Lilongwe, 3 March 2015

An alliance of 19 civil society organisations and a GMO-resistance movement led by the Commons for EcoJustice (EcoJustice) and representing Malawian small-scale farmers, faith-based organisations, organic movements, and non-governmental organisations, among others, have lodged a substantive submission to the Malawi authorities, strongly opposing the Confined Field Trial (CFT) permit application submitted by the Lilongwe University of Agriculture and Natural Resources (LUANAR) Bunda College in respect of genetically modified (GM) pod borer resistant Cowpea varieties. The Bunda College application has significant implications for Malawi, the region and the continent because cowpea is an indigenous African crop with great importance as a food security crop. 

Bunda College has applied to the office of the Biosafety Registrar in Malawi to conduct CFT for a GM cowpea variety, resistant to the insect pod borer (Maruca vitrata). The cowpea is an important source of protein in Malawi as it can be grown in regions that are not suitable for the cultivation of other leguminous crops, such as beans and groundnuts. It is also the first crop to be harvested during the ‘hunger months’ when farmers are waiting for the main grain harvest. 

If successful, the CFT permit will allow Bunda College to conduct a three-year trial at Lilongwe University of Agriculture and Natural Resources’ Bunda College campus at the same site where Bacillus thuringiensis (Bt) cotton field trials are being conducted. 

However, the civil society coalition found the Bunda College application to be fatally flawed as it is poorly study designed and is lacking even the most rudimentary biosafety data, such as basic information on the molecular characterisation of the event itself and no account of socio-economic risks. 

It is not clear from the CFT documents what the overall purpose of the CFT is. On the one hand it states the trial is to “evaluate the efficacy of the Bt resistance trait” while on the other claiming the goal “is ultimately to confirm substantial equivalence of Bt-cowpea”. Unfortunately, the study’s design will not confirm either: no experiment to compare Bt cowpea components with that of its conventional counterpart has been described, while the small-size and minimal replication of the CFT will not provide sufficient data on efficacy. The little efficacy testing that is proposed is minimal and insufficient. The CFTdesign is lacking even the most basic parameters, proposing no methods to quantify Cry1Ab expression in the plant or its efficacy on the target pest. No consideration has been given to pest resistance evolution, or to effects on non-target organisms or secondary pests. The cowpea is known to attract beneficial insects, including wasps, honeybees and lady beetles. 

According to Bright Phiri from EcoJustice, “It is our opinion that the measures proposed to prevent potential gene-flow between Bt cowpea and wild relatives in the surrounding area are inadequate. This is particularly alarming given the region’s status as the centre of origin of cowpea. The applicant claims that, based on field tests carried out previously in Nigeria, Ghana and Burkina Faso, ‘no discernable phenotypic changes’ were observed compared to non-transgenic cowpea plants. However, no data or reference to peer review study is made in support of this.” 

The Civil Society Coalition similarly also found that no data was provided to support claims that none of the genetic components were sourced from infectious agents and that none encode for allergens or toxins. 

In summary, the Coalition found that The Bunda College application completely ignores to address the following critical questions; 

1.         How will Bt cowpea be priced/marketed in Malawi given that it is mostly grown from local/farm-saved varieties and given the lack of availability of officially certified varieties?

2.         What effect will replanting Bt cowpea have on the efficacy of the Bt protein in the following season (as cowpea is self-pollinating there will be little incentive for farmers to purchase fresh seed every year)?

3.         What are the implications of seed exchange for transgene spread or gene flow? The applicant states that cowpea has low out-crossing rates, and therefore there is little concern with transgene spread. However, it has been shown that farmer seed exchange in Africa plays a major role in gene flow of GM crops.

4.         What are the gender implications of introducing Bt cowpea? Will farmers require credit to purchase Bt cowpea seed? In Malawi, cowpea is known as a “women’s crop”.

5.         Organic farmers use cowpea as a leguminous cover crop. Organic certification does not allow for the use of GM seeds. What would contamination of conventional cowpea with transgenes mean for organic farmers?

6.         Will the major buyers of cowpea (such as ADMARC or private companies) be happy purchasing Bt cowpea, given there are currently no GM food crops grown in Malawi?

7.         As stated in section 3.2, farmers grow cotton and cowpea in the same areas and are subject to similar insect pest pressure. If Bt cotton and Bt cowpea are grown in the same areas, what are the implications for pests to develop resistance?

8.         What are the implications for informal cross border trade of Bt cowpea seed into Mozambique and Zambia and the resulting biosafety implications of transgene spread taking into account that both the Mozambique and Zambian governments have placed restrictions on the import of GM seed into their countries? 

The Civil Society coalition has appealed to the office of the Biosafety Registrar to entirely reject the Bunda application until all of the concerns raised in the submission have been adequately addressed. 

Points to note

1. The 19 organisations opposing the Bunda College application include EcoJustice, Civil Society Agricultural Network, Farm Radio, Coordination Union for the Rehabilitation of the Environment, Self Help Africa, Churches in Action Relief and Development, Find Your Feet, Trustees of Agricultural Promotion Programme, Farmers Forum for Trade and Social Justice, Network for Youth and Development, Kusamala Institute for Agriculture and Ecology, Never Ending Food, Right to Food, Evangelical Lutheran Church in Malawi, Malawi Organic Growers Association, Sustainable Rural Growth and Development Initiative, Schools and Colleges Permaculture, Afriseed and Women in Agribusiness in the Sub-Sahara Africa Alliance and all members of the GMO-Free Malawi platform (a grouping of individuals, farmer groups, organisations, networks and faith-based institutions who share common environmental, safety and scientific concerns about GMO crops in general and unify their voice to advance a campaign against any intent by profit-oriented entities to introduce GMOs in Malawi). 

2. The application is for approval of a CFT of cowpea plants (Vigna unguiculata [L.] Walp) that have been genetically modified for resistance against an insect pest of cowpea in Africa, Maruca vitrata. Cowpea line IT86D-1010 was genetically modified to express Cry1Ab protein encoded by the cry1Ab gene (Bt gene) sourced from Bacillus thuringiensis, a commonly occurring soil-borne bacterium. 

3. The objection can also be downloaded at

For further information, please contact:

Bright M. Phiri - Programme Coordinator
Commons for EcoJustice
P.O. Box 1028,
Lilongwe. Malawi.
Tel: +265 (0) 111 585 700
Mobile: +265(0) 995 522 882
Facebook: GMO-Free Malawi
Skype: brightphiri