December 7, 2001

To: Ms. Ivana Jelenic and Ms. Jasminka Radovic

Department of Biodiversity and Leadership Protection

Ministry for Environmental Protection and Physical Planning

Tel: 6106-551

Fax: 6118-388

Dear Ms. Jelenic and Ms. Radovic:

We received a copy of the letter dated November 29, 2001 from Jill F. Byrnoa, First Secretary of the Political-Economic Section of the U.S. Embassy in Zagreb. We are deeply concerned that the positions detailed in the letter do not accurately reflect the positions held by the U.S. government or its citizenry.

Croatia's proposed ban or restriction on the importation, marketing, use and production of genetically modified organism and products has broad support within the United States. It is our opinion that the reference to the United States' rights under the WTO in the letter is an inappropriate use of political power. The SPS agreement does allow members to "provisionally adopt sanitary or phytosanitary measures on the basis of available pertinent information" in cases "where relevant scientific evidence is insufficient." (Article 5.7).

It is not difficult to make the case that scientific evidence is lacking with respect to genetically engineered crops and foods. The U.S. government does very little to regulate or oversee the introduction of agricultural biotechnology products. The U.S. Food and Drug Administration does not require health or safety testing prior to approvals, unless the manufacturer of a particular genetically engineered product voluntarily informs the FDA of possible risks.

Since 1996, over 28,000 open field test sites of experimental biotech varieties have been permitted. Information regarding the location and specific attributes of these experimental varieties is considered proprietary in the U.S., and unapproved varieties that have not undergone significant testing and evaluation are left to cross-pollinate with conventional varieties, without any substantive way of determining the potential negative effects on human or animal health or the environment.

In the United States, farmers, consumers, processors, and many government officials are concerned about the lack of oversight and testing of genetically modified organisms and the potential impacts on the environment and human health. We have attached a letter from U.S. Senate Majority Leader Thomas Daschle which clearly demonstrates that the positions described to you by Jill F. Byrnea do not accurately reflect the views of the entire U.S. government or its citizens.

We strongly encourage the Croatian Government to implement EU biotech directives as quickly as possible. The EU has taken a responsible approach to biotechnology that balances the interests of consumers, producers and industry. Their implementation will facilitate the development food security and expedite the accession of Croatia into the EU.

Please feel free to contact us if you would like further information.

Sincerely,

Kristin Dawkins

Vice President for International Programs

Institute for Agriculture and Trade Policy