LMO/GMO 규제법률 도입방법에 대한 비교법적 고찰 - 한국, 미국, 유럽연합을 중심으로 -

Korea, U.S.A., and EU show different introduction of LMO/GMOs regulations. While Korea and EU, as a Party to Biological Safety Protocol, have adopted similar approaches to regulate LMO/GMOs products, U.S.A. has chose its unique or non-specific general LMO/GMOs regulations. EU legislations on LMO/GMOs has been in place since the early 1990s, and they include Regulation (EC) No 1829/2003 of the European Parliament and of the Council of 22 September 2003 on genetically modified food and feed (OJ No L268/1, 18.10.2003), Regulation (EC) No 1830/2003 concerning the traceability and labelling of genetically modified organisms and the traceability of food and feed products from genetically modified organisms and amending Directive 2001/18/EC (OJ No L.268/24,18.10.2003), Directive 2001/18/EC on the deliberate release into the environment of genetically modified organisms and repealing Council Directive 90/220/EEC, Directive 2009/41/EC on the contained use of generically modified micro-organisms, Regulation (EC) No 1946/2003 on transboundary movement of LMO/GMO. On the other hand, U.S.C. does not have no single statue and no single federal agency to govern the regulation of biotechnology products. As a result, a complex range of laws govern to all foods, drugs and chemicals produced from biotechnology. Under these laws, three federal agencies-the FDA, Department of Agriculture, and the Environmental Protection Agency have primary responsibility for the regulation of biotechnology products.