One-Door-One-Key Principle: Observations Regarding Integration of GM Authorization Procedures in the EU

Under European Union (EU) law, genetically modified organisms (GMOs) for consumption require authorizations for cultivation, for use in human food, and for use in animal feed. The recast of the legislative framework in 2003 introduced the "one-door-one-key principle." This principle links and integrates the procedures to acquire these three authorizations partly in a mandatory and partly in an optional manner. Even though the EU legislature perceives the three authorizations as intrinsically linked, in practice considerable differences can be observed in the presence of GMOs on the EU market for cultivation, for feed use, and for food use. Partly these differences are reflected in differences in authorization.

This Article traces the one-door-one-key principle in EU GMO food law; its content is an application. Based on literature and a few interviews, it attempts to explain the gap between legal theory and business practice.