On the 31 December 2004 the Chief sanitary Physician of the State issued a decree #13 “On the strengthening of the control over food products derived from GMS”. The decree establishes a fact of the spread of GM crops worldwide in 2003 and admits that the approved GM derived food is safe. The decree gives the brief analysis of results of post-registration monitoring of GM derived food as well as facts of falsification of requirements of the binding labeling, and the list of 13 GM crops “approved for use in food industry and selling to population without restrictions” (annex 1). It also the “list of food raw material having GM analogs approved on the world market but having not passed through the registration procedure in the Russian Federation, which may enter the internal market and are subject to control for GM presence” (annexes 3, 4).

The decree summarizes the regulatory basis in the realm of oversight and control of food products derived from GM sources, stipulates the binding character of post-registration monitoring, and declare availability of 153 qualified expert conducting quantitative analysis of recombinant DNA.

The decree directs strengthening the control over GM derived food considering this a 2005 year priority, defines seven lead regional centers for GM detection in food products, orders to prepare amendments to the current labeling regulations, and improve method and personnel training for quantitative detection of GM components.

The decree also provides a list of food (annex 5) which is shall be subject to binding monitoring for detection of GM components from sources defined in annexes 3 and 4 (“GMS of food produced in the world on industrial scale” and “The list of GMM and food products based on GMM officially approved in the world for use in food industry”).

Food products subjected to binding control with quarterly review includes domestically produced and imported “meat and meat products, birds and bird keeping products, milk, milk products including butter and sour cream, fish, fish products, and other sea products, bakery, flour and cereals, sugar and confectionery products, vegetables, water-melon, melon and gourd plantation products, potato, fruits and berries, wild growing food products, plant oil products, beer and beverages, alcoholic drinks, honey and apiculture products, baby food, potted/canned food, grain and grain derived products, others.

The decree says nothing about sampling, border control, and financial mechanism to support the activities.

Besides that there are a number of factual mistakes or inaccuracies in the decree. Thus, strangely enough, neither the decree nor its annexes mention maize Bt11, though it had been approved long ago in Russia and elsewhere in the world food use and is being grown commercially in a number of countries. Annex 4 - “GMS of food produced in the world on industrial scale” lists crops, which are not grown commercially but only passed through approval process (a number of potato varieties) or even not approved for planting (wheat 71800). Moreover crops grown for food and feed (maize Bt11, cotton, lentils, chicory) are missing from the lists.

Judging on the list of products subject to binding testing the Russian labeling procedure will cover imported cheeses and beer, which hardly matches the declared harmonization with the EC.