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  The Great Political Battle over
the Future of Biotechnology
Global Resistance Against Genetically Modified Organisms:
The Cases of the EU and Japan
(Additional study of Canadian contrast case)


Since the mid-1990s, a global political battle has unfolded around one of the most promising industries of the future: biotechnology. While transgenic technology showed great promise and became widely adopted in North America, it also became the target of a global resistance movement including non-governmental organizations (NGOs), key states, and international organizations. The battle plays out along several dimensions-modern technology and human progress, global trade, environmental protection, health, food security, development, democratic deficit, and cultural identity-making it one of the fault lines in globalization. State policy with respect to genetically modified organisms (GMOs) includes both national regulations and support for global standards in international negotiations such as the 2000 Cartagena Protocol on Biosafety. Domestic and international regulatory frameworks of countries with respect to GMOs, however, are not always coherent.

My proposed research program for the next three years will focus on the specific roles played by the European Union (EU) and Japan in the competition for global GMO governance. Both of them have taken strict regulatory approaches that undermine their future claims to leadership in this rising technology field. At the same time, the actions of the EU and Japan have diverged at the international level: in contrast to the EU's role as an international regulatory advocate, Japan has appeared incoherent by disconnecting its national approach from its international actions. My research aims at developing a model on the politics of state resistance to globalization at the domestic and international levels. While an emergent literature has focused on EU biotechnology regulations and, to a lesser extent, on international negotiations about GMOs, no study has undertaken a multi-level cross-regional comparative analysis. In particular, GMO politics in Japan have yet to be analyzed.

This research program involves process-tracing of domestic regulations on GMO production and labeling (two in Japan and four in the EU) on the one hand and the role played by Japan and the EU in the Cartagena negotiations and at the World Trade Organization (WTO) on the other. In addition, this research will use the comparative method to contrast political processes and outcomes in Japan and the EU. The framework developed in this study will offer insights for the study of GMO policy in other countries, such as Canada, Mexico, Brazil, China, and India. It will also shed light on other areas of contestations over global standards.

Since two-level comparative study is novel in the field of GMO regulations and resistance to globalization, there will be considerable interest in its results among scholars of international political economy, comparative political economy, Japanese politics, and EU policy-making. The study is also likely to spark significant interest among scholars of public policy and environment in Canada and the US, as well as among policy practitioners in government and nongovernmental organizations.

Detailed Description of Research

The main objective of this research program is to develop and apply new models of the politics of resistance to globalization, by analyzing the policy positions taken by the European Union (EU) and Japan on genetically modified organisms (GMOs). Such models will shed light on other battles that lie at the frontier of globalization: the setting of global standards, regulation of financial technology, debates on health research and cloning, and approaches to cultural exception (cultural diversity). Precisely, this research program aims at answering four questions:
1. Why do states go against biotechnology and resist GMOs (given the huge economic cost)?
2. What explains the domestic convergence (both regulatory) but international divergence (liberal Japan and regulatory EU) in GMO positions between the EU and Japan?
3. Why did Japan act against the setting of strict GMO regulations at the global level while passing tight labeling rules at home?
4. In contrast to Japan, how does the multi-level nature of EU decision-making affect its role as a key actor in the GMO battle?
Table 1 summarizes the research puzzle through a two-dimensional matrix of state positions on GMOs.

Table 1. Typology of States on the Liberal-Regulatory Spectrum on GMOs
International Level
Domestic Level Liberal (Pro GMO) Regulatory (Anti-GMO)

Liberal (Pro-GMO) 1. Consistent Liberalizers
[USA, Canada, Argentina] 2. Internationalist Regulators
[Most Developing Countries]

Regulatory (Anti-GMO) 3. Unilateralist Regulators
[Japan, Australia, Russia, Brazil] 4. Consistent Regulators
[EU, China, South Korea, New-Zealand]

Within OECD countries, the default box is box 1 (consistent liberalizers). Given that biotechnology is one of the most promising technologies, going against it implies huge economic and technological costs. This study therefore focuses on the most puzzling cases, those contained in boxes 3 and 4.

Since the mid-1990s, a global political battle has unfolded around one of the most promising industries of the future: biotechnology. The development of genetically modified seeds and crops in the 1990s proved extremely successful and quickly transformed North-American agriculture. As of 2003, 81% of US-grown soybeans, 73% of US-grown cotton, and 40% of US-grown corn were genetically modified. Between 1996 and 2002, global area of transgenic crops increased 35-fold, from 1.7 million hectares to 58.7 million hectares, underlining the extremely high rate of GMO technology adoption. Ninety nine percent of all world GMOs are grown in four countries alone: the US (66% of global area), Argentina (23%), Canada (6%), and China (4%).
While transgenic technology continued to dazzle many and to move beyond crops into fish and animals, it also became the target of a global resistance movement including non-governmental organizations (NGOs), key states, and international organizations. The battle plays out along several dimensions-modern technology and human progress, global trade, environmental protection, health, food security, development, democratic deficit, and cultural identity-making it one of the fault lines in globalization.
The contest unfolds both at the national and international levels. At the national level, countries introduce regulations on the production, testing, and labeling of GMOs, competing to set a dominant global standard. At the international level, an inter-state tug-of-war gave birth to the UN Cartagena Biosafety Protocol (CPB) that was signed in Montreal in January 2000 and took effect in September 2003 after being ratified by 50 countries. A further battle plays out at the WTO since May 2003, when the US, Canada, and Argentina launched a legal action against the EU's de facto moratorium on GMOs. The core divide in the GMO battle pits a US-led coalition that favors a pro-technology liberal global regime against a EU-led coalition (supported by Japan, Brazil, India, and China) that favors full public information and the precautionary principle.

Relation to Existing Literature
The major political analysis of the Cartagena negotiations (Bail, Falkner, and Marquard 2002) focuses on the trade-environment tradeoff without a clear theoretical framework. The majority of studies on GMO politics follow neatly in the traditional literature in either international political economy or comparative political economy.
At the international level, researchers have drawn upon five major paradigms in international political economy: realism, institutionalism, private governance, constructivism, and domestic linkages Using a realist focus on power, Newell and Mackenzie (2000) and Falkner (2000) analyze the Cartagena negotiations through a particular emphasis on the US-EU power play. Kalaitzandonakes and Phillips (2000) provide an institutional analysis of the role of the Codex (UN-based international institution) in global labeling. Further, Newell (2003) uses a private governance approach to argue that biotech firms have shaped the patterns of global GMO governance. Kempf's analysis of global GMO politics (2003) can in turn be construed as social movement resistance to US hegemony. Finally, Dunlop's (2000) analysis of divergences in US and EU GMO policy points to the centrality of domestic variables: the inclusiveness of regulatory institutions and the size of the industry lobby.
At the national level, the existing GMO literature builds upon four theoretical traditions in comparative political economy: interest groups, institutions, culture, and social movements. Bernauer and Meins (2003) explain the divergence between US and EU regulations primarily in terms of the collective action capacity of consumer and producer interests while Dunlop (2000) emphasizes the role of industry in regulatory processes. The institutional literature, however, has so far proven to be the most insightful, particularly in the case of EU regulations. Patterson (2000) emphasizes the bureaucratic tensions within the Commission and the competing relation between the Commission and the European Parliament. Skogstad (2003) argues that the supra-national nature of the EU leads it to seek legitimacy through network governance which in turn shapes a more integrative regulatory regime. Cultural and Foucauldian explanations have also been advanced to explain the differential framing of GMOs (Gottweis 1995 and Andree 2002). Finally, a growing literature on anti-globalization movements emphasizes the role of a rising civil society, both at the national and global level. In sum, no work has yet looked at the interaction of domestic and international variables and across states. Table 2 summarizes existing hypotheses on GMO politics from the fields of international political economy and comparative political economy.

Table 2. Existing Hypotheses on GMO Politics from International Political Economy (IPE) and Comparative Political Economy (CPE).
Theory Key Variables Selected Relevant Works Application to GMOs
1. Realism Economic interests and
Variant: US hegemony Krasner 1990 Falkner 2000
Newell and Mackenzie 2000
2. Neo-liberalism & Institutionalism Transaction costs, collective action problems, monitoring Haas, Keohane, and Levy 1993
Keohane 1984 Kalaitzandonakes and Phillips 2000
3. Private Governance Role of private agents, market-enforcement
Global firms Cutler, Haufler, and Porter 1999, Sell 1999 Lee, Humphrey, and Pugh 1997, Falkner 2003, Hall and Biersteker 2002, Cerny 2002

Newell 2003
4. Constructivism Global norms, world society, epistemic communities, global social movements Meyer and Boli 1997
Haas 1992, Finnemore 1993, Keane 2003
O'Brien et al 2000
Osgood 2001
Kempf 2003
5. Domestic Institutions
Interest Structures Schreurs and Economy 1997, DeSombre 2000, Schreurs 2002 Dunlop 2000
1. Interest Group Structure and power distribution of interest groups Olson 1965, 1982
Stigler 1971, Baron 2000, Pollack 1997 Bernauer and Meins 2003 (EU)
Dunlop 2000 (EU)
2. Institutional Structure of policy-making, bureaucratic structure / power

Network governance Tsebelis and Garrett 2000 (EU)
Vogel 1996
Scharpf 1999 Cantley 1995 (EU)
Patterson 2000 (EU)
Bernauer & Meins 2003 (EU), Dunlop 2000 (EU)
Skogstad 2003 (EU)
3. Cultural / Psychological Cultural lens
Value framing of science Jasanoff 1995 Gottweis 1995
Andree 2002 (Canada)
4. Sociological Presence of resistance movement, global linkages Keck and Sikkink 1998
Thomas 2001 Kempf 2003 (EU)
Bove and Dufour 2001 (EU)

Given the large number of countries and regulatory outcomes involved in the global GMO battle, I focus here on two major players (the EU and Japan) and two cases each: national regulations and their roles in the Cartagena negotiations on biosafety. I will be able to use both the comparative method (particularly the study of differences within a similar regulatory choice) and in depth process-tracing within each case. Process-tracing aims at systematically analyzing the sequence and way through which independent variables and the preferences of relevant actors translate into political outcomes. It thus requires one to follow all steps in policy-making process and the actions of all actors involved in the process, up until the outcome (see George and McKeown 1985:35). Researchers who use this method cannot rely upon written documents alone, because many critical steps do not leave a written trace and because the motivations of key actors remain unclear. Interviews with all possible political actors provide the crucial link in the analysis of the political process. Hence the requirement of significant periods of field research, during which I will spend time in ministries, with legislators, and with related interest group leaders, gathering intermediate documents and probing preferences through interviews.

Case Selection
The proposed study focuses on the analysis of the actions of the two major OECD players in the anti-GMO camp: the EU and Japan. Japan is the world's largest importer of GMOs (with 80% of its soybeans and 90% of its corn coming from the US). Naturally, the EU is not a state, but remains the most significant level of analysis for GMO politics, given that key regulatory moves take place at the EU level. The study analyzes both domestic-level regulations and international-level actions:

Actor \
Dimension Main National Regulations International Role (Cartagena, WTO)
Japan o 1999 Law on compulsory labeling of GMOs
o June 2003: Law on the release of GMOs (testing, producing) o Compromise Group in Cartagena negotiations (1999-2000)
o Pro-US move in Seattle 1999
EU o Directives 90/219 (Contained Use) and 90/220 (Deliberate Relase)
o 1997 Novel Foods Regulation
o Oct 1998-June 1999: de facto moratorium on new approvals
o Oct 2002-July 2003: Directive 2001/18 on labeling and traceability o Leader at Cartagena negotiations, 1999-2000
o Leader at WTO negotiations, 1999-2003