotechnology:
There is no discussion about animal biotechnology in Turkey however the Biosafety Law
presumably covers this realm.
Section VII. U.S. Exports:
Table-1: U.S. Agricultural Exports to Turkey
U.S. Agricultural Exports to Turkey
2006 2007 2008 2009 2010 2011
Product Value in Thousand US Dollars
Cotton 512,417 767,115 536,325 487,301 860,904 1,180,291
Soybeans 139,493 126,102 213,738 341,540 250,427 127,999
Feeds and Fodders 27,976 96,444 238,466 88,989 89,067 21,295
Soybean Meal 20,650 41,553 52,202 79,171 59,445 46,731
Vegetable Oils (Ex Soybean) 58,294 79,392 110,515 52,712 45,957 42,368
Other Bulk Commodities 15,228 19,372 15,911 33,741 25,913 13,344
Other Consumer Oriented 15,441 11,586 16,252 16,351 16,435 26,386
Other Intermediate Products 12,150 16,269 13,663 7,785 11,506 12,407
Planting Seeds 5,603 6,242 12,939 10,096 9,104 16,102
Coarse Grains 0 77,476 73,038 4,073 2,718 0
Pet Foods 4,774 4,707 5,646 5,837 2,703 1,224
Snack Foods 1,670 825 2,520 3,219 1,564 1,781
Soybean Oil 2,203 36 149 2,060 79 2,803
Breakfast Cereals 22 62 25 132 44 11
Subtotal product possibly containing 816,551 1,247,181 1,291,389 1,133,007 1,375,866 1,492,742
All others 224,276 265,976 454,958 410,695 774,286 1,042,838
Total exports 2,040,827 1,513,157 1,746,347 1,543,702 2,150,152 2,535,580