NGOs raise the alarm that the Forest Stewardship Council is opening the door to the global release of genetically engineered trees

By Chris Lang

In February 2022, FSC announced that it is starting a “learning process on genetic engineering in forestry outside of FSC-certified area”. According to FSC’s website, “The aim of the FSC GE learning process will be for FSC and its members to gain sufficient and trusted knowledge on developments in genetic engineering in forestry.”

FSC’s website states that,

FSC intends to use this knowledge to determine whether it could develop a governance model ensuring rigorous safeguarding, risk management and shared value creation for genetic engineering in forestry in non-FSC certified area. The learnings would also be used to update existing policies and enable informed decision making for FSC and its members on topics related to developments in genetic engineering in forestry in the future.

Currently, FSC does not allow GE trees in certified operations, and it prohibits companies from commercially using GE trees in non-certified areas. But FSC’s euphemistically named “GE learning process” is clearly aimed at further weakening or removing this prohibition.

The Campaign to STOP GE Trees has written a Letter of Protest calling on FSC “to reaffirm its commitment to FSC’s current policy that prohibits the use of genetically engineered trees.”

Please sign on to the letter before 5 October 2022 so that the letter can be delivered before FSC’s General Assembly.

And the Canadian Biotechnology Action Network recently put out a briefing about FSC and GE trees.

The risks of GE trees

CBAN’s briefing summarises the problems with GE trees as follows:

Forests would be at risk from unknown and unpredictable impacts and interactions with genetically engineered trees. Forest ecosystems have a high degree of complexity, which is recognised but still not fully understood, making it unlikely that we will be able to understand or predict the potential impacts of intentionally or unintentionally introducing GE trees.

Unforeseen impacts can arise from the release of trees with new intended genetically engineered traits, as well as with the many possible unintended modifications that can result from the processes of genetic engineering.[1] Unintended effects from genetic engineering could, for example, change the safety or nutritional quality of seeds and nuts;[2] or alter wood rotting qualities which may impact fungal communities and the larval development of some insects. Even intended changes at the DNA level may impact the behaviour of trees in unexpected ways, such as changing stress responses[3] and interactions with other species, including over space and time. Experience with GE crop plants already warns that plantations of GE insect- or disease-resistant trees could shift pest pressures, with impacts on surrounding trees and forests.[4]

There are active proposals to deliberately release genetically engineered trees into the wild.[5] The use of GE trees in plantations would also put forests and forest ecosystems at risk from GE contamination, including invasiveness over time. The contamination risks from GE trees are particularly high because trees are long-lived organisms that produce abundant pollen and seed designed to travel long distances,[6] through wind dispersal and with help from animals. Once GE contamination begins, it cannot be stopped. GE trees will contaminate native forests, which themselves will become contaminants in a never-ending cycle.

[1] Wilson, A. K., Latham, J. R., & Steinbrecher, R. A. 2006. Transformation-induced mutations in transgenic plants: analysis and biosafety implications. Biotechnology & genetic engineering reviews, 23, 209–237.;
Li, J et al. 2019. Whole genome sequencing reveals rare off-target mutations and considerable inherent genetic or/and somaclonal variations in CRISPR/Cas9-edited cotton plants. Plant biotechnology journal, 17(5), 858–868.;
Wang, X., Tu, M., Wang, Y. et al. 2021. Whole-genome sequencing reveals rare off-target mutations in CRISPR/Cas9-edited grapevine. Hortic Res 8, 114.

[2] Benevenuto RF, et al. 2017. Molecular responses of genetically modified maize to abiotic stresses as determined through proteomic and metabolomic analyses. PLoS ONE 12(2): e0173069.

[3] Benevenuto RF, et al. 2021. Proteomic profile of glyphosate-resistant soybean under combined herbicide and drought stress conditions. Plants, 10(11): 2381.

[4] Lu Y, Wu K, Jiang Y, Xia B, Li P, Feng H, Wyckhuys KA, & Guo Y. 2010. Mirid bug outbreaks in multiple crops correlated with wide-scale adoption of Bt cotton in China. Science, 328(5982), 1151–1154.;
Schmidt JEU, Braun CU, Whitehouse LP, Hilbeck A (2009). Effects of activated Bt transgene products (Cry1Ab, Cry3Bb) on immature stages of the ladybird Adalia bipunctata in laboratory ecotoxicity testing. Arch Environ Contam Toxicol, 56.

[5] Canadian Biotechnology Action Network. 2021. Alert: Proposed release of genetically engineered American chestnut in US and Canada.

[6] Williams, Claire G. 2005. Framing the issues on transgenic forests. Nature Biotechnology 23 (530-532). June.

FSC and greenwashing of industrial tree plantations

In 2004, I wrote a report for the World Rainforest Movement and Friends of the Earth International about GE trees. The report includes a section about FSC and GE trees that highlights the problems with FSC’s approach to GE trees. The problems stem from the fact that FSC sees no difference between industrial tree plantations and forests. FSC has certified millions of hectares of large-scale monoculture plantations. The fact that these plantations are not GE trees is of little consolation to the farmers and Indigenous Peoples who have lost their land and livelihoods to the corporations behind these destructive plantations.

While FSC does not allow GE trees in certified operations, FSC does allow certified companies to carry out research into GE trees. Three FSC-certified companies have field trials of GE trees: Suzano, Stora Enso, and International Paper.

Suzano, GE trees, and FSC

The Brazilian company Suzano is the largest pulp and paper producer in the world. The company provides perhaps the best illustration of how FSC’s weak position on GE trees has failed to stop the development of GE trees – even by companies that are very closely associated with FSC.

Suzano’s industrial tree plantations in Brazil are FSC certified. By certifying these vast areas of fast growing monocultures FSC is helping to greenwash Suzano’s socially and environmentally destructive operations.

Suzano has pulpwood plantations covering an area of about 1.5 million hectares in Brazil. Suzano is the result of a series of mergers of huge pulp and paper companies operating in Brazil: Suzano Pulp and Paper; Fibria; Aracruz; and Votorantium.

In 2010, Suzano Pulp and Paper bought a UK-registered company called FuturaGene, which carries out research into GE trees. In 2012, Stanley Hirsch, CEO of FurturaGene stated that,

FSC is at the moment is a market barrier…But we are seeing a change in the certification bodies. FSC now allows forestry companies to look at research into GM trees. We are encouraging dialogue with FSC.

In 2013, Fibria wrote (in an answer to a questionnaire about GE trees organised by The Forests Dialogue):

Fibria has been carrying out research with Genetically Modified Eucalyptus since the late 1990s in controlled environments (both laboratory and greenhouse). Since 2011, with the new FSC interpretation on GMO Policy, Fibria has expanded field trial research in areas outside the scope of certification. Currently, Fibria has 92 hectares with GM Tree field trials (less than 0.01% of the company’s total area), into 11 different field trials.

In response to the same questionnaire, Suzano wrote that,

We expect to be ready to deploy GM yield‐enhanced eucalyptus commercially in the last quarter of 2014. There will then be a period in which scaling up and deployment in the different regions in which the company has commercial operations will progress towards full scale commercial production.

In 2015, FuturaGene obtained approval for its GE faster-growing eucalyptus tree. These trees were not used commercially because by the time the GE trees were developed and approved, Suzano had already developed non-GE eucalyptus trees that grew faster.

In November 2021, Brazil’s government approved the commercial planting of Suzano’s GE herbicide-tolerant eucalyptus tree.

Suzano remains a member of FSC. Estevão do Prado Braga, who worked at Suzano from 2011 to 2019, was on the Board of FSC from 2014 to April 2022. The whole time he was on the Board, Suzano, through its subsidiary FuturaGene, was carrying out research into GE trees.

Suzano’s involvement in GE tree research and FSC raises several questions:

  • Why would a pulp and paper company invest money into research into GE trees, unless it planned to use GE trees commercially?
  • Why would Suzano place one of its employees on the Board of FSC (which is the only certification scheme that has a position restricting the use of GE trees) unless it hoped to lobby FSC to further weaken its opposition to GE trees?
  • Why did FSC allow Suzano to remain certified, and associated with FSC, when the company has probably done more than any other company in the world to develop GE trees?

FSC’s “panel of experts”

FSC’s “panel of experts” includes the Victor Frankenstein of GE trees: Steven Strauss of Oregon State University. Apart from having spent a large part of his career developing and promoting GE trees, Strauss has actively lobbied to overturn FSC’s opposition to GE trees. In 2004, Strauss wrote that,

One certification system, that of the Forest Stewardship Council, originated with strong input from the extremist environmental groups Greenpeace and Friends of the Earth. It treats the use of any GE trees, even in a completely confined research plot, as a major violation for which certification would be precluded for that company.

Strauss notes that “companies have requested that this rule be rescinded, at least for research”. Sure enough, FSC subsequently weakened its position on GE trees to allow certified companies to carry out research into GE trees, as long as they didn’t plant them commercially.

Most recently Strauss co-wrote a paper that argues for policies that accept low levels of contamination from some GE perennial crops to reduce the legal risks and costs of field testing. The paper argues for industry “stewardship” and “best management practices” which would do away with requirements “for tracking gene dispersal” and “legal liability for gene movement”.

This raises a couple more questions:

  • Why would FSC turn to Steven Strauss for their “expert panel” rather than, say, someone who has documented the impact of industrial tree plantations on Indigenous Peoples and local communities and their environments in the Global South?
  • Or perhaps someone who has critically analysed the pulp and paper industry and the massive corporations that will benefit from this dangerous technology?

The rest of the “expert panel” consists of Jason Delborne of North Carolina State University, Andrew Blackwell of Arcadis Consultants, Juan Ramon Miguelez of 3sustainability, and Keith Robert Hayes of CSIRO.

Apparently, FSC contacted more than 80 experts before selecting these five white men from the Global North.

FSC states that it “is committed to ensure diversity of perspective and expertise background in the panel of experts, and the FSC Board has therefore decided to keep open seats for additional areas of expertise, including bioethics and biodiversity, with a focus on female experts and experts from the Global South.” So that’s alright then.

Cross-posted from REDD-Monitor.


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