68 pages of “listening”, zero pages of action – what Defra’s report on PBO seeds reveals

October 10, 2025 by Pat Thomas

Defra has published its long-awaited Summary of Responses to the consultation on the Plant Varieties and Seeds Framework for Precision Bred Plant Varieties.

At more than 60 pages, the document is detailed, data-heavy, and full of the language of collaboration – yet beneath the surface it reveals something deeply troubling about how public participation is being used in policymaking around gene-edited crops.

On paper and at first glance, this looks like government listening. Defra tells us it has “consulted” and “continued the collaborative approach”. Responses were “analysed in full.” It thanks respondents for their engagement and repeatedly assures them that their feedback will “inform and shape implementation.”

But nowhere – not once – does the Department commit to acting on what people actually said.

The tone is relentlessly positive: phrases such as “good understanding,” “broad support,” and “collaborative approach” appear again and again, giving the impression of collaboration and consensus. Yet the content of the report tells a very different story – one of concern and disagreement and calls for transparency, traceability and labelling that the government shows no intention of honouring.

This is consultation as performance. It is a 68-page exercise in listening without hearing, summarising without responding, and giving voice to dissent in order to neutralise it.

What people actually said

A total of 425 responses were received – mostly individuals, farmers, and businesses, many from the organic and non-GMO sector. Defra noted that 110 responses were based on campaign templates – and certainly a good number of these will have come from our guidance and the meetings we convened around this issue.

Importantly, and unusually, it chose not to remove these from the analysis as it did with the 2021 public consultation on Genetic Technologies. Instead, they were included in a “structured thematic analysis.” This decision matters. It acknowledges that the concerns raised through the coordinated efforts like ours were legitimate, widespread, and coherent – not a noisy minority, but a visible reflection of public sentiment.

And what did those respondents say? The messages from all groups were remarkably consistent.

Transparency first. Across all respondent groups there was what Defra itself calls a “strong consensus on the importance of clear, accessible information.” People want to know which plant varieties have been produced using gene-editing or other so called “precision-breeding” genetic modification technologies. They want a central, searchable register and clear information on seed packets and other plant reproductive material. They want to make informed choices.

Labelling matters. Three-quarters of respondents supported mandatory labelling of gene-edited seeds, with support especially high among organic businesses (94%). Labelling was described as essential for protecting organic certification, maintaining consumer confidence, and ensuring the integrity of non-GMO supply chains. Without it, many said, farmers and retailers would be forced into costly, time-consuming verification processes that threaten business viability.

No labelling, higher costs. 64% of respondents said that the absence of clear labelling would increase costs – administrative, compliance-related, and reputational. Organic producers warned that they would have to develop new systems to check suppliers and prove their crops were free from “precision-bred” GMOs.

A public list, not a buried record. While 76% supported publication of a Precision Bred Variety List in the Plant Varieties and Seeds Gazette, most emphasised that the Gazette is an obscure, poorly searchable document intended for specialists. Respondents urged Defra to go further: to create a free, user-friendly, online database and to link it with labelling at every stage of the supply chain.

Alignment and integrity. Respondents also raised serious concerns about divergence within the UK and between the UK and the EU. With Scotland, Wales, and Northern Ireland continuing to regulate gene-edited organisms as GMOs, and with the EU preparing new but distinct rules for “new genomic techniques,” many fear that England’s go-it-alone approach will create confusion, damage market access, and undermine organic and conventional sectors that rely on regulatory consistency.

Taken together, these responses show an engaged and informed public asking for the bare minimum of transparency in a changing regulatory landscape. Far from opposing innovation, respondents asked for the tools that would allow them to co-exist with it: information, choice, and clarity.

Defra’s response – or lack of it

After sixty pages of analysis, charts, and demographic detail, the report’s “Next Steps” section is barely half a page long. The conclusion? Defra “remains committed to implementing the Genetic Technology (Precision Breeding) Act 2023.”

That’s it.

There is no commitment to mandatory labelling. No promise of a searchable public database. No timetable for further consultation or review. Not even a pledge to publish information in the Seeds Gazette let alone in any format beyond that.

The silence is not accidental. It’s a political choice. The government knows that if it accepts the principle of labelling for seeds and plant reproductive material, it will have no legitimate excuse for refusing to label food derived from those same gene-edited crops. To acknowledge one is to concede the other.

By stopping transparency at the farm gate, the government protects a bogus deregulatory agenda that depends on consumers being kept in the dark.

As this policy beds in, during the runup to the implementation of the Genetic Technology Regulations in November, we can expect a wave of content “slop” – PR-driven newspaper and TV features masquerading as science reporting. In thrall to ideas of progress, potential, innovation and growth, not one will ask an intelligent or critical question about what this technology is or what it might mean for the environment, for farmers, or for the food on our plates.

The language of listening – and the reality of silence

Defra has done the work of “harvesting data” – of gathering and summarising public opinion – and then quietly set it aside, ignoring the overwhelming consensus on the one issue that mattered most: the right to know what we are buying, planting, and eating.

This consultation report reads less like an instrument of democracy and more like an exercise in bureaucratic containment.

Its language of collaboration imitates openness while closing off meaningful influence. The very words that signal participation – “engagement,” “feedback,” “inform and shape” – function as a substitute for action.

Even dissent is neutered: respondents “expressed concern” or raised “broader issues” that “extended beyond the specific scope” of the consultation. The effect is to make disagreement sound procedural, not political.

The reports length and density give it the appearance of transparency. The inclusion of tables and percentages create a record of due process, even as the substance of that process remains hollow.

There are, quite literally, zero new commitments arising from this theatre of the absurd.

What this means

The government’s approach to genetic technology is being driven by the myth of speed and ideology, not by evidence or accountability.

The Precision Breeding Act removed basic safeguards that existed under the previous GMO regime; The regulations coming into effect in November doubled down on this legislative fiasco. Through consultations like this, Defra builds a procedural armour around that deregulation – a process that looks participatory but changes nothing.

The implications go far beyond gene-edited crops. If this is how “collaboration” works, it sets a precedent for policymaking across food, farming, and environmental governance: a model in which public consultation is used to validate decisions already made.

Transparency and traceability were the public’s clear demand. Defra’s refusal to act on that demand speaks volumes.

Listening is not the same as hearing – and a consultation that ends where it began is not democracy, it’s choreography.

Pat Thomas is a Director and co-founder of Beyond GM and A Bigger Conversation
Beyond GM is currently pursuing a judicial review of the Genetic Technology Regulations. Read more here and here and please support our CrowdJustice fundraiser.