In a joint EU-funded research project the procedures for the authorised release of genetically modified organisms in Europe were compared.
Although the EU Directive 90/220 on deliberate releases regulates the conditions for releases and bringing onto the market, practical implementation had varied. For example the Dutch authorities justified the introduction of herbicide-resistant rape strains exclusively on the basis of their direct influence on the natural environment. The Danes looked at the possible influences on farming practice, while the British regarded the problem as being purely agricultural and having nothing to do with the Directive. Other differences concern the information policy: In the Netherlands information was freely accessible to the public; in Germany and other countries it was filtered. Interpretations of the nature of the risk, avoidance strategies or risk/benefit analyses also differed.
The study identified serious obstacles to harmonisation because of different interpretations of the object at risk, its acceptability in the light of conventional environmental risks and the basis of comparison for genetically modified plants. It came to the conclusion that the decision-making process should take account not only of scientific expertise, but also of the political background and environmental legislation traditions.