4  I  SEED WORLD EUROPE  I  SEEDWORLD.COM/EUROPE | OCTOBER 2026
EDITOR’S MESSAGE
EUROPE’S 20-NUCLEOTIDE HANDBRAKE
BY: MARCEL BRUINS
E
urope has finally moved on New 
Genomic Techniques (NGTs), and 
for that the seed sector should allow 
itself a moment of cautious celebration. 
After years of legal uncertainty, political 
wrangling and the long shadow of the 
GMO debate, the EU is preparing to 
create a dedicated framework for plants 
obtained through targeted mutagenesis and 
cisgenesis.
That is no small thing. For plant breed­
ers, it means that not every gene-edited 
plant will automatically be pushed into the 
full machinery of GMO legislation. Some 
NGT plants will be recognised as suffi­
ciently equivalent to conventionally bred 
plants and will follow a lighter route. 
Yet the celebration comes with a 
familiar European footnote. The door has 
opened, but someone in Brussels is standing 
beside it with a ruler.
At the heart of the regulation is a 
two-category system. Category 1 NGT 
plants are those considered equivalent 
to plants that could occur naturally or be 
obtained through conventional breed­
ing. These plants will not be regulated as 
GMOs, although they will still require 
verification. Category 2 covers the rest: 
NGT plants that fall outside the Category 
1 criteria and therefore remain subject to 
GMO-style authorisation, risk assessment, 
labelling, traceability.
The trouble is that the fast lane may be 
rather narrow.
One of the most discussed limits is the 
famous, or perhaps infamous, 20-nucleo­
tide threshold. Under the Category 1 cri­
teria, certain substitutions or insertions 
may involve no more than 20 nucleotides. 
There are also limits on the number of 
modifications. Deletions are treated differ­
ently and can be larger, which gives breed­
ers some useful room for gene knockouts 
and gene silencing. But for insertions and 
substitutions, the 20-nucleotide bound­
ary has become the symbolic fence around 
European comfort.
This is where the regulation starts to 
look less like a scientific tool and more like 
a policy compromise wearing a lab coat.
Twenty nucleotides may sound precise, 
but precision is not the same as wisdom. 
Plant genomes are not tidy filing cabinets 
where disruption can be predicted solely by 
measuring the length of an edit. A small 
change can have a large effect. Natural 
variation, conventional mutagenesis and 
ordinary breeding can produce genetic 
differences far beyond what this threshold 
appears willing to tolerate.
From a breeding perspective, that 
is the frustration. The problem is that it 
has created a Category 1 route and then 
surrounded it with restrictions that may 
exclude useful, safe and urgently needed 
innovations.
The herbicide tolerance exclusion 
is another example. It simply moves the 
plant out of Category 1. The same applies 
to traits involving the production of a 
known insecticidal substance. This is why 
some critics from the innovation side say 
Europe is still working with one hand tied 
behind its back. The new framework may 
allow many SDN1-type outcomes, where 
a small targeted mutation is introduced 
without adding new genetic material. But 
more precise sequence changes associated 
with SDN2, and larger insertions associated 
with SDN3, are far more likely to fall into 
Category 2. 
For readers allergic to gene-editing 
alphabet soup, SDN1, SDN2 and SDN3 
are best understood as different levels 
of editing. SDN1 is like making a small, 
targeted change. SDN2 can make a more 
directed correction or replacement using a 
repair template. SDN3 can introduce larger 
pieces of genetic material. 
The future of plant breeding will 
not only be about making tiny changes. 
Breeders will need a wide toolbox to 
develop varieties that can cope with heat, 
drought, salinity, emerging pests, changing 
disease pressure, reduced inputs and shift­
ing consumer expectations. Some valuable 
traits will fit neatly within Category 1. 
Others will not. 
But policy should not rely on breeders 
being forced to perform regulatory gymnas­
tics. The purpose of modernising the law 
should be to enable responsible innovation, 
not to reward only those innovations that 
can squeeze through a molecular keyhole.
The irony is that the EU itself rec­
ognises the central scientific point. Some 
NGT changes are indistinguishable from 
changes that could arise naturally or 
through conventional breeding. Yet having 
accepted that principle, the regulation then 
becomes nervous and starts counting nucle­
otides as if plant breeding were a game of 
regulatory Jenga.
Pull out the right 20 pieces, and 
everything is fine. Add one too many, and 
the tower must be inspected under GMO 
rules.
The seed sector can welcome the mile­
stone and still criticise the handbrake. The 
20-nucleotide threshold may have been 
designed as a reassurance mechanism. But 
reassurance has a cost when it becomes 
over-engineered. If the threshold excludes 
too many useful innovations, it will not 
merely classify technologies.
Europe has taken an important step. It 
has been recognised that not all gene-edited 
plants should be treated like classical GMOs. 
But by building a fast lane with a 20-nucle­
otide speed bump, trait exclusions, and a 
lingering fear of broader precision breeding, 
Europe may still be doing what it has done 
too often in agricultural innovation: moving 
forward while pressing the brake.
For plant breeders, the message is 
therefore mixed. Welcome to the future, 
but please keep your edits short.   
Marcel Bruins
editorial director, Seed World Europe
mbruins@seedworldgroup.com
This column is an abbreviated version 
of an article previously published on 
Seed World Europe. For the full version, 
scan the QR code.

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