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Monsanto comments to USTR on US-Thailand FTA

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April 8, 2004

Ms. Gloria Blue
Office of the U.S. Trade Representative
600 17th Street NW
Washington, DC 20

By Electronic Submission :

Subject : United States - Thailand Free Trade Agreement
Written Comments

Monsanto Company appreciates this opportunity to submit written comments pertaining to
the initiation of negotiations with Thailand on a Free Trade Agreement (FT A) as notified in
the Federal Register (69 ER 9419, February 27,2004). Monsanto supports the upcoming
trade negotiations with Thailand, but believes that current barriers to agricultural
biotechnology must be addressed.

Monsanto is a leading international provider of agricultural products and solutions. We use
unparalleled innovation in plant biotechnology, genomics and breeding to improve
productivity and to reduce the costs of farming. We produce leading seed brands, including
DEKALB, and we develop biotechnology traits that integrate insect control and weed control
into the seed itself. We make Roundup, the world’s best-selling herbicide, which can be
combined with our seeds and traits to offer farmers integrated solutions. Our biotechnology
traits have helped to positively change the face of global agriculture and adoption of biotech
crops worldwide continues to grow. In 2003, approximately 167 million acres of biotech
crops were grown by 7 million farmers in eighteen countries, which represents a 15 percent
increase over 2002 estimates.

Established in 1968, Monsanto Thailand has been providing Thai farmers with conventional
hybrid seeds and a variety of crop protection products for over thirty years. Monsanto
Thailand is headquartered in Bangkok and maintains seed manufacturing and research
facilities in Phitsanulok and Nakornrachasima. Monsanto’s investment in Thailand
operations is approximately $7.6 million, and we retain about 5,000 contract production
farmers throughout the country. Clearly, we view Thailand as a market with excellent
growth potential and as an important window to serve the growing Southeast Asian market
for both conventional and agricultural biotechnology crops.

Historically, Thai regulators have demonstrated leadership in the region in developing
policies and regulations governing biotechnology. However, for the past three years, there
has been no progress in government evaluation — through field trials — or approvals of
agricultural biotechnology products, which jeopardizes any opportunities for the introduction and commercialization of biotech products in this market. Without access to these products, Thai farmers will lose the additional tools to enhance their efficiencies or address local environmental issues through the use of agricultural biotechnology. It is our hope that this situation might be addressed and resolved either in a parallel fashion with the FTA negotiations or directly within the context of the negotiations.

Field Trial Moratorium and the Need for Science-Based Regulations in Thailand

Thailand has well defined guidelines for the regulation of agricultural biotechnology, and it
was the first country in Southeast Asia to begin conducting biotech field trials for Bollgard Bt
insect-protected cotton in 1997. Those field trials were conducted in three stages as provided by the biosafety guidelines under the supervision of the Thai Department of Agriculture and were completed in 1999. Despite the completion of all required regulatory trials, the commercial use ofBt cotton in Thailand has yet to be approved by the Thai government.

In 2001, the Thai Cabinet imposed a moratorium on large-scale field-testing of biotechnology-improved crops in response to activist pressure. The moratorium has remained in effect for three years with no clear indication that it will be lifted. Public comments made by Thai officials seem to indicate that the moratorium does not prohibit government station field trials, which are smaller in scale, but was designed to only preclude larger commercial field trials.

In January 2003, Monsanto submitted an application to the Thai Depamnent of Agriculture to
initiate small-scale, government station field trials for Roundup Ready herbicide tolerant
corn. Roundup Ready corn can help Thai farmers better meet demand by increasing
productivity and to address pressing environmental concerns, including more efficient use of water resources through conservation tillage practices. Roundup Ready corn has been
planted extensively in North America and has been delivering these benefits to US and
Canadian farmers since 1997. Over a year has elapsed with no indication that this application
will be approved, and no scientific justification has been provided for the lack of action on
the application.

It would be a modest, yet important first step for ensuring that the Royal Thai Government is
committed to a timely, transparent and science-based process to evaluate biotechnology
crops, to resume the limited, government station field trials that are necessary to demonstrate the safety of the product and to build public confidence in the regulatory process.

The net result of the Thai moratorium on field trials is similar in many respects to the
European Union moratorium on approvals of new agricultural biotech products. Without
field trials to demonstrate the safety of agricultural biotech products, approvals cannot be
obtained, therefore impeding the introduction and commercialization of these products.

Ultimately, the Royal Thai Government should be strongly encouraged to clarify and
implement a science-based biosafety and regulatory system to guide the evaluation, approval and commercialization of biotech crops. In the context of free trade, we believe it is
imperative that the U.S. work with Thailand to eliminate the current barriers to agricultural
biotechnology-improved crops and establish a science-based regulatory system — including
field trials of new crops — consistent with their international trade obligations in order to
bring the benefits of these products to market in Thailand and to further promote consistent
access to American agricultural technologies and products.