Europe’s approach to crop biotechnology is changing. New Genomic Techniques (NGTs) — including gene editing — are increasingly seen as tools to accelerate development of climate-resilient, nutrient-rich, and pest-resistant crops. But regulatory direction across the region remains uneven. The UK has already implemented a new legal framework, the EU is still negotiating its proposal, and Switzerland is developing a separate risk-based model.
A press release published by ISAAA unpacks what that divergence means for innovation, breeders and farmers. A must-read as Europe redefines its biotech future.
UK: Precision Breeding Framework Now in Force
The United Kingdom is the first major European economy to fully implement a dedicated regulatory pathway for gene-edited crops. The Genetic Technology (Precision Breeding) Act, passed on March 23, 2023, was activated through the Genetic Technology (Precision Breeding) Regulations 2025, which took effect on November 13, 2025.
Under the UK’s system, Precision-Bred Organisms (PBOs) are not regulated as traditional GMOs if the genetic changes could have occurred naturally or through conventional breeding. The framework introduces a simplified notification process for research and marketing, intended to speed innovation while maintaining oversight for more complex genetic modifications.
EU: NGT Proposal Enters Final Negotiations
In the European Union, regulatory reform gained urgency after the 2018 European Court of Justice ruling that placed NGTs under GMO legislation. In response, the European Commission released its NGT proposal in July 2023, introducing a two-tier system:
Category 1 NGT plants: treated similarly to conventional crops and exempt from key GMO requirements
Category 2 NGT plants: subject to risk assessment and authorization, with continued labeling requirements
As of early 2025, the proposal is in the final legislative phase, with trilogue negotiations underway between the European Commission, Parliament, and Council. Key issues include labeling, traceability, coexistence, and patent policy. Patents remain the most contested topic, with Parliament proposing restrictions that industry groups argue could weaken investment and innovation.
Switzerland: Draft Law Proposes Risk-Based Approach
Switzerland is pursuing its own framework. In April 2025, the Federal Council introduced a draft Breeding Technologies Act (BTA) to ease restrictions on plants developed using techniques such as CRISPR. Unlike the UK model—and unlike the EU’s proposed Category 1 exemption—the Swiss draft keeps a stronger precautionary structure, requiring risk assessment for new NGT plants unless prior assessments justify a waiver.
Outlook
Across Europe, the regulatory environment is shifting from precaution toward more differentiated, science-based oversight. The UK framework is already operational. The EU’s final decision will determine how widely gene-edited crops can move into the European market and may influence policy across global trade partners. Switzerland’s approach reflects continued emphasis on risk evaluation and consumer choice.
