Report Highlights: 

The Tunisian legislation on biotechnology, drafted before the revolution, has been indefinitely postponed. The new general post revolution environment created a long list of priority for the government which makes unlikely any legislation to be approved until the election of a new parliament by the end of the year. Meanwhile, imports of biotech products into Tunisia will continue to be handled in a manner similar to that of conventional agricultural products. Tunisia is an important importer of corn and soybeans with the US maintaining 50% of the Tunisian soybean import market. FAS/Tunis continues to assist in building Tunisia’s biotechnology research capacity through exchange programs and technical workshops 

Section I. Executive Summary: 

Tunisia still has no legal framework dealing with the introduction, use, and marketing of agricultural biotechnology. New legislation for biotech products was expected to be finalized and adopted by the Tunisian parliament before the end of 2010. However, that legislation has been indefinitely postponed. In 2011, Tunisia underwent a historic revolution that spread to several Arab countries and changed the picture of the Middle East and North African region. Today, Tunisia is in a recovery phase after the revolution and is trying to implement democratic systems and institutions through the writing of a new constitution. The new general environment created a long list of priorities for the government which makes it unlikely that new biotech legislation will be approved before the election of a new parliament in late 2014. 

There is no debate today on biotechnology in Tunisia since Tunisian awareness of this issue is very low. However as a new democracy in transition, there will be an intense debate in the next few years between pro and anti-biotech opponents, mainly influenced by European Union (EU) policy regarding biotechnology issues. Pending the expected debate on biotech products, imports of genetically engineered (GE) products into Tunisia will continue to be handled in a manner similar to conventional agricultural products. Although Tunisian officials recognize the existence of GE materials in imported animal feed products, the dependence of Tunisia’s agriculture on these imports, as well as their increased international acceptance, have allowed the import of these biotech products to continue. 

Agricultural biotechnology activities in Tunisia continue to be restricted to the research level principally covering applications related to plants, animals and insects. There is government support provided to several biotechnology research institutes that have emerged in Tunisia in recent years allowing the improvement of Tunisia’s understanding of biotechnology issues at the researchers’ level. 

In the past few years, FAS/Tunis carried out several activities aimed at building close working relationships with key players dealing with biotechnology issues in Tunisia. Post sponsored several conferences and supported Cochran and Borlaug programs’ participants in biotech activities. Post also conducted some successful outreach activity targeted at policy makers, opinion leaders, legislatures, and civil societies in Tunisia in order to help guide the process of establishing viable biotechnology legislations in the country. 

Section II. Plant Biotechnology Trade and Production: 

a) Product development: 

Agricultural biotechnologies uses in Tunisia are limited to three domains of application: plants, animals and insects. The activities involving biotechnologies such as the production of GE materials and recombinant DNA are restricted to the structures of research. 

b) Commercial production: 

Field-testing and, a fortiori commercial use, are on hold pending the enactment of national biosafety regulations. 

c) Exports: 

Tunisia does not export biotech crops/products to the United States or other countries. 

d) Imports: 

Concerning the trade, there is no segregation as both biotech and non-biotech products are handled the same way and no existing laws restrict, control or authorize the trade of biotech products. A recent study published by the Tunisian Ministry of Health demonstrated that human alimentation in Tunisia was free of GE materials while animal feed contains a high level of it, principally imported corn and soybean meal. 

Following are the main regulations governing the import of (1) seeds and seedlings, (2) unprocessed food and feed and (3) consumer-oriented products: 

(1) Seeds and seedlings imports must comply with Decree # 2002-621 dated March 19th, 2002. This decree sets rules to import all seeds and seedlings. Apart from the phytosanitary aspects, the main provisions of this decree are the obligation for the importer to apply for a license, to have a minimum storage capacity and to keep records for its inventories. Seeds and seedlings covered by this decree are: potato, citrus, strawberry, pulses, horticultural seeds, forages, cereals and vine. 

(2) Unprocessed food and feed: the existing sanitary and phytosanitary rules do not refer to the biotechnology aspects. In Tunisia, phytosanitary control of imported food and feed is regulated by the Law # 92-72 dated August 3rd 1992, while sanitary control is covered by the Law # 99-24 dated March 9th, 1999. The enforcing authorities are the DGPCQPA (Direction Generale de la Protection et du Controle de la Qualite des Produits Agricoles) and DGSV (Direction Generale des Services Veterinaires), both departments within the Ministry of Agriculture. 

(3) Consumer-oriented food products: Apart from the sanitary and phytosanitary laws that apply also to this type of product, consumer-oriented products must comply with the decree dated July, 1985 validating Tunisian standard NT 15-23 (1983) which applies to pre-packed food commodities labeling and presentation. The enforcing authority is the DQPC (Direction Generale de la Protection du Consommateur) of the Ministry of Commerce. 

For the last two decades, Tunisia has been a net importer of agricultural products with a negative food trade balance. In 2013, Tunisia total exports reached $1.691 billion, while total imports were around $2.751 billion. Leading agricultural imports in 2013 were wheat ($928 million), corn ($238 million), vegetable oils ($ 325 million). The leading exports were olive oil and products ($ 511 million), fishery products, dates, and citrus. Tunisia is one of the world’s four leading exporters of olive oil, a fact that is largely overlooked as much of its production is exported in bulk to the EU to be refined, bottled, and marketed and re-exported from EU countries (Italy, Spain). 

Tunisia's primary trading partners are France, Italy, Germany, Belgium, Luxembourg, and the Maghreb countries. In 2013, the United States was Tunisia’s sixth largest trading partner. In 2013, U.S. agricultural exports to Tunisia were down at $163 million after an all-time high in 2011, with corn oil, oilseeds, coarse grain, and wheat exports accounting for the bulk of these exports. It is worth to note that the US trade balance with Tunisia is historically positive except in 2012. Tunisia’s main exports to the United States are mineral fuels, mineral oils, olive oil, articles of apparel and clothing accessories, electrical parts and biggest imports from the U.S. are oil seeds, cereals, machinery and mechanical appliances and chemicals. 

Section III. Plant Biotechnology Policy: 

a) Regulatory Framework: 

Two Ministries are involved in biotech use, the Ministry of Agriculture and the Ministry of Environment and Sustainable Development. The Ministry of Health is also involved via its agency, ANCSEP, which is in charge of sanitary and environmental controls of imported goods. On the research side, the Government of Tunisia (GOT) implemented a fully supportive policy for Agricultural biotechnology. However, Tunisia is at a crossroads on biotechnology policy. Most of the Tunisian researchers see agricultural biotechnologies as useful in addressing the country’s agricultural chronic problems such as crop disease, weeds, and erratic precipitation. This enthusiasm is countered by skepticism as a result of Tunisia's close ties with Europe. Tunisia ratified the Cartagena protocol in 2002 (Law #58-25/06/2013) and established a national legal framework for bio safety with the United Nation Environment program (budgeted at 927.000US$) that includes a scientific committee on GMO. The national legal framework objective is to identify how to allow the monitoring and the control of GE product uses in a controlled environment, as well as controlling the trade and transit of GE products in Tunisia. The recommendations of the committee will guide the laws and decrees to be drafted and voted on by the parliament. The guideline for the law that is currently under preparation is the precautionary principle and basing the uses of GE products on a double authorization system. The first one is a prior authorization agreement granted by the Ministry of Environment. The second is an authorization from the ministry directly involved with the request, depending on the area of concern (i.e. Agriculture, Health). 

A lot of progress toward the draft biosafety law was done. However, the adoption by the Tunisian parliament has been indefinitely postponed and currently there is no legal framework dealing with the use and release of products of agricultural biotechnology in Tunisia. The draft of Tunisia’s biosafety regulations is not yet a public document. However, it is reportedly made up of two laws (a draft law related to the confined use, deliberate release and commercialization of biotech products, and a draft law related to the import and transit of biotech products), three decrees and three ministerial orders. The post transition revolution period will not be favorable to accelerating the adoption of the law as the country has many other priorities. 

b) Approvals: 

Biotech products are handled in the same way as conventional imported agricultural products with no additional or extra approvals. 

c) Field Testing: 

Officially, there is no law that prohibits or authorizes field testing in Tunisia. Some transgenic grapevine experiences were reported in the past. 

g) Labeling: 

Concerning labeling, it should be noted that Tunisia published a decree in September 3, 2008 (Art. 7) that makes labeling mandatory for all GE food products and GE food ingredients. However, this obligation is not sufficiently clear and does not provide details on the type of products involved, the percentage of GE material authorized and the authority in charge of the enforcement. 

h) Trade Barriers: 

GE imported products are subjects to the same tariffs and barriers than conventional products. 

i) Intellectual Property Right (IPR): 

In Tunisia, there is a legislative framework that deals with IPR but it is not specific to GE products. 

j) Cartagena Protocol Ratification: 

Tunisia ratified the Cartagena protocol in 2002 (Law #58-25/06/2013). 

k) International Treaties/Fora: 

Tunisia participates in international treaties and conventions such as the International Plant Protection Convention (IPPC), or the Codex Alimentarius (Codex), where issues concerning biotechnology are discussed. 

l) Related Issues: Not applicable 

m) Monitoring and Testing: 

In 2008, a national laboratory for GE product detection and a research center to assess the risks of using biotech products were established. Several laboratories seems to have the potential to carry out GE product testing using PCR-based detection methods, once the legislation is in place. It is worth noting that Tunisia is receiving technical assistance from the EU to establish its biotechnology testing capacity but there is no regular monitoring testing program for GE products. 

n) Low Level Presence Policy: Not applicable 

Section IV. Plant Biotechnology Marketing Issues: 

a) Market Acceptance: 

There are no significant market acceptance issues related to the sale of biotech products in Tunisia due to the non-existence of GE food-use on one hand, and the absence of strong consumer movements pushing trade-restrictive agendas on the other hand. However, it is mandatory to inform consumers when GE methods of production are involved. 

b) Public/private Opinion: 

Consumers continue to be largely unaware of the controversial debate between proponents and opponents of biotech at the international level. The biotech debate has not yet reached the public arena although we see from time to time newspaper articles conveying the EU concerns about modern biotechnology. A recent local inquiry showed that only 4% of the Tunisian had heard about GE products in the past. 

Large scale farmers in Tunisia would be interested in biotech crops since their adoption will reduce the costs brought by the use of pesticides and irrigation. Moreover the use of GE plants resistant to diseases, salinity or drought would be profitable considering that a reduction of the cost of treatments and an improvement of the yield would be obtained. However the question arises for the small-scale farming (less than 20 hectares) which represents a majority of the total number of the farms in Tunisia. In such farm, cereal seeds are simply taken out of the previous harvest and no pesticide or herbicide treatments are applied because of their costs. Consequently the use of GE products would be possible only through governmental support by subsiding transgenic seeds for example. 

c) Marketing Studies: Not applicable 

Section V. Plant Biotechnology Capacity Building and Outreach: 

a) Activities: 

The Contributions of Plant Biotechnology in Confronting Climate Change" 

In October 2010, FAS/Tunis, in cooperation with the Department of State, organized a well-attended workshop targeted at 200 policy makers, opinion leaders, legislatures, and civil societies in Tunisia in order to help guide the process of establishing viable biotechnology legislations in Tunisia. The successful workshop, presented by four U.S. experts from Cornell University, University of California Berkeley, and University of Nevada, addressed several issues related the contributions of plant biotechnology in confronting climate changes and focused on biotech role in addressing plant disease, mitigating global warming, and adapting crops to marginal soils. The successful event generated wide positive media coverage and gave the scientific community an opportunity to engage in the policy debate over various biotechnology subjects in Tunisia. 

Norman E. Borlaug Fellowship program 

Under this program, a Tunisian researcher from CBBC participated in June 2009 in a six-week training program at Oklahoma State University. The program will help the Tunisian researcher to improve its knowledge of small grain production and to gain exposure to the latest U.S weed management practices. In addition the program will provide the opportunity for Tunisian scientists and policymakers to establish long-term contacts with U.S. scientists and apply the newly gained knowledge from U.S. laboratories to their research and development programs. 

Cochran Program 

Post conducted several Cochran programs focusing on giving government key officials an enhanced understanding of commercial realities in the US, so they do not impose restrictive regulations. The last Cochran program exclusively devoted to Biotech was in 2001. 

b) Strategies and Needs: 

FAS/Tunis maintains a close contact with the research laboratories in Tunis and regularly engages them in outreach activities and scientific exchange programs of mutual interest. FAS/Tunis office, under an overall regional strategy, supports local interest in biotechnology by developing several activities. Post activities have been focused on identifying key players and on advocating science-based biotech risk assessments and trade-friendly regulations. We have been successful in establishing relationships with key officials; some of them are influential members of the National Biosafety Committee. AgTunis will continue promoting exposure and increased familiarity of Tunisian regulators and scientists with biotechnology, especially since the presence of researchers involved in biotech issue was identified as a weakness of the Tunisian system at a recent workshop on biotechnology. 

Section VI. Animal Biotechnology: 

Animal biotechnologies are at their early stages except for basic reproductive biotechnologies such as artificial insemination. Embryo transfer, although technically feasible, has not yet gained a significant uptake in the livestock sector