Science Speaks
The Great Gene-Editing Divide: Europe’s Race to Regulate Next Generation Crops

The Great Gene-Editing Divide: Europe’s Race to Regulate Next Generation Crops

By Clement Dionglay

December 3, 2025

The landscape of agricultural innovation in Europe is undergoing its most significant transformation in decades. New Genomic Techniques (NGTs)—including highly precise tools such as gene editing—promise to fast-track the development of resilient, sustainable crops. However, the path to the field is anything but unified. As the European Union struggles toward a common framework, the United Kingdom has already drawn a clear line as the lead with a fully enforced law, and non-EU members like Switzerland are charting their own cautious course.

The UK in the Lead: Precision Breeding Now a Law

The United Kingdom has established itself as the first major European economy to fully adopt a science-based regulatory framework for gene-edited crops. On March 23, 2023, the Genetic Technology (Precision Breeding) Act was passed into law. Its implementing regulations, the Genetic Technology (Precision Breeding) Regulations 2025, officially came into effect on November 13, 2025, launching a new, streamlined system.

The core principle of the UK's Precision Breeding Act is that organisms developed using gene-editing technologies (known as Precision-Bred Organisms, or PBOs) should not be regulated as traditional Genetically Modified Organisms (GMOs) if the resulting genetic change could have occurred naturally or through conventional breeding.

This new framework introduces a simpler notification system for PBOs used in research and marketing, moving them out of the stringent, decades-old GMO regime inherited from the EU. The goal is to accelerate the development of crops that are drought and disease resistant, healthier (e.g., biofortified foods), and require less use of pesticides and fertilizers.

Scientists and breeders can now submit applications to register these new crop varieties, paving the way for advanced farming solutions. The UK's move is being hailed as a historic milestone for agriculture, providing a clear and long-awaited path to market for innovative projects. The new policy is expected to accelerate the development of a wide range of improved crops already in the pipeline. Potential early applications include higher-yielding strawberries, nutritionally enhanced oilseeds, and disease-resistant sugar beet and potatoes.

By allowing the rapid creation of crops that require fewer inputs and are more resilient to climate change, experts believe precision breeding will help the UK produce healthier food, reduce food waste, and lead the world in sustainable, science-based farming. Political support for the Act remains strong, reflecting a decisive shift in public and political opinion toward science-based solutions for global food challenges.

While the Act is law in England, the devolved governments of Scotland and Wales have chosen to continue regulating gene-edited organisms under the existing, strict GMO rules, creating a fragmented regulatory map within the UK itself.

EU's Battle for a Breakthrough: The NGT Proposal

In the European Union, the push for modernization began after the 2018 European Court of Justice (ECJ) ruling, which classified NGTs under the same strict rules as traditional GMOs.

In July 2023, the Commission released the Proposal on New Genomic Techniques (NGTs) and Plant Reproductive Material (PRM). The proposal, suggested by the Council of the European Union in 2019, is meant to create a significant impact on Europe's seed companies, farmers, and vegetable growers. The proposal seeks to create a two-tier system for plants developed through targeted mutagenesis or cisgenesis:

NGT Category 1 Plants: These are plants deemed equivalent to conventional crops because their modifications are minor (e.g., limited to a maximum of 20 genetic changes). Under the proposal, these plants would be exempted from the requirements of the existing GMO legislation, including mandatory labeling on the final product.
NGT Category 2 Plants: These are all other NGT plants. They would still require risk assessment and authorization, but under a potentially faster, more proportionate process than the current GMO rules, and would still require mandatory labeling.

Current Update and the Patent Standoff

As of early 2025, the legislative process is in the final stages of intense negotiation. Both the European Parliament and the Council of the EU (Member States) have adopted their negotiating mandates. This has opened the door for "trilogue" negotiations to agree on the final text of the law. Trilogue negotiations on the EU Proposal involve the European Commission, the European Parliament, and the Council of the EU. These negotiations aim to finalize a common text for the regulation of NGT plants and their products.

The key issues being addressed in the trilogue negotiations include patenting, traceability and labeling, risk assessment, and coexistence. A major point of contention delaying the final agreement is the issue of patents. The European Parliament, in particular, has pushed for a highly controversial amendment: a ban on patenting NGT plants and their genetic traits. Proponents of the ban argue it would protect farmers and traditional breeders from monopolistic control, while industry groups warn it would stifle investment and innovation in Europe. The outcome of the trilogue negotiations will determine whether the EU can successfully move away from its restrictive 2018 ruling.

In November 2025, Euroseeds, together with European farmers and agri-cooperatives group Copa and Cogeca, released a joint Letter that highlighted the importance of a science-based and innovation-friendly regulatory framework for NGT plants. An Open Letter was also released, signed by a coalition of 26 food and feed associations, urging the swift adoption of New Genomic Techniques and calling the European Parliament to avoid new restrictions and to finalize an agreement with the Council and the Commission.

Switzerland’s Risk-Based Approach

In April 2025, Switzerland, which is neither an EU member nor adopting the UK's framework, is proposing its own distinct path defined by a principle of precaution. Switzerland's Federal Council released a proposal for the Breeding Technologies Act (BTA) to ease restrictions on plants developed through new genomic techniques such as CRISPR. The bill also aims to strengthen Switzerland's position as a hub for agricultural innovation and cultivation.

The current Swiss law, the Federal Act on Non-Human Gene Technology, is stringent. While the government has discussed proposals to relax NGT regulations, its approach remains more conservative than the EU's planned "NGT 1 exemption."Switzerland’s position, as outlined in legislative drafts, is unique:

No General Exemption: Unlike the EU's Category 1, the Swiss framework requires that every new NGT plant must undergo a risk assessment.
Conditional Waiver: A risk assessment may only be waived if another NGT plant of the same species and with the same type of genetic changes has already successfully passed a safety assessment.
Focus on 'Dignity of Living Beings': Swiss law incorporates a clause requiring respect for the dignity of living beings, which must be considered in the context of genetic modifications.

This measured approach aims to ensure that no untested NGT product reaches the market, prioritizing biosafety and consumer freedom of choice over rapid deregulation.

European Consensus Shifts

Across the continent, the regulatory mood is shifting from outright prohibition to careful acceptance. The UK has provided a clear-cut model for deregulation, focusing on the product (what the plant is) rather than the process (how it was made).

Meanwhile, the 27 member states of the EU are grappling with the fundamental question of how to balance innovation—which is critical for climate-resilience and food security goals—with established principles of precaution, traceability, and consumer choice. The emerging rules will define Europe’s ability to compete in global agricultural technology. The outcome of the EU's trilogue on the NGT proposal, expected to conclude soon, will set the trajectory for gene-edited crops across the continent for years to come.

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