In a recent study on the social acceptance of biotechnology in the European Union (EU), it is concluded that moral concerns in particular could serve as a potential blockade to the consumer approval of certain applications of modern biotechnology. In general, bioethical arguments play an important role in public debates on biotechnology in Europe. However, the diversity in content and structure of bioethical debate is considerable among the different EU member countries.

In Spring 1997, the first ships arrived with genetically altered soya beans in the harbours of the Netherlands, France and Denmark. The transgenic beans made up a small proportion of the undifferentiated US soya bean harvest. The shippings provoked protest from environmental organizations, which oppose the production and use of genetically altered plants, mainly on ethical grounds. 'One should not alter the natural world' is, in different formulations, their central issue. The environmental organizations have received wide public support. Public discussion on moral issue of development in biotechnology is very intense in Europe. Consequently, the European Union regularly commissions research on public opinion within the different member countries, the so­called Eurobarometer (see also box).

European public opinion
The 1996 Eurobarometer includes the opinion of about 1000 citizens per EU country concerning biotechnological developments and applications in the different sectors. In Nature the international team of researchers concludes that "many Europeans are uneasy about modern biotechnology, particularly about new genetic technologies. Although there is widespread support for 'traditional' medical applications in the fields of diagnosis and treatment, few approve of the use of transgenic animals for research or for applications such as transplantation of organs into humans. There is also a striking mismatch between the traditional concern of regulators with issues of risk and safety, and that of the public, which centres on questions of moral acceptability."
The individual acceptance of biotechnology appears to depend on several factors. Firstly, knowledge of biotechnology is an important prerequisite for having an outspoken opinion. People with greater knowledge of biotechnology are more likely to express a definite opinion which can be either positive or negative. Secondly, the specific application of biotechnology is very important. The use of biotechnology for development of medicines is much more accepted than its use for food production and agriculture. Thirdly, social acceptability is influenced by perceptions of risk associated to the technology. However, the most dominant factor is the moral acceptability of biotechnology. The researchers conclude that "first, usefulness is a precondition of support; second, people seem prepared to accept some risk as long as there is a perception of usefulness and no moral concern; but third, and crucially, moral doubts act as a veto irrespective of people's views on use and risk." This pattern holds true in every EU country and across all applications. It is however contrary to the main focus in political discussions on biotechnology in the EU, which focuses especially on risk and safety, more than on moral acceptance (see also Monitor No. 26). Biotechnology is extensively regulated in Europe but the reasons that are at the basis of the regulation seem to differ from the real issues in public opinion.
What are the main moral issues of concern in Europe? It appears that the focus of bioethical concern differ among the EU member countries. Moreover, the way bioethical considerations in society are approached varies substantially.

Germany: entrenchment of discussion
Germany has a long tradition of fierce discussion on ethics and biotechnology. Widespread reservation towards the deliberate release of genetically modified organisms, for instance, has always been strong in Germany. This has resulted in restrictive biosafety regulation.
A typical characteristic of the German debate is a lack of informal/personal communication between the participants in the public debate. The main opponents in the debate, industry on the one hand and issue groups on the other, hardly communicate with each other unless through the media.
The other side of the formalistic approach, is that procedures are static and less appropriate to the fast changing situation in modern biotechnology. For example, Germany already had formal procedures to apply for (and oppose) permission for release experiments with GMOs, even before the first application in 1989. The application procedure, which included open public hearings, was considered so burdensome and time consuming by applicants, that hardly any experiments were applied for. It was only because of intense pressure from the industry and research associations, and after the transfer of the biotechnology research of the German private company Schering to the USA, that the regulation was amended. The industry even organized a huge advertising campaign asking for attention and support for their problems.
Nowadays the German opponents in the public debate, industry as well as NGOs, are entrenched in their positions, which does not lead to any progress in the debate. The opponents appear not to be able to work towards an agreement on ethical issues. Given the importance of the topic, both parties seek public support through the media to increase their political power, resulting in a further entrenchment of the public debate.

The Netherlands: searching for consensus
The organization of the debate in the Netherlands is quite different from Germany. An 'informal consultation group' has been organized. In the consultation group, representatives of several non­governmental organizations, such as environmental and consumer groups, research and biotechnology industry regularly meet on a voluntary basis. This informal group sets up its own agenda. The main result of the consultation group is a voluntary policy on labelling biotechnology food products.
This intensive interaction between opponents in the public debate does not prevent each group from trying to directly influence the general public. The partners in the consultation group respect each other's position, and how they want to involve the greater public in their own way. Aggressive and large publicity campaigns have taken place. Although these campaigns have not always been appreciated by other members, they have not influenced the informal biotechnology convention significantly. The focus on consensus in the bioethical debate gives the members the possibility to achieve results without losing face. The consensus of the consultation group has stimulated results in the general debate on ethical issues in biotechnology in the Netherlands.

Italy: focus on humans
Italy has no large scale chemical industry or a tradition of research in biotechnology. Partly as a consequence, the awareness and interest of the general public in biotechnology are very low, and the 'public' debate has been confined to some small circles. In sharp contrast with Germany and the Netherlands, Italian environmental groups and other NGOs show very little interest in biotechnology. The small public attention almost exclusively focuses on subjects concerning human reproduction, such as in vitro fertilization, gene therapy and other applications of biotechnology to humans. These are usually sensationalized by the media. As a consequence, the regulatory system in Italy mainly follow the minimal obligatory EU requirements, and has been working without much social control.
The focus on humans appear to be analogous to the Roman Catholic ethical rules. This is in contrast with the more Northern European Christian protestant bioethics which generally looks upon nature and animals as things which humanity should take care of. Together with a greater individual responsibility for how humans handle nature in the Christian Protestant world view, it can be understood that scientists, politicians and the general public in Northern Europe generally favour a more responsible­for­nature standpoint than is favoured in Southern Europe.

European attitudes on biotechnology In the 1993 Eurobarometer study, 28,000 citizens from all member countries from the European Union were questioned about their 'objective' knowledge of biotechnology and how they perceive biotechnology. The study asked the respondents to judge biotechnology's promises and threats. Based on the average answers, the EU countries can be categorized as shown in the figure.  The diagram sorts the countries into four quadrants. In the 'cautious' countries in the upper right quadrant, the promise of biotechnology is rated high, as is the threat. This applies to public opinion in Denmark, the Netherlands, Norway and Greece. Although Greece and the Northern European citizens express the same perception of biotechnology, the Greeks state that their knowledge of biotechnology is low, while the Danes, the Norwegians and the Dutch consider their knowledge as relatively high.  At the bottom right, those countries are gathered in which biotechnology is assessed mainly as a promise. All five Latin countries are present here: Spain, Portugal, Italy, France and Belgium. Except for France, the average knowledge of biotechnology in these 'happy­go­lucky' countries is relatively low.  In Great Britain and both parts of Ireland, both the promises and the threats related to biotechnology rate low. This 'uninvolved' quadrant appears suitable for island nations.  In the upper left quadrant finally, people assess biotechnology mainly as a threat, less as a promise. Germany and Luxembourg are presented in this 'gloomy' quadrant.  Source: F. van Baren, G. Hofstede and F. van de Vijver (1995), Knowledge of and Attitudes to Biotechnology: The influence of national cultures: An application of DECOR. Report commissioned by the European Commission DGXII. Maastricht, the Netherlands: IRIC, University of Limburg.

France: no debate
The French government is reserved towards bioethical regulation. A report submitted to the Prime Minister in April 1991 suggested that regulation in the field of human reproduction would be premature. The report called for a wide debate in parliament, which however has not followed.
This French 'laissez faire' policy can only understood in the light of the disinterest of the greater public. In France hardly any public debate on ethical aspects of biotechnology takes place. Such debate is not stimulated by government either. In this way the absence of public debate in France is comparable to the situation in Italy. However, France has an important biotechnology industry and research activities. In Europe it is the country with the largest number of field trials with genetically modified organisms. This capacity in biotechnology is partly due to the early stimulation of biotechnology research by the French government, which started in the 1970s. Still the French government does not play an active role in the public debate on bioethics. The policy choices in this respect are totally different from the ones in Denmark

Denmark: open and profound
In 1986 the Danish parliament passed a law on gene technology and environment (probably the first in the world) that initially prohibited the deliberate release of GMOs. Later this was eased. This first implementation of a stringent regulation which was later loosened, compares to the situation in Germany.
In spring 1997 the Danish minister of agriculture announced the government's goal to improve the living conditions of domestic animals. The initiative included public discussions and the development of alternatives to increase the welfare of animals in intensive agriculture. The main reason for this initiative was of an ethical nature: animals should be treated better.
Reference to ethical arguments can be found elsewhere in Danish public debates. In 1994, the Danish food and beverages multinational Danisco announced that it would avoid genetic engineering in its research and development activities. The company claimed 'to be an ethical company'. Novo Nordisk, a Danish pharmaceutical multinational, reconsidered significant investments in China when it came to a national debate about whether Western companies should invest in countries where human rights are not respected by the government. This public debate was indirectly initiated by the Danish government when is appeared that Denmark stood on its own in supporting a resolution on China's infringements of human rights in the UN Human Right Commission. Although Novo Nordisk finally has invested in China, it announced its decision as an ethical one. According to Novo Nordisk, the company serves the ethical principles better by staying than by leaving. "What would it possibly achieve if we closed down our factory in China? Just by being there we can exert a long­time influence and help improve things in the future" reads the Novo magazine in May 1997. In comparison with the German or French situation, it is striking that in Denmark a company is willing to defend its decision in an ethically oriented public debate.
Apparently a company and the general public look upon each other as partners in the discussion. In the case of Novo Nordisk this is not surprising. The company has a tradition of inviting environmentalists and other issue groups to their productions plants and laboratories. These visits are not meant only to show the 'beautiful technology', but chiefly to exchange opinions about issues that concern the visitors most. These discussion with issue groups are welcomed by employees of the company. Representatives of Novo Nordisk are on a list to join the discussion with the environmentalists as well.
An open discussion of difficult bioethical topics can be called typically Danish. When the Parliament approved the first R&D programme in biotechnology in 1986, it allocated US$ 1.5 million to disseminate information on modern biotechnology. More than 21,000 persons participated in these educational activities and all the different points of view were represented in the debate. Already in the mid­eighties the Danish government had initiated 'lay panel discussion' as a means to help decide on controversial subjects. In the panel discussion about 30 Danish citizens gathered for a weekend to receive information about the technical details of a controversial subject, for example genetic modification of animals, followed by discussion. The results of such lay panel discussions have been input for political decision making. Meanwhile the public acceptance of biotechnology has increased: the percentage of people urging the implementation of an international moratorium on the use of rDNA decreased from 39 per cent in 1987 to 25 per cent in 1989. Nowadays, the Danes are recognized in the Eurobarometer research as critical to, but not afraid of, biotechnological developments.

In every European country, issue groups play a role in the public debate on bioethics. However, in Italy and France their role is comparably small, and their success mostly limited to getting public attention for the ethical issues concerning human applications of biotechnology. The government, industry and public have no interest in further debate in these countries.
In Germany, social and political attention for issue groups is huge. The public debate mainly takes place in the media. Direct contact between industry, policy makers and issue groups are scarce. This type of debate leaves little room for compromise because each concession to the other 'party' is a public defeat. Consequently, the discussion is characterized by a high entrenchment, and the German government is forced to be the arbitrator.
The role of the government in the Danish bioethical debate is much more diverse, being initiator and participant as well. It results in a rather open atmosphere, in which ethical considerations in policy decisions can be made public. Finally, in the Netherlands, issue groups and industry together create a discussion niche in which together they can come to voluntary agreements. Instead of being arbitrator and regulator, its main role lies in providing information to the public.
Wieger van Dalen

Eggink & Van Dalen Consultancy, Marnixstraat 28, 7553 LC Hengelo, the Netherlands. Phone & fax (+31) 74 250 4397;
E­mail wkvdalen@worldaccess.nl

Sources
J. Durant et al. (1997), "Europe Ambivalent on Biotechnology." Nature, vol. 387, June 1997, pp. 845­847.

F. van Baren, G. Hofstede and F. van de Vijver (1995), Knowledge of and Attitudes to Biotechnology: The influence of national cultures: An application of DECOR. Report commissioned by the European Commission DGXII. Maastricht, the Netherlands: IRIC, University of Limburg.

E. Recchia and F Terragni (1995), GMO Releases: Managing uncertainties about biosafety: The implementation of directive 90/120 on the deliberate release of GMOs into the environment in Italy. Milano, Italy: CERISS.

F. Terragni (1992), Bioethics in Europe, Report commissioned by the European Commission DGXII. Luxembourg.