CHAPTER SEVEN

Food Security and the

Sustainability of GMOs in the
United States and the
European Union
Gerard Breeman1, Sarah Giest, Dovile_ Rimkute_
Institute of Public Administration, Leiden University, The Hague, The Netherlands
1
Corresponding author: e-mail address: g.e.breeman@fgga.leidenuniv.nl

Contents
1. Introduction 165
2. GMO Controversies 166
3. Theoretical Approach: Frames and Institutional Context 168
3.1 Framing Theories 169
3.2 Institutional Context 170
3.3 Research Design 172
4. GMO Regulation in the US and the EU: General Institutional Frames 172
4.1 The Institutional Context and Framing 174
4.2 Specific Institutional Frames 177
5. Analysis 185
6. Conclusions 187
References 188
Further Reading 193

1. INTRODUCTION
A wide variety of arguments is used in discussions about the advantages
and disadvantages of genetically modified organisms (GMOs). These discus-
sions have resulted in serious controversies and many different policy out-
comes (Abou-Gabal, 2015). Some regions in the world focus on the effects
of GMOs on the environment; others highlight food safety issues. Some
countries apply restrictive GMO policies; others do not. This chapter aims
to analyze how the different controversies of the GMO discussions have

Advances in Food Security and Sustainability, Volume 2 # 2017 Elsevier Inc. 165
ISSN 2452-2635 All rights reserved.
https://doi.org/10.1016/bs.af2s.2017.09.005
166 Gerard Breeman et al.

been structured by analyzing which frames are used and how these frames are
related to the policy decisions governments have taken. It will also explore
why the different policy decisions are taken by further involving the insti-
tutional context in the analysis. In this context, frames, institutions, and pol-
icy decisions in two Member States of the European Union (Austria and the
UK) and two US States (Vermont and California) are analyzed. The choice
includes two states that took constraining measures to GMOs (Austria, Ver-
mont) and two states that did not (UK, California).
These different approaches prompt the question of what the factors and
mechanisms explaining divergent policy outcomes in the US and the EU as
well as in (Member) States are. We seek to place the divergent approaches
toward the regulation of GMOs in an institutional context. We argue that a
good starting point in providing an account of what lies behind different
GMOs governance decisions and practices is sociological institutionalism.
Different institutional structures and political legacies are key factors
explaining how dissimilar GMO policy frames prevail. More specifically,
we argue that different institutional contexts provide different framing opportunities
for interest groups, NGOs, and other stakeholders that in turn shape GMO
policy outcomes (Str€ unck, 2005).
In the next section, we distinguish four types of controversies that are
central to GMO discussions. In Section 3, the theoretical concepts of fram-
ing and institutions are presented, as well as a brief methodological note.
Section 4 describes the institutional structures of the GMO food policy arena
(such as regulatory agencies) on both continents. Section 5 presents the pol-
icy frames per (Member) State, resulting in a final analysis that answers the
research question. The chapter ends with a conclusion.

2. GMO CONTROVERSIES
The World Health Organization (WHO) defines GMOs as
“organisms (i.e. plants, animals or microorganisms) in which the genetic
material (DNA) has been altered in a way that does not occur naturally
by mating or natural recombination” (World Health Organization
(WHO), 2014). The modification of organisms is, however, not new.
Humans have been selecting plants and animals for thousands of years and
some indicate a starting point as early as 32,000 BC (Wang et al., 2013;
Zimmer, 2013). Through selective breeding, plants and animals grow faster,
produce more, and are more resistant to diseases. As a result of millennia of
Food Security and the Sustainability of GMOs 167

selective breeding, the DNA of countless animals and plants has been
changed.
Since the 1970s, however, it has become possible to change crops and
animals by modifying the DNA structure of organisms in such a way that
would not have been possible through natural recombination. This tech-
nique is sometimes referred to as genetic engineering. Instead of selective
breeding, a genetic engineer takes a specific part of the DNA of one organ-
ism and inserts that into the genome of another organism. Genetic engineer-
ing includes both the adding and removing of DNA material. It can be done
within the same species, between different species (transgenic) and, recently,
also with synthesized material. Genetic engineering has been mainly applied
to make crops more resistant to diseases and certain herbicides (Rangel,
2015). Nowadays, more than 90% of corn, soy, and sugar beets in the US
are genetically modified. When we use the term GMO in this chapter
we mean genetically engineered organisms and not the modification of
organisms through selective breeding.
Discussions about GMOs are largely centered around four types of con-
troversies. The first controversy concerns food safety. Many studies show that
GMOs are safe for consumption (Snell et al., 2012). At the same time, how-
ever, some scientists (Hilbeck et al., 2015) point out that there is not enough
knowledge about the long-term effects. Additionally, in 2016, the WHO
warned about the negative health effects of herbicides that contain
glyphosates which are typically used during the production of GMOs.
Glyphosates kill weeds but do not harm the crops that are genetically mod-
ified to be resistant to glyphosates. Glyphosates, however, may be potentially
cancerogenic (IARC, 2017).
The second controversy concerns the negative effects GMOs may have
on the environment. On the one hand, statistics show that the use of insecti-
cides has come down thanks to GMOs. On the other hand, the use of her-
bicides has been increasing due to two reasons. First, most GMOs are
designed to be resistant to herbicides, which results in an easy use of herbi-
cides to kill weeds between the GMOs. Such is the case with the use of
glyphosates as mentioned earlier. Second, the intensive use of herbicides
makes weeds resistant, which results in so-called super weeds, which, in
turn, need more and stronger herbicides. Additionally, studies highlight
the possible unwanted cross-pollination of GM crops with other crops
affecting biodiversity. Finally, GMOs are typically used in industrial agricul-
ture which can have negative effects on ecological diversity and soil quality
(Shiva et al., 2011).
168 Gerard Breeman et al.

The third controversy concerns the necessity of GMOs for food security.
GMOs are considered by many as the solution for fighting hunger and for
increasing yields (von Braun, 2010). However, this claim is contested for not
having scientific support. It is sometimes argued that this claim reflects more
the corporate interests rather than that it is a necessity to reach global food
security ( Jacobsen et al., 2013). The main argument against GMOs is that a
lot of other studies and practices have shown that yields can be just as good
with agricultural techniques that are not dependent on GMOs (Gerry, 2015;
Sarich, 2014).
The fourth controversy concerns an entire set of different ethical and
fundamental rights issues that are related to GMOs. Supporters of GMOs
emphasize the long history of (and experience with) crop selection and
cross-fertilization and point out that GMOs are no different. Opponents
question whether it is ethically sound to change the DNA of crops at all.
Moreover, supporters and opponents also argue about possible effects of
GMOs on social–economic relations. One of the aspects of these relations
is GMO labeling. Some say that if GMOs are considered to be “materially
not different” in composition from other crops, it should not be necessary to
label them as such (Fox, 2015). Others argue that consumers have the right
to know what they eat, and thus they demand GMO labeling on food. The
labeling might, however, affect markets and competition structures,
resulting in new submarkets and higher food prices. Finally, GMOs also raise
questions with regard to the increasing power position of the producers of
GM seeds. On the one hand, these companies obtain patents of the products
they develop and need the revenues to innovate. On the other hand, due to
the patents they become intellectual and commercial owners of certain
crops. This can potentially put farmers in a deadlock position where they
become dependent on the seeds form these companies (Abou-Gabal, 2015).

3. THEORETICAL APPROACH: FRAMES AND

INSTITUTIONAL CONTEXT
How did these controversies evolve into different policy outcomes in
the US and EU? There are many comparative studies of GMO policies in the
US and the EU (Gaskell et al., 1999; L€ ofstedt and Vogel, 2001), as well as
studies about GMO policies of the individual US and EU (Member) States
(Bovay and Alston, 2016; Johansson, 2009; Montpetit et al., 2006). There is,
however, not a comparative study between the US and the EU about how
higher governance level institutions (i.e., the federal and EU level) affect the
Food Security and the Sustainability of GMOs 169

lower governance levels in terms of framing and policy outcomes. In this

chapter, we want to fill in this gap. We argue that different institutional set-
tings in and within the US and the EU are important factors explaining how
national, federal and supranational governments, NGOs, and other stake-
holders determine policy frames that eventually affected actual policy deci-
sions at the lower governance level. Hence, we rely both on framing and
institutional theories.

3.1 Framing Theories

Framing theory suggests that every policy issue has many potential dimen-
sions; therefore, framing is an essential device for policy actors who want to
influence potential policy outcomes (Baumgartner and Mahoney, 2008;
Daviter, 2009; Eising et al., 2015). Framing is a political and normative
activity that refers to the attempt of policy actors to select and highlight spe-
cific aspects of a policy issue and their importance (McAdam et al., 1996). It
is used to emphasize certain aspects of a situation or a problem that serves the
interests of stakeholders (Rein, 1983). If frames prevail by obtaining public
support, they can facilitate the institutionalization of a specific ideational
constellation (Candel et al., 2014). For instance, in the 1950s and 1960s,
European agricultural policy was framed predominantly in terms of food
security, which in turn, authorized the institutionalization of the European
common agricultural policy—the CAP—mainly serving the interests of the
European farmers (Candel et al., 2014; cf. Skogstad, 1998).
Often, policy controversies are constructed out of different conflicting
frames at the same time. This is particularly true in multilevel governance
systems consisting of many policy actors working at different levels,
possessing conflicting policy positions, and preferring different policy out-
comes. In such cases, the policy process evolves through different episodes
of framing and reframing activities, during which stakeholders fight over the
meaning of the policy problem. Some policy problems, such as food security
are so complex and full with conflicting frames that these are referred to as
“wicked problems” (Candel et al., 2014; Rittel and Webber, 1973; Termeer
et al., 2015). Being part of the food security discussions, competing policy
frames are also common in the GMO debates, marked by high salience, sci-
entific uncertainty, and ideological heterogeneity.
To approach such complexities analytically, we draw on previous fram-
ing studies that suggested subdividing the essential frames along two dimen-
sions. Eising et al. (2015) distinguish between generic and specific frames.
170 Gerard Breeman et al.

Specific frames are related to the political issue at hand, while generic frames are
more universal and can be used across different policy areas, across time, or
even in different policy contexts (De Vreese, 2005; Eising et al., 2015). Spe-
cific frames analytically focus on “issue-specific aspects of frame selection,
organization, and elaboration” (Eising et al., 2015: p. 518), whereas generic
frames only enable wide-ranging comparisons of framing activities between
issues, countries, and regions (De Vreese, 2005: p. 109). Combining both
specific and generic frames in our analysis helps us to identify the general
frames in the US and the EU, as well as the more specific characteristics
of policy framing within the US and the EU, i.e., across (Member) States.
Furthermore, Eising et al. (2015) argue that to explain how generic and specific
frames emerge and develop, one has to take into account the institutional con-
text, in which policy actors compete for their policy positions. We will,
therefore, elaborate on the institutional context first.

3.2 Institutional Context

Scholars form diverse schools of thought agree that the institutional contexts
are relevant factors explaining why specific arguments, problems, and solu-
tions feed into the political process (Hall and Taylor, 1996). We focus on
sociological institutionalism to derive expectation about how institutional
settings filter the frames that emerge in the US and the EU GMO regulation
as well as across (Member) States within these two regions. Sociological
institutionalism focuses on how organizations pursue legitimacy within a
certain environment and how they attempt to respond and adapt to these
environments (DiMaggio and Powell, 1991; Tolbert and Zucker, 1996).
Scholars of institutional theory argue that organizations and their strategies
are greatly affected by the wider institutional context in which they func-
tion. That is, organizational strategies are shaped by the institutional legacies
that mirror the culture, history, and polity. Barley and Tolbert (1997) sug-
gest that institutions can be grasped by focusing on “the history of negoti-
ations that lead to shared typifications or generalized expectations and
interpretations of behavior” (p. 94).
Main institutions comprise of the political, legal, and social institutions at
the supranational and national levels. North (1994, 1990) suggests that insti-
tutional settings can be divided into formal and informal institutions. Formal
institutions are laws, policies, and agreements that people create. Informal
institutions are the behavioral norms and values of individuals. Within for-
mal and informal institutional settings, organizations strive to survive and
Food Security and the Sustainability of GMOs 171

gain legitimacy by responding to collective interests, often with the goal of

having these interests categorized as informal practices or formal rules.
We expect that frames come about in a certain institutional context com-
prising of formal and informal institutions. Policy actors do not frame issues
in isolation; they highlight certain elements and disregard other elements
because of the rules of the games. Framing is used to promote certain policy
images “highlighting particular aspects of a perceived reality, while simulta-
neously occluding or downplaying other aspects” (Van den Brink, 2009: p.
35). Each debate has its own arena and venues, its own participants and orga-
nizations, and its own rules of the game. In other words, there is an institu-
tional context that structures the debates and makes certain types of
interactions more likely than others. Decisions about the issue are taken
at different levels or in different systems and with different authority:
“Each institutional venue is home to a different image of the same question”
(Baumgartner and Jones, 2010: p. 31).
Against this backdrop, we rely on the argument that institutional con-
texts are relevant filters for the generic and specific frames. That is, different
institutional settings provide different framing opportunities for interest
groups, NGOs, and other stakeholders (Str€ unck, 2005). We expect that dif-
ferent formal and informal institutional contexts empower different actors
(i.e., stakeholders) that gain legitimacy and influence to promote certain pol-
icy frames. As a result, policy solutions (outcomes) are based on the policy
frames through which a policy problem is constructed by legitimate actors in
a specific institutional setting (Sch€on and Rein, 1994; Shim et al., 2015).
More specifically, we expect that policy actors and their frames will differ
depending on the level in which they attempt to influence policy outcomes.
We anticipate that generic institutional frames—defined as the wide-ranging
rule system—will be mostly used at the federal (the US) and supranational
(the EU) levels. At federal or supranational level, policy actors need to coop-
erate and coordinate among themselves to influence policy outcomes. Fur-
thermore, the need for policy entrepreneurs possessing information,
technical skills, and knowledge of how to revise frames is considerably high.
At the EU level, the European Commission plays a crucial role (Daviter,
2009; Stone-Sweet et al., 2001). Eising et al. (2015) note that
“frequently, the Commission frames policy proposals in a way that is meant
to bring together the relevant political and societal actors as well as decrease
the amount of conflict between them.” As a result, these frames have to be
generic, as opposed to specific, in order to avoid potential policy conflicts
(cf. Candel et al., 2014). In a similar vein, at the federal level, core policy
172 Gerard Breeman et al.

entrepreneurs, such as independent regulatory agencies, are expected to

employ generic institutional frames.
The positions of national actors on supranational or federal policies,
however, exclusively depend on national or state interests and the degree
to which national or state level preferences deviate from general regulations
created at the supranational or federal level. This is the case as formal and
informal institutional settings vary across (Member) States. Accordingly,
their national or state level policy actors are expected to promote different
problem views and an opposition over policy solutions that originate from a
supranational or federal level. As Eising et al. (2015) suggest “taking in con-
sideration the variety of national circumstances, it is not a far leap to expect
that actors from different Member States will invoke different frames when
responding to EU policy proposals [i.e., generic institutional frames]” (p.
520).

3.3 Research Design

To gauge the relevance of the institutional context for generic and specific
framing activities, we analyze two different political systems and four
(Member) States within those two polities. The core differences in the
generic institutional frames are illustrated by comparing the institutional
contexts and emerging frames in the US and the EU. In so doing, we draw
upon multiple evidentiary sources such as primary document analysis (offi-
cial documents, e.g., regulations, formal communication documents) and
published research on this specific topic. We rely on the most similar systems
design method for our comparative analysis, i.e., the four selected cases vary
on our key explanatory variable (i.e., institutional context) but are similar in
terms of other potentially relevant explanatory factors, e.g., four states func-
tion in the multilevel systems and must comply with the supranational/fed-
eral regulations, the degree of policy complexity, scientific uncertainty, and
the number of competing policy actors. To observe which specific frames
emerge in the selected cases we rely on primary document analysis (media
reports, acts, minutes of formal and information discussion or political
debates, and policy documents).

4. GMO REGULATION IN THE US AND THE EU: GENERAL

INSTITUTIONAL FRAMES
Even though both the US and the EU emphasize their concerns about
public health, food safety, and environmental sustainability, the two regions
Food Security and the Sustainability of GMOs 173

rely on different regulatory perspectives and policy frames to address GMO

controversies. The US has, what can be called, a pro-GMO regulation
(Kreibohm, 2013). Already early in the history of GMO developments,
the US made the decision that existing legislation and existing government
departments were best placed to deal with this new technology by following
the concept of substantial equivalence: “the US says yes to GMOs unless
proven hazardous, whereas the EU says no unless they are proven safe”
( Johansson, 2012: p. 78). The US regards GM food as materially not differ-
ent from non-GM food and considers GMO technology as a sustainable
method to produce food (Dibden et al., 2013). Under this approach, the
safety of foods produced using biotechnology involves a consideration of
whether they characterize these products as a substantial equivalent to similar
traditional products. The concept of substantial equivalence originates from
the US Food and Drug Administration’s definition of “a class of new medical
devices that do not differ materially from their predecessors and, thus, do not
raise new regulatory concerns” (Doh and Guay, 2006: p. 60). This resulted
in the situation where legislation was never specifically written out for
GMOs. Consequently, the use of GMOs is constantly rising in the US.
According to US Department of Agriculture survey data (2016), the culti-
vation of genetically modified herbicide-tolerant (HT) soybeans increased
from 17% of US soybean coverage in 1997 to 68% in 2001 and 94% in
2014, 2015, and 2016. Plantings of GM corn grew from 8% of US corn acre-
age in 1997 to 19% in 2000 and 2001, and climbed to 29% in 2003 and 79%
in 2016.
The EU approach is based on the precautionary principle (PP) when it
comes to GMOs. This entails that a statistically convincing standard of proof
is required before any GM product is introduced to the market. Products are
also screened for possible hazards and a large regulatory system is being
developed in a piecemeal fashion to account for new generations of products
(Tait, 2011; Tait and Levidow, 1992). Already in the early 1970s, scientists
themselves evaluated the new technology of recombinant DNA (r-DNA) as
risky. Paired with growing societal opposition toward GM-products of any
kind, this led to the “implementation of one of the most stringent process-
based regulatory regimes world-wide” (Devos et al., 2008: p. 30). As a result,
the EU regulation on GMOs is considerably restrictive, i.e., the EU applies
legal constraints on the use of GMO, including premarket approval system,
rigorous labeling, and traceability (Barling, 2013). The prevailing GMO
policy frame emphasizes consumer protection in view of scientific uncer-
tainty and the protection of agrodiversity and sustainable food production.
174 Gerard Breeman et al.

It restricts the autonomy of GMO producers, while the autonomy of con-

sumers is relatively high (Abels, 2007; Timmermans, 2007).
These differences regarding GMOs regulation pushed the two regions
into an economic conflict. Scholars observe that the gap between the US
and the EU concerning GMO policy outputs continues to grow deeper.
This prompts the question of why GMO regulation has been so divergent
between the US and the EU. For this we turn to the institutional context and
discuss in the next section how the difference in institutions and interactions
patterns with NGOs, interest groups, and other stakeholders have led to the
divergent policy frames that directly influenced government policies in the
two regions.

4.1 The Institutional Context and Framing

The core differences in the GMO regulation between the US and the EU
originate from the different principles the two regions rely on to arrive at
their policy outputs, as well as a different set of institutional actors that
are in charge of GMO regulation. We observe that the different formal
and informal institutional settings in the US and the EU provide distinct pos-
sibilities for framing.
To begin with, the delegation of powers to independent regulatory
agencies marks an important difference in the US and the EU institutional
setting. The US agencies in charge of GMO regulation—the Environmental
Protection Agency (EPA) and the Food and Drug Administration (FDA)—
combine executive powers, legislative tools, and means of the judiciary. The
US agencies are responsible for both risk assessment and risk management of
GM products. Standards of food safety are defined at federal level and exe-
cuted by federal agencies in the states. It is important to note that the rep-
utation of agencies such as the FDA and the EPA rank high (Carpenter,
2010) and they are trusted by US citizens (Vogel, 2001).
Furthermore, due to the limited controversy surrounding the issue and
categorizing GMOs as part of traditional agriculture, Americans generally
pay little attention to the debate over genetically modified foods, despite
extensive media coverage of the issue (Branson, 2013). It seems that the gen-
eral discussion in the US remains at a regulatory level and the extensive
weighing of pros and cons in the European context have not affected con-
sumers (IFIC Foundation, 2014). Additionally, a survey, released by Rutgers
University, found that more than half of Americans (53%) say they have
never heard of genetically modified food and only about a quarter (26%)
Food Security and the Sustainability of GMOs 175

realize that current regulation does not require GM products to be labeled

(Branson, 2013).
Such institutional setting is argued to be very favorable for the biotech
industry, which provides explanation for why NGOs have been dismissed
in the US (Vogel, 1995). Furthermore, scholars in the field point to a lack
of notable biotechnology disasters that would produce political domain for
NGOs to redefine the policy problem. US consumers are less concerned
about potential health risks of GMOs, as US food safety regulation has
not experienced any major, nationwide food-related scandals and crises.
As a result, public stakeholders, such as NGOs and social activists, lack
opportunities of framing (Str€ unck, 2005). In the US, environmental groups
and public activists have fought battles in different institutional contexts if
compared to the EU (Str€ unck, 2005; Vogel, 2001).
In the EU, risk assessment and risk management duties are separated: the
European Food Safety Authority (EFSA) is responsible for risk assessments,
whereas the European Commission takes risk management decisions based
on EFSA scientific advice. Such separation of risk assessment and risk man-
agement is a distinctive feature of European consumer policy and marks a
relevant difference in GMO regulation between the US and the EU: EFSA
is denied powers its US counterparts, i.e., FDA and EPA, possess. As a result,
“US regulatory agencies clearly lead European counterparts concerning
comprehensive rulemaking” (Str€ unck, 2005: p. 209). Furthermore, all
GMOs must be approved to be safe before they are placed on the EU mar-
ket. This assessment process is conducted by EFSA in collaboration with
Member States’ scientific bodies and the European Commission decides
on authorization. It is important to note that Member States play a vital role
in the supranational regulation processes of GMOs and have the possibility
to restrict or prohibit the cultivation of GMOs in their territory even when
supranational regulators approve certain GMOs (European Commission,
2010; Directive (EU) 2015/412; Gaskell et al., 2010). Because of such for-
mal institutional setting, functional fragmentation in the EU across different
levels of policy-making is strong (Str€ unck, 2005).
Functional fragmentation has provided an access to the European polit-
ical process to many stakeholders as well as public activism. The relative
influence of environmental groups in the US and the EU adds to the expla-
nations of the variation in the framing of GMO issues. The EU, as the pri-
mary regulatory actor, plays a major role in setting common standards and
oversees legislative activities concerning GMOs. Environmental groups
relying on pressure politics played an active role in shaping a European
176 Gerard Breeman et al.

public opinion and the EU and national policies on GMOs. NGOs such as
Greenpeace and Friends of the Earth publicized information raising fears
about food safety and quality among consumers (Bonardi and Keim,
2005). Salience of the GMO issue grew and public formed negative opinions
toward GM foods, which in turn pressured European politicians to constrain
the entry of these foods into EU market. Scholars in the field claim that the
2003 decision of one of the leading manufacturers of GMO crops,
Monsanto, to leave the cereal business in Europe is a result of NGO activism
(Doh and Guay, 2006).
Important has also been the fact that much of the discussion in the EU
surrounding GMOs is shaped by past scandals affecting food safety—in par-
ticular BSE—and the risks that come with such a technology (Kreibohm,
2013). Food scandals in Europe have provided the opportunity for public
interest groups to link issues together through “frame-bridging” (Str€ unck,
2005: p. 217). Even though there is no direct link between the mad cow
disease (BSE) and GM feed, public activists used the existing concerns of
consumers to frame GMO as a major health, environmental, and agricultural
threat that could potentially result in severe food crises. NGOs largely linked
GMOs to harming sustainability in the agricultural sector while also
reminding of the fall-out of BSE. Gradually, additional and more diverse
arguments entered the debate, spanning everything from trust in scientists
to sustainability concerns in agriculture. To that end, the goal of the precau-
tionary principle, which was to reassure the public by giving them confi-
dence and reduce uncertainties, was turned on its head by public
suspicion toward scientists, policy makers, and industry due to the public
portrayal of GMOs and its development coinciding with events like BSE
and an economic crisis that put the spotlight on a wide array of environmen-
tal concerns. “Thus, at the time when GMO issues were widely publicized
from 1996, the confidence in institutions and in certain technological
advances had decreased” (Bonny, 2003: p. 53). To that end, in 2002, the
precautionary principle was formally enshrined in the EU food safety policy
by the adoption of Regulation (EC) 178/2002 (2002) which laid down gen-
eral principles and requirements of food law and established the EFSA
(Szajkowska, 2012). The principle also requires consultation of members
of the public, as Harmon (2014) points out, “public hearings were domi-
nated by recitations of the ills often attributed to genetically modified organ-
isms, or GMOs: cancer in rats, a rise in childhood allergies, out-of-control
super weeds, genetic contamination, overuse of pesticides” or the disappear-
ance of butterflies and bees.
Food Security and the Sustainability of GMOs 177

In summary, the US regulatory approach clearly differs from approaches

emphasizing consumer policy and consumer protection in the EU. While the US
relies on the “private initiative model,” the EU draws on the “consumer
organization claim model” (Hodges, 2001; Str€ unck, 2005: p. 209). US reg-
ulatory politics regarding GMOs is “characterized by the adversarial nature
of the political economy surrounding industrial regulation” (Doh and Guay,
2006: p. 60), whereas the EU regulatory setting provides more space for
NGOs advocating for the precautionary measures. However, it is important
to note that differences emerge both within the US and the EU, as differ-
ences in issue framing emerge across the (Member) States, as elaborated in
the analysis that follows.

4.2 Specific Institutional Frames

4.2.1 Austria (EU)
In 1995, Austria joined the EU and shortly after issued a GM-free labeling
regime. The regime is said to be one of the strictest in Europe, as it is
“process oriented,” controlling the whole production chain (Austrian
Federal Ministry of Health, 2013). The Austrian Gene Technology Act reg-
ulates the main aspects of biotechnology and genetic engineering at national
level. It transposes European Directives and specifies the interpretation of
some of the very specific aspects of the EU GMO regulation for the Austrian
context. It includes the use of GMOs; deliberate release of GMOs into the
environment; the placing on the market of products that contain GMOs;
and the application of biotechnology in human medicine, such as gene anal-
ysis and gene therapy (Bundesministerium f€ ur Gesundheit und Frauen,
2012). Connected to the Gene Technology Act, Austria put in place a com-
mission (Gentechnikkommission) monitoring compliance and applying
sanctions for breaches of law (idem). Throughout the years Austria has also
constantly updated its regulatory framework to account for new products
and procedures in GMO food processing.
Austria made headlines during a regulatory dispute between the
European Commission and Upper Austria. Upper Austria argued that it
could present new evidence that would prove the harmful consequences
of GMO use. The European Commission did not agree that the evidence
was sound or new and took Upper Austria to the European Court where
it was ruled that the Commission was right on all charges (Case
C-421/03, Commission of the European Communities v Republic of
Austria, 2005/C 6/27).
178 Gerard Breeman et al.

This, however, did not prevent Austria from using the safeguard clause as
a basis for a ban of GMOs in the country. The safeguard clause states that
new information linked to safety or environmental risk allows Member
States to restrict or prohibit the use or sale of GMOs (Directive (EC)
2001/18, 2001). However, limiting this clause, the European Commission
also states that “when a product containing a GMO, as or in products, is
placed on the market, and where such a product has been properly autho-
rized under this Directive, a Member State may not prohibit, restrict or
impede the placing on the market of GMOs, as or in products, which com-
ply with the requirements of this Directive” (Directive (EC) 2001/18,
2001). Austria was able to work around this restraint by pointing toward
the size of the country and the possibility of cross-pollination of GMO crops
planted anywhere in the country. In recent years, Austria went even further
by “taking advantage of the EU’s crystallizing coexistence policy and setting
up legal regimes at the regional level which, in theory, are in line with the
EU’s liberal demands but in practice prohibit it” (Seifert, 2006, 2008: p. 24).
The Ministry of Health publishes regular reports in German and English
on the developments in GMO research and European regulation in the field.
The current perspectives can be summed up as being hesitant toward GMOs
based on the limited scientific evidence of its safety. The latest report states
that the EU has moved forward in approving, for example, a certain type of
genetically modified corn, but that the Austrian government will stick to its
strict regulation, because
…the general question of whether the effector molecules produced by the appli-
cation of new techniques, e.g. siRNAs, pose risks when ingested by humans and
animals to date has not been researched sufficiently. The same applies to effects
on other organisms (e.g. insects, nematodes) that are exposed to such molecules,
including their potential transmission. In conclusion, for all new plant breeding
techniques core elements of the current risk assessment requirements for GM plants
are mandatory.
Ministry of Health (AGES) (2013): p. 2

In light of strict governmental regulations, labeling and no intention by gov-

ernment to loosen GMO laws, public opposition has been limited. Farmers
also took a backseat in public opposition to GMOs, as Austrian policy was
designed to protect particularly organic farmers (Seifert, 2008). It goes so far
that the only anti-GMO organization currently listed for Austria is “BIO
Austria.” This is a network of governmental stakeholders and organic
farmers advocating for organic, sustainable agriculture—including the non-
use of any GMOs.
Food Security and the Sustainability of GMOs 179

As Sassatelli and Scott (2001) point out, Austria not only responded to
the “real” danger to organic farming in the country, but also to the
“assumed” dangers that the public associates with GMOs. Further, Austria
linked the issue to consumption patriotism and the notion of “consumer
responsibility.” This was pursued by creating labels not only for the quality
of products, but also for their place of origin—directed toward the fear of
unlabeled US products entering the market. In short, “the consumer is
not addressed as a rational egoist but as a social agent; as a bearer of new
and old values and loyalties as well as preferences” (Sassatelli and Scott,
2001: p. 236). Overall, Austria takes organic farming as the baseline for food
production instead of traditional farming (Devos et al., 2008). In other
words, “organic farming became the sacred cow of Austrian agriculture pol-
icy so that anything that might compromise the sector tends to provoke
aversive reactions by policymakers” (Seifert, 2008: p. 35).

4.2.2 United Kingdom

The UK Foods Standards Agency is responsible for monitoring and regulat-
ing GM foods. The agency has an advisory committee on Novel Foods and
Processes (ACNFP), which is a nonstatutory, independent body of scientific
experts that advises the Food Standards Agency on any matters relating to
novel foods, including GM foods. Concerning regulatory procedures, the
UK relies on EU legislation for GMOs stating that:
The safety assessments of GM foods are carried out by the European Food Safety
Authority (EFSA), which sometimes consults the Agency. Assessments include a
detailed study of potential for toxic, nutritional and allergenic effects. Where nec-
essary, the Agency may also seek advice from the ACNFP.
Foods Standards Agency (2014)

The deliberate release of GMOs into the environment, such as GM crops for
field trials or for commercial release, is assed by a scientific committee of the
Department for Environment and Rural Affairs (DEFRA), with the release
overseen by an agency of DEFRA, under the provision of Directive EC
2001/18. For a long period, there was no clear policy on this new technol-
ogy and discussions were largely held among experts. In the late 1990s, gov-
ernment faced an impasse over regulatory decisions. The regulatory
shortcomings were magnified by a Monsanto advertising campaign in
1998, promoting GM crops as a way to reduce pesticides. This was met with
responses by NGOs, which moved the debate beyond environmental con-
cerns and emphasized food security issues. A wide range of criticism
180 Gerard Breeman et al.

followed, which targeted both the EU and UK regulatory bodies as well as

the lack of self-regulation by industry stakeholders. Adding to public con-
cerns was the outbreak of mad cow disease (BSE), which put GMO in the
same line of fears for food safety and health (Barling, 2002). After a wide
range of public criticism, government organized a consensus conference,
which led to a reinforcement of the expert/lay boundary. “This framework
implied little scope for public participation in definitions of risk or benefit,
much less in innovation priorities. Policy issues could be implicitly delegated
to expert bodies through normative assumptions in their advice” (Levidow,
2007: p. 105). Another public debate in 2003 called “GM nation?” intended
to include a wider perspective, drawing over 20,000 participants. This led to
actors capturing the issue of GMOs for other political issues. In fact, some
drew a comparison between GMOs and weapons of mass destruction, as the
discussion coincided with the US–UK attack on Iraq based on what turned
out to be false information (Levidow, 2007). Industry stakeholders also
responded by forming a network across. In an anti-GMO atmosphere, a
consortium of supermarket retailers in the UK and European countries, such
as France, Italy, and Belgium, formed an alliance to sell GMO-free products.
This, in turn, incentivized food processors as well as restaurants and catering
groups to follow suit (Barling, 2002). Among other things, these actions by
European supermarkets led to strict labeling laws in the UK, where vendors
selling unlabeled GM products can be fined up to 5000 pounds
(Herrick, 2005).
The issue of labeling further illuminates the gap between public demands
and government responses. Since 2015, the UK government is moving away
from the hard stance against GMOs by focusing on the opportunity to grow
genetically modified crops. The Science and Technology Committee UK
(2015) points out that:
…current regulations prevent EU states from making their own decisions about
whether or not to adopt GM products…The result of the risk assessment process
being politicized in this way is that applications remain trapped in the system for
years, or even decades.
Science and Technology Committee UK (2015)

The British government, unlike the Austrian government, further argues

that GMOs take on an important role in the future of agriculture. They
argue that more food production is needed globally and that GM technology
could contribute to that by providing a safe and responsible way of providing
more food, with the UK as a scientific innovator of new GM crop varieties.
Hence, the recent loosening of the European framework for GMOs is in line
Food Security and the Sustainability of GMOs 181

with the UK’s planting of GMOs for field trials, although there is no com-
mercial planting of GM crops to date in the UK. The uncertainty of a chang-
ing EU legislation and the positive attitude of the British government toward
the technology raised concerns among activists and anti-GMO groups.
These developments in combination with low levels of confidence in the
UK regulatory system in connection to GMOs have further facilitated
NGO movements, such as Greenpeace, to mobilize against GM-food.

4.2.3 Vermont (US)

Vermont is one of the smallest states of the US with a population of 600,000.
It is famous for its forests, nature, and agriculture and is the largest producer
of maple syrup in the US. Politically speaking, Vermont is known for its idi-
osyncratic positions on several issues and has a history of trailblazing single-
state decisions on larger issues such as health care, same-sex marriage, and
GMO labeling. The state has more farmers’ markets and certified organic
farms per capita than any other state:
Vermont is a heavily agricultural state that prides itself on a reputation for purity:
green mountains, real maple syrup, small dairy farms.
Hopkinson, 2016
Vermonters take our food and how it is produced seriously, and we believe we have
a right to know what’s in the food we buy.
Hopkinson, 2016

Since 1994 Vermont has been trying to set up regulation to label genetically
engineered food. At that time it passed a law requiring the labeling of dairy
products that contained a genetically engineered protein, a growth hormone
for cows. A federal court, however, deemed the law in violation with the
industry’s First Amendment rights, which says that a person or company
is not compelled to speak or give information unless there is an important
reason to do so. The court ruled that the state of Vermont cannot force com-
panies to speak about an issue, the protein, which is considered to be
completely safe for consumption.
In May 2014, the Vermont government signed a new labeling law,
which came into force in July 2016. As of that date, all products containing
GMOs had to print on their labels: “produced with genetic engineering.”
Some exemptions for dairy, meat, and certain other products were in place.
Compared to 1994, the law was better substantiated stating that labeling is
required because “genetically engineered foods potentially pose risks to
health, safety, agriculture, and the environment” (H.112 (Act 120), an act
relating to the labeling of food produced with genetic engineering). In
182 Gerard Breeman et al.

contrast to 1994, the district court of Vermont ruled that such broad con-
cerns permitted the government to compel speech and to mandate labeling
(Ben-Shahar, 2016).
One month later, however, the Vermont law was nullified by a federal
law. Under this law, all food in the US containing genetically engineered
ingredients should have either a text label, a symbol, a 1-800 telephone
number, or an electronic code that can be read by smart phones, such as
a QR code. This law creates a mandatory national label, preventing a patch-
work of state level regulations. Critics argue, however, that electronic codes
will exclude large groups, in particular low-income and rural groups and the
elderly, from having access to the actual information. Additionally, the def-
inition of GM food or the amount of GM ingredients a product should allow
to label it as GMO are much more stricter than the Vermont law. Critics of
this federal law already coined it as the DARK acr, short for short for
“Denying Americans the Right to Know” (Masterson, 2016).
The discussions preceding the GMO labeling legislation in Vermont
addressed all four controversies presented at the beginning of the chapter.
The issues raised included food safety, distrust toward multinational compa-
nies, patenting, religious concerns and the effect on the environment, focus-
ing on the use of herbicides, and the pollution of waters. These aspects were,
however, tied together under the “the right to know” campaign by the sup-
porters, which emphasized labeling and the distribution of information on
products using GMOs. In opposition to the idea of labeling, GMO friendly
groups argued that labels are only necessary when there is a threat to human
health and since this is not the case—referring to the FDA approval of
GMO—there is no reason for labeling. Developing this argument further,
GMO friendly groups highlighted the fact that a Vermont-specific legisla-
tion would create a patchwork of different regulations, and thus interfere
with interstate trading. The argument is that companies work nationwide
and products may end up in one place or the other—unintentionally violat-
ing state law. After a similar debate in Maine and Connecticut, for example,
these two states agreed that they would put their GMO labeling law into
effect only if neighboring states would have had similar rules in place.
In sum, the Vermont response to GMOs follows to a great extent the
same patterns and discussion as in other states and at the federal level.
The entire debate focused on the issue of labeling. Vermont’s policy makers
have been lobbied by the big companies with arguments that state labeling
will make interstate trade more difficult, will be expensive and increase food
prices, will result in a patchwork of regulation and labels, and labeling will be
Food Security and the Sustainability of GMOs 183

misleading because consumers will perceive it as a food safety warning.

Moreover, the opponents of labeling argued that it would be unsound if
a small state would be determining this issue for the entire country and that
forced labeling would be a breach of the first Amendment. Supporters, how-
ever, argued that already 64 countries introduced mandatory labeling which
did not result in higher prices and that mandatory labeling is necessary
because of potential health risks, meaning that labeling does not conflict with
fundamental rights. On the contrary not labeling would be a violation of the
popular “Right to Know.” More specifically, Vermont’s forerunner men-
tality, promoting itself as a green state, made the state stand out from the
other states. Or, as one of the interviewees in the economist responded:
“Vermont was the first to abolish slavery in 1777 and now we are the first
again!” (The Economist, 2014).

4.2.4 California (US)

With more than 39 million inhabitants, California has by far the biggest pop-
ulation of the US and is the third largest state in terms of size. Whereas Ver-
mont is the first and only state where a GMO labeling law came into force, it
was in California in 1987 that the first genetically modified bacteria was
released into the environment (BBC, 2002). Since then, Californian NGOs
have put the GMO issue at their front burners. When, for instance, in 2003
the GLoFish, a genetically modified fluorescent zebrafish, was brought unto
the market, California was quickly to put a ban on it.
Just like Vermont, California is known for its liberal, somewhat
“alternative” and environmental friendly society. And, just as in Vermont,
the entire GMO debate focused on the claim of consumer and environmen-
tal groups about their “right to know,” inducing a possible labeling regula-
tion. The same arguments as in Vermont were used by both the supporters
and the opponents: it would lead to higher consumer prices, stigmatize GM
food as unsafe, constrain interstate commerce, and jeopardize small retail
businesses because they would be made responsible for selling products with
the right labels. Why then did California not succeed in adopting a regula-
tion whereas Vermont did?
First of all, the way the bill was put on the agenda in California was dif-
ferent from that in Vermont. The 2012 bill for mandatory labeling was a
result of an initiative from NGOs and citizens instead of the government.
The petition was signed by 970,000 people. The ballot proposition
37 was named: The California Right to Know Genetically Engineered Food
Act. It was voted and rejected by a majority (51.4% vs 48.6%) in November
184 Gerard Breeman et al.

2012 (Ballotpedia, 2012). In the run up to the voting, the “no” campaign,
spent more than $45.6 million to highlight the negative consequences of the
labeling. The big agricultural multinationals Monsanto and Dupont contrib-
uted $8.1 million and $5.4 million, respectively. The supporters of the bill,
however, could only spent $8.7 million (idem).
The “no” campaign highlighted successfully the rising costs for con-
sumers and the burdens of a possible labeling law for small farmers and shop-
keepers. The San Bernardino Sun wrote for instance: “What a nightmare
scenario for grocers small and large who, under the terms of the initiative,
would have to keep reams of paperwork certifying that all the food they sell
is properly labeled as to which might contain genetically modified organisms
or not” (San Bernardino Sun, 2012). Importantly, the bill was also criticized
for its quality. “This initiative, as with so many initiatives, is sloppily written;
it can’t be changed after it’s passed” (Plumer, 2012). Lawmakers pointed out
that California went through a similar experience with toxic-chemical label-
ing laws. “In the end, so many warning signs got posted that they became
essentially useless” (Plumer, 2012). They expected a messy and potentially
expensive implementation due to the unclear provisions of the law. The bill
was also seriously criticized by the supporters of the labeling regulation.
Their main argument was that the bill exempts meat from animals that
are fed with GM crops. Which means that the bill would be rather weak
because most of the GM soy is used in animal feed.
A second important difference with Vermont was the strong media
attention the dispute received because of the potential impact the bill could
have had on the rest of the US. California has an economy of significance
and once the bill would have been adopted it was expected to spread all over
the country, creating a domino effect. This has already happened before
with, for instance, caged eggs. When the state of California decided to
ban caged eggs, it was quickly adopted in other states as well. Additionally,
editorials of leading newspapers such as the LA Times wondered why this
particular information about GMO is more valuable to be put on a label than
any other type of information. Genetically modified food is considered to be
safe, whereas, for instance, concerns about increasing resistance to antibiotics
would make it also reasonable to mention whether or not a product contains
elements of antibiotics.
In sum, the specific institutional pathway and context of the introduction
of the bill on the public and policy agenda as well as the economic impact
California could have had explains largely why labeling was framed as it was
and why in the end labeling was introduced in Vermont and not in Califor-
nia. After the tough campaigning of 2012, the pro and con positions were
Food Security and the Sustainability of GMOs 185

settled to such an extent that a second attempt in 2015 in the Senate to intro-
duce a labeling law failed as well. The heated disputes in California, how-
ever, ignited initiatives in other states and it was one of the reasons that the
issue was pushed higher on the agenda at the federal level which in the end
resulted in the national labeling law in 2016.

5. ANALYSIS
Both, Austria and the UK, raise concerns regarding GMOs. However,
in Austria it is the government that has been advocating for GM-free agri-
culture and even fighting legal battles with the EU in order to protect
organic farmers. As a result, organic farmers as well as anti-GMO groups
have little to oppose to since regulation is strict and not likely to change
soon. The discussion also remains in the realm of agriculture. In the UK,
on the other hand, the government welcomes the loosening of GMO reg-
ulation at European level and is envisaging to expand the GMO cultivation.
In opposition, anti-GMO groups are strong and controversy flares up reg-
ularly induced by changing EU regulation, which the UK relies on, or media
attention to the subject. The discussion also spans beyond agriculture and
includes environmental, health, and corporate power concerns. In short,
Austria runs a largely consensual and inward-looking policy when it comes
to GMOs. The loosening of EU regulation also perpetuates the argument
that Austrian farmers will remain in the position of a competitive advantage
if all of Austria is GMO-free (Seifert, 2008). The British government pur-
sued a strategy in which they marginalized critical voices early on while also
being vague about who regulates what in the field of biotechnology. Public
concerns, scientific risk assessment, and economic benefits were further sep-
arated in the discussion, increasing efforts by anti-GMO groups to link the
different aspects together.
Both Vermont and California have been critical about GMOs. All con-
troversies as discussed earlier have been put forward but in the end the entire
GMO debate in both states boiled down to the question whether to label
GMO products or not, framed as the consumer’s “right to know.” The dif-
ference, however, is that the Vermont government took the initiative to for-
mulate a labeling regulation using, in addition to the right to know, also
public health and environmental frames, whereas in California it was the
result of a citizens initiative. The latter ignited a heated debate and an expen-
sive campaign. Due to the campaigning of large GMO multinationals, the
frame that dominated was the costs of the labeling for the small shopkeepers
and interstate trading.
186 Gerard Breeman et al.

Taken together, Austria and Vermont exhibit quite similar specific insti-
tutional frames in their opposition to GMOs despite the fact that they are
situated in different larger institutional contexts. In these two examples,
the agricultural frame with an environmental and sustainability lens gives
the opportunity to shape the discussion along the lines of GMO being harm-
ful for the environment and ultimately for the wellbeing of farmers. In con-
trast, the UK also situates the GMO debate in an agricultural context, but
then from a food production perspective. This means that GMO is seen
as a tool to preserve larger amounts of crops and being able to produce more
and potentially nutrient-richer food. California is again another story.
Although the framing of the GMO debate evolved along the same lines
as it did in Austria and Vermont, the surfacing dominant framing is that
of trade and the increasing product prices due to labeling.
Whereas the debates of pro and con span across the continents, the leg-
islative output concerning GMOs is very much tied to the larger institutional
frames, existent in the US and the EU. For example, Vermont decided upon
a labeling mandate, which was overruled by the federal level after a short
period. The UK continues to plant field trials of new GM varieties as it pur-
sues its role in promoting itself as at the vanguard of scientific and techno-
logical innovation within the food security frame. Table 1 summarizes these

Table 1 General and Specific Institutional Frames in the EU and the US

General Institutional Frame Specific Institutional Frame
European Union
Austria • Precautionary principle • Agricultural and
• Consumer organization claim environmental context
model • Labeling legislation/
• Health, environmental, and constraining cultivation
agricultural threat frame
United • Agriculture and food
Kingdom production context
United States
California • Substantial equivalence • Agriculture and market
• Private initiative model context
• Economic, industry, and trade • Trading argument in the
frame context of labeling
Vermont • Agricultural and
environmental context
• Labeling legislation (short-
term)
Food Security and the Sustainability of GMOs 187

findings by comparing the general and specific institutional frames at EU and

US federal level, as well as the (Member) State discussions.
The table highlights the fact that actors within the national or state con-
text invoke frames that are determined by the closest level—that of the
nation or the state. A combination of salience and state or national regulation
shape the arguments that dominate the discussion. There is a point to be
made that this specific institutional context also sets the stage for different
groups to have a voice on the issue of GMOs. So the national or state level
institutional context both determines the visibility of certain groups as well
as the specific institutional frames they discuss. The EU and federal level
offer a mirror for shaping certain arguments. That means that if the state
or nation runs against the context given at higher level, this can be used
as a justification mechanism, either by arguing that there is a compliance
with those rules or a rebellion against them.

6. CONCLUSIONS
This chapter has explored the way in which different countries and
states frame the issue of GMOs linked to food policy within the larger insti-
tutional context of the EU and the US. We identified four controversies that
are associated with GMOs: food safety, environment, food security, and eth-
ical issues. Our analysis shows how in two EU Member States (Austria and
the UK) and two US states (Vermont and California) these controversies
have resulted in different policy outcomes.
First, it shows that all four distinguished controversies have been part of
the GMO debates on both continents. The general framing of the GM food
debates at the federal (US) and supranational (EU) levels, however, is differ-
ent. In the US, the safety of GMOs is less of an issue compared to the EU.
GMOs in the US have always been considered as materially not different
from their predecessors and thus do not need new regulations. Furthermore,
decisions about the safety of food products are rarely politicized because
there is no clear political cleavage between the political parties about GMOs.
The US further has not had major food scandals, and consumers have a high
level of trust in the US food authorities. This has resulted in a strong insti-
tutional position of the industry, who frames GMOs, at the least, as “business
as usual,” but more often as a sound and necessary technological innovation.
In contrast, the EU has had a number of food scandals, which resulted in
lower levels of consumer trust regarding the EU food authorities. The
EU policy system also leaves more room for political influence from both
environmental and consumer interests groups and Member States. This leads
188 Gerard Breeman et al.

to a situation where not only the food security frame (GMOs are good for
production) but also the public health and environmental frames are heard
louder with more impact. Within these generic framing and institutional
context, the GMO discussions in the US focused mainly on whether prod-
ucts should be labeled and what the consequences would be for the industry
and retail. Within the EU generic framing and institutional context, how-
ever, the GMO discussions in the EU have been much broader, providing
more room for different political or emotional arguments that obviously go
beyond the scientific arguments upon which the EU food safety authority
bases its advice.
Second, this chapter also shows that specific institutional factors explain
why Austria (EU) and Vermont (US) adopted constraining GMO regula-
tions and the UK (EU) and California (US) did not. Both Austria and Ver-
mont have put forward bioenvironmental farming and public health frames
to discuss GMOs. Within the general institutional context, however, Ver-
mont could only set up a state labeling regulation, whereas Austria could
take more constraining regulations such as the ban on GMO crop cultiva-
tion. The political room that the general institutional context provided in
the UK resulted, in contrast to Austria, in policies to support GMO crop
cultivation. In California, however, the labeling was voted down because
of the strong industrial and business oriented framing of the consequences
of the labeling regulation, and the lawmakers’ criticism of the quality of
the citizens’ initiative bill.

REFERENCES
Abels, G., 2007. Trade and human rights: inter and supranational regulation of ART and GM
food. In: Montpetit, E., Rothmayr, C., Varone, F. (Eds.), The Politics of Biotechnology
in North America and in Europe. Lexington Books, Lanham, MD, pp. 35–60.
Abou-Gabal, N., 2015. Understanding the Controversy and Science of GMOs. Huffington
Post. 28 July 2015. Available at http://www.huffingtonpost.com/sonimacom/gmos_b_
7880026.html. Accessed 6 May 2017.
Austrian Federal Ministry of Health, 2013. GM-Free Labelling Regime in Austria: Back-
ground, Status Quo, Visions. Presentation by Dr. Dietmar Vybiral, Dep. II/B/15 in
Budapest, 16.-17.4.2016. Available at http://gmo.kormany.hu/download/5/7d/
e0000/Dietmar%20Vybiral_AT%20presentation.pdf. Accessed 20 April 2017.
Ballotpedia, 2012. California Proposition 37, Mandatory Labeling of Genetically Engineered
Food (2012). Available at https://ballotpedia.org/California_Proposition_37,_Mandatory_
Labeling_of_Genetically_Engineered_Food_(2012). Accessed 8 May 2017.
Barley, S.R., Tolbert, P.S., 1997. Institutionalization and structuration: studying the links
between action and institution. Organ. Stud. 18 (1), 93–117.
Barling, D., 2002. The European response to GM foods: rethinking food governance.
In: Bailey, B., Lappe, M. (Eds.), Engineering the Farm: The Social and Ethical Aspects
of Agricultural Biotechnology. Island Press, Washington DC, pp. 95–111.
Food Security and the Sustainability of GMOs 189

Barling, D., 2013. 15 Regulating GM foods in the 1980s and 1990s. In: Phillips, J.,
Smith, D.F. (Eds.), Food, Science, Policy and Regulation in the Twentieth Century:
International and Comparative Perspectives. Routledge, New York, pp. 239–256.
Baumgartner, F.R., Jones, B.D., 2010. Agendas and Instability in American politics.
University of Chicago Press, Chicago.
Baumgartner, F.R., Mahoney, C., 2008. Forum section: the two faces of framing individual-
level framing and collective issue definition in the European Union. Eur. Union Politics
9 (3), 435–449.
BBC, 2002. GM Crops: A bitter Harvest? BBC News. 14 June 2002. Available at http://
news.bbc.co.uk/2/hi/science/nature/2045286.stm. Accessed 7 May 2017.
Ben-Shahar, O., 2016. Vermont’s GMO Labeling Law Violates the First Amendment. For-
bes. 1 June 2016, Available at https://www.forbes.com/sites/omribenshahar/2016/06/
01/gmo-science-and-the-constitution-vermonts-labeling-law-violates-the-first-
amendment/#4ebc927251f1. Accessed 7 May 2017.
Bundesministerium f€ €
ur Gesundheit und Frauen, 2012. Rechtsvorschriften in Osterreich,
Gentechnikgesetz. Available at http://www.bmgf.gv.at/home/Gesundheit/Gentechnik/
Rechtsvorschriften_in_Oesterreich/. Accessed 28 April 2017.
Bonardi, J.P., Keim, G.D., 2005. Corporate political strategies for widely salient issues. Acad.
Manage. Rev. 30 (3), 555–576.
Bonny, S., 2003. Why are most Europeans opposed to GMOs? Factors explaining rejection
in France and Europe. Electron. J. Biotechnol. 6 (1), 50–71.
Bovay, J., Alston, J.M., 2016. GM labeling regulation by plebiscite: analysis of voting on
proposition 37 in California. Agric. Resour. Econ. Rev. 41 (2), 161–188.
Branson, K., 2013. Most Americans Pay Little Attention to Genetically Modified Foods, Sur-
vey Says. Rutgers Today. 1 November 2013. Available at http://news.rutgers.edu/
research-news/most-americans-pay-little-attention-genetically-modified-foods-
survey-says/20131101#.WQcgJVWLS70. Accessed 28 April 2017.
Candel, J.J., Breeman, G.E., Stiller, S.J., Termeer, C.J., 2014. Disentangling the consensus
frame of food security: the case of the EU Common Agricultural Policy reform debate.
Food Policy 44, 47–58.
Carpenter, D., 2010. Reputation and Power: Organizational Image and Pharmaceutical
Regulation at the FDA. Princeton University Press, Princeton, New Jersey.
Daviter, F., 2009. Schattschneider in Brussels: how policy conflict reshaped the biotechnol-
ogy agenda in the European Union. West Eur. Politics 32 (6), 1118–1139.
De Vreese, C.H., 2005. News framing: theory and typology. Inf. Des. J. Doc. Des. 13 (1),
51–62.
Devos, Y., Cougnon, M., Vergucht, S., Bulcke, R., Haesaert, G., Steurbaut, W.,
Reheul, D., 2008. Environmental impact of herbicide regimes used with genetically
modified herbicide-resistant maize. Transgenic Res. 17 (6), 315–316.
Dibden, J., Gibbs, D., Cocklin, C., 2013. Framing GM crops as a food security solution.
J. Rural. Stud. 29, 59–70.
DiMaggio, P.J., Powell, W.W. (Eds.), 1991. The New Institutionalism in Organizational
Analysis. University of Chicago Press, Chicago, IL.
Doh, J.P., Guay, T.R., 2006. Corporate social responsibility, public policy, and NGO activ-
ism in Europe and the United States: an institutional-stakeholder perspective. J. Manag.
Stud. 43 (1), 47–73.
The Economist, 2014. Vermont v Science: The Little State That Could Kneecap the Biotech
Industry. The Economist. 10 May 2014. Available at http://www.economist.com/
news/united-states/21601831-little-state-could-kneecap-biotech-industry-vermont-
v-science. Accessed 7 May 2017.
Eising, R., Rasch, D., Rozbicka, P., 2015. Institutions, policies, and arguments: context and
strategy in EU policy framing. J. Eur. Publ. Policy 22 (4), 516–533.
190 Gerard Breeman et al.

European Commission, 2015. Directive (EU) 2015/412 of the European Parliament and of
the Council of 11 March 2015 Amending Directive 2001/18/EC as Regards the Pos-
sibility for the Member States to Restrict or Prohibit the Cultivation of Genetically Mod-
ified Organisms (GMOs) in Their Territory Text With EEA Relevance. Off. J. Eur.
Union L 68 (4), 1–8.
European Commission, 2010. A Decade of EU-Funded GMO Research (2001
2010).
Directorate-General for Research and Innovation Directorate E—Biotechnologies,
Agriculture, Food, EUR 24473. Available at http://ec.europa.eu/research/biosociety/
pdf/a_decade_of_eu-funded_gmo_research.pdf. Accessed 8 May 2017.
European Commission, 2002. Regulation (EC) 178/2002 of the European Parliament and of
the Council of 28 January 2002 laying down the general principles and requirements of
food law, establishing the European Food Safety Authority and laying down procedures
in matters of food safety. Off. J. Eur. Union L 31, 1–24.
European Commission, 2001. Directive (EC) 2001/18 of the European Parliament and of
the Council of 12 March 2001 on the deliberate release into the environment of genet-
ically modified organisms and repealing council directive 90/220/EEC. Off. J. Eur.
Union L 106, 1–39.
Foods Standards Agency, 2014. GM Foods. FSA. Available at https://www.food.gov.uk/
science/novel/gm. Accessed 19 June 2017.
Fox, M., 2015. There’s No Need to Label GMO Plants, FDA Says. NBC News. 23 Novem-
ber 2015. Available at http://www.nbcnews.com/health/health-news/theres-no-need-
label-gmo-plants-fda-says-n468301. Accessed 7 May 2017.
Gaskell, G., Bauer, M.W., Durant, J., Allum, N.C., 1999. Worlds apart? The reception of
genetically modified foods in Europe and the US. Science 285 (5426), 384–387.
Gaskell, G., Stares, S., Allansdottir, A., Allum, N., Castro, P., Esmer, Y., Fischler, C.,
Jackson, J., Kronberger, N., Hampel, J., Mejlgaard, N., Quintanilha, A.,
Rammer, A., Revuelta, G., Stoneman, P., Torgeresen, H., Wagner, W., 2010. Euro-
pean and Biotechnology in 2010, Winds of Change? A Report to the European Com-
mission’s Directorate-General for Research, October 2010, EUR 24537 EN. .
Gerry, C., 2015. Feeding the World One Genetically Modified Tomato at a Time:
A Scientific Perspective. Blog, Special Edition on GMOs, Harvard University. August
9, 2015. Available at http://sitn.hms.harvard.edu/flash/2015/feeding-the-world/.
Accessed 7 May 2017.
Hall, P.A., Taylor, R.C., 1996. Political science and the three new institutionalisms. Pol.
stud. 44 (5), 936–957.
Harmon, A., 2014. A Lonely Quest for Facts on Genetically Modified Crops. International
New York Times. 04/01/2014. Available at http://nyti.ms/19V4ygW. Accessed 28
April 2017.
Herrick, C.B., 2005. Cultures of GM: discourses of risk and labelling of GMOs in the UK and
EU. Area 37 (3), 286–294.
Hilbeck, A., Binimelis, R., Defarge, N., Steinbrecher, R., Szekács, A., Wickson, F., …
Novotny, E., 2015. No scientific consensus on GMO safety. Environ. Sci. Eur.
27 (1), 4.
Hodges, C., 2001. Multi-party actions: a European approach. Duke J. Comp. Int. Law
11, 321–354.
Hopkinson, J., 2016. How Vermont Beat Big Food: One State With 600,000 People and An
Anti-GMO Streak is About to Rewrite U.S. Food Labels. What Just Happened?
Politico. 17 March 2016. Available at http://www.politico.com/agenda/story/2016/
03/vermont-gmo-labeling-law-national-standard-000067. Accessed 2 May 2017.
International Agency for Research on Cancer (IARC), 2017. Some Organophosphate Insec-
ticides and Herbicides: Monographs on the Evaluation of Carcinogenic Risks to
Humans. IARC, vol. 112.
Food Security and the Sustainability of GMOs 191

International Food Information Council (IFIC), 2014. Consumer Perceptions of Food Tech-
nology Survey. May 2014, Washington DC. Available at http://www.foodinsight.org/
sites/default/files/FINAL%20Full%20Report_IFIC%202014%20Food%20Tech%
20Survey.pdf. Accessed 28 April 2017.
Jacobsen, S.E., Sørensen, M., Pedersen, S.M., Weiner, J., 2013. Feeding the world: genet-
ically modified crops versus agricultural biodiversity. Agron. Sustain. Dev. 33 (4),
651–662.
Johansson, A., 2009. Biopolitics and reflexivity: a study of GMO policymaking in the Euro-
pean Union Doctoral dissertation. Link€ oping University Electronic Press. Available at
http://www.diva-portal.org/smash/get/diva2:209628/FULLTEXT01.pdf. Accessed 1
October 2017.
Johansson, A., 2012. Pragmatism revisited: an overview of the development of regulatory
regimes of the GMOs in the European Union. In: Howlett, M., Laycock, D. (Eds.),
Regulating Next Generation Agri-Food Biotechnologies. Routledge, New York,
pp. 73–92.
Kreibohm, L., 2013. Who’s Afraid of GMOs? Understanding the Differences in the Regu-
lation of GMOs in the United States and European Union. American Institute for Con-
temporary German Studies, AICGS Issue Brief 44. Available at http://www.aicgs.org/
site/wp-content/uploads/2013/08/Issue-Brief-44_GMOs1.pdf. Accessed 28 April
2017.
Levidow, L., 2007. European public participation as risk governance: enhancing democratic
accountability for agbiotech policy? East Asian Sci. Technol. Soc. Int. J. 1, 19–51.
L€ofstedt, R.E., Vogel, D., 2001. The changing character of regulation: a comparison of
Europe and the United States. Risk Anal. 21 (3), 399–416.
Masterson, K., 2016. Congress Passes A GMO Labeling Bill That Nullifies Vermont’s Law.
VPR News. 15 July 2016. Available at http://digital.vpr.net/post/congress-passes-gmo-
labeling-bill-nullifies-vermonts-law#stream/0. Accessed 7 May 2017.
McAdam, D., McCarthy, J.D., Zald, M.N., 1996. Comparative Perspectives on Social
Movements: Political Opportunities, Mobilizing Structures, and Cultural Framings.
Cambridge University Press, Cambridge.
Ministry of Health (AGES), 2013. New Plant Breeding Techniques. RNA-dependent
Methylation, Reverse Breeding, Grafting. Federal Ministry of Health, Vienna.
Montpetit, E., Rothmayr, C., Varone, F. (Eds.), 2006. The Politics of Biotechnology in
North America and Europe: Policy Networks, Institutions and Internationalization.
Lexington Books, Lanham.
North, D.C., 1990. Institutions, Institutional Change and Economic Performance.
Cambridge university press, Cambridge.
North, D.C., 1994. Economic performance through time. Am. Econ. Rev. 84 (3), 359–368.
Plumer, B., 2012. Everything you Need to Know About California’s Genetically Modified
Food Fight, in One Post. The Washington Post. online, 3 November 2012. Available at
https://www.washingtonpost.com/news/wonk/wp/2012/11/03/everything-you-
need-to-know-about-californias-genetically-modified-food-debate-in-one-post/?
utm_term¼.7265f4b4ed17. Accessed 19 June 2017.
Rangel, G., 2015. From Corgis to Corn: A Brief Look at the Long History of GMO Tech-
nology. Blog, Special Edition on GMOs. Harvard University, 9 August 2015. Available
at http://sitn.hms.harvard.edu/flash/2015/from-corgis-to-corn-a-brief-look-at-the-
long-history-of-gmo-technology/. Accessed 7 May 2017.
Rein, M., 1983. From Policy to Practice. Me Sharpe, New York.
Rittel, H.W., Webber, M.M., 1973. Dilemmas in a general theory of planning. Pol. Sci.
4 (2), 155–169.
San Bernardino Sun, 2012. Endorsement: No on Prop. 37; More Information is Good, but
Rampant Litigation Isn’t. The San Bernardino Sun. 10 January 2012. Available at http://
192 Gerard Breeman et al.

www.sbsun.com/general-news/20121001/endorsement-no-on-prop-37-more-
information-is-good-but-rampant-litigation-isnt. Accessed 7 May 2017.
Sarich, C., 2014. 8 Proofs we Don’t Need GMOs to Feed the World: Key Research Shows
we Don’t Need GMOs to Feed the World. Natural Society. 04 November 2014.
Available at http://naturalsociety.com/proof-dont-need-gmo-feed-world/. Accessed 7
May 2017.
Sassatelli, R., Scott, A., 2001. Novel food, new markets and trust regimes: responses to the
erosion of consumers’ confidence in Austria, Italy and the UK. Eur. Soc. 3 (2), 213–244.
Sch€on, D.A., Rein, M., 1994. Frame Reflection: Toward the Resolution of Intractable Pol-
icy Controversies. Basic Books, New York.
Science and Technology Committee UK, 2015. EU Regulation on GM Organisms not ‘Fit
for Purpose’. Commons Select Committee, UK Parliament. Available at http://www.
parliament.uk/business/committees/committees-a-z/commons-select/science-and-
technology-committee/news/report-gm-precautionary-principle/. Accessed 26 May
2017.
Seifert, F., 2006. Regional GM opposition as multilevel challenge? The case of upper Austria.
Tailoring Biotechnol. 2 (3), 11–36.
Seifert, F., 2008. Consensual NIMBYs, contentious NIABYs: explaining contrasting forms
of farmers GMO opposition in Austria and France. Sociol. Rural. 49 (1), 20–40.
Shim, J., Park, C., Wilding, M., 2015. Identifying policy frames through semantic network
analysis: an examination of nuclear energy policy across six countries. Pol. Sci. 48 (1),
51–83.
Shiva, V., Barker, D., Lockhart, C., 2011. The GMO Emperor has no Clothes: A Global
Citizens Report on the State of GMOs—False Promises, Failed Technologies. Synthesis
Report. Navdanya International.
Skogstad, G., 1998. Ideas, paradigms and institutions: agricultural exceptionalism in the
European Union and the United States. Governance 11 (4), 463–490.
Snell, C., Bernheim, A., Berge, J.B., Kuntz, M., Pascal, G., Paris, A., Ricroch, A.E., 2012.
Assessment of the health impact of GM plant diets in long-term and multigenerational
animal feeding trials: a literature review. Food Chem. Toxicol. 50 (3), 1134–1148.
Stone-Sweet, A., Sandholtz, W., Fligstein, N., 2001. The Institutionalization of Europe.
Oxford University Press, Oxford.
Str€
unck, C., 2005. Mix-up: models of governance and framing opportunities in US and EU
consumer policy. J. Consum. Policy 28 (2), 203–230.
Szajkowska, A., 2012. Regulating Food Law: Risk Analysis and the precautionary Principle
as General Principles of EU Food Law. Wageningen Academic Publishers, Wageningen.
Tait, J., Levidow, L., 1992. Proactive and reactive approaches to risk regulation: the case of
biotechnology. Futures 219–231, April.
Tait, J., 2011. More faust than Frankenstein: the European debate about the precautionary
principle and risk regulation for genetically modified crops. J. Risk Res. 4 (2), 175–189.
Termeer, C., Dewulf, A., Breeman, G., Stiller, S.J., 2015. Governance capabilities for dealing
wisely with wicked problems. Adm. Soc. 47 (6), 680–710.
Timmermans, A., 2007. Accomodation, bureaucratic politics, and supranational Leviathan:
ART and GMO policy-making in the Netherlands. In: Montpetit, E., Rothmayr, C.,
Varone, F. (Eds.), The Politics of Biotechnology in North America and in Europe.
Lexington Books, Lanham, MD, pp. 193–214.
Tolbert, P.S., Zucker, L.G., 1996. The institutionalization of institutional theory. In: -
Clegg, S.R., Hardy, C., Norde, W.R. (Eds.), A Handbook of Organizational Studies.
Thousand Oaks, London, pp. 169–184.
US Department of Agriculture, 2016. Recent Trends in GE Adoption. Washington DC.
November 2016. Available at https://www.ers.usda.gov/data-products/adoption-of-
Food Security and the Sustainability of GMOs 193

genetically-engineered-crops-in-the-us/recent-trends-in-ge-adoption.aspx. Accessed 3
May 2017.
Van den Brink, M., 2009. Rijkswaterstaat on the Horns of a Dilemma. Eburon, Delft.
Vogel, D., 2001. The New Politics of Risk Regulation in Europe. Discussion Paper
3London School of Economics and Political Science.
Vogel, D., 1995. Trading up: Consumer and Environmental Regulation in a Global Econ-
omy. Harvard University Press, Cambridge, MA.
von Braun, J., 2010. Food insecurity, hunger and malnutrition: necessary policy and tech-
nology changes. N. Biotechnol. 27 (5), 449–452.
Wang, G.D., Zhai, W., Yang, H.C., Fan, R.X., Cao, X., Zhong, L., Poyarkov, A.D., 2013.
The genomics of selection in dogs and the parallel evolution between dogs and humans.
Nat. Commun. 4, 1860.
World Health Organization (WHO), 2014. Frequently Asked Questions on Genetically
Modified Foods—May 2014. Available at http://www.who.int/foodsafety/areas_
work/food-technology/Frequently_asked_questions_on_gm_foods.pdf?ua¼1.
Accessed 6 May 2017.
Zimmer, C., 2013. From Fearsome Predator to Man’s Best Friend. New York Times.
16 May 2013. Available at http://www.nytimes.com/2013/05/16/science/dogs-
from-fearsome-predator-to-mans-best-friend.html?_r¼0&adxnnl¼1&ref¼science&
adxnnlx¼1368713430-N272zh4+W5fjM4y0hFrmqg. Accessed 6 May 2017.

FURTHER READING
European Council, 1990. Council Directive 90/220/EEC of 23 April 1990 on the Deliberate
Release Into the Environment of Genetically Modified Organisms. Off. J. L 117, 15–27.