2007 BT Cotton in India

Bt COTTON IN INDIA
A STATUS REPORT
Asia-Pacific Consortium on Agricultural Biotechnology

(APCoAB)
C/o ICRISAT, NASC Complex, Dev Prakash Shastri Marg, Pusa Campus
New Delhi - 110 012, India
Citation: APCoAB. 2006. Bt cotton in India A status report. Asia-Pacific Consortium

on Agricultural Biotechnology, New Delhi, India. p. 34.
Printed in 2006
For copies please write to:

Coordinator
ASIA-PACIFIC CONSORTIUM ON AGRICULTURAL BIOTECHNOLOGY
(APCoAB)
C/o ICRISAT, NASC Complex
Dev Prakash Shastri Marg, Pusa Campus
New Delhi - 110 012, India
FOREWORD
The Asia-Pacific Consortium on Agricultural Biotechnology (APCoAB) was established
in 2003 under the umbrella of the Asia-Pacific Association of Agricultural Research
Institutes (APAARI) an initiative of the Food and Agriculture Organization that has
been promoting appropriate use of emerging agri-technologies and tools in the
region. APCoABs mission is To harness the benefits of agricultural biotechnology for
human and animal welfare through the application of latest scientific technologies
while safeguarding the environment for the advancement of society in the Asia-Pacific
region.
The last decade has witnessed tremendous advances in the application of
biotechnology for crop improvement. APCoAB has been documenting achievements
in agricultural biotechnology that have led to improvements in crop productivity and
farm incomes in the Asia-Pacific region. The first approval of Bt cotton cultivation in
India was granted in the year 2002. Over the last four years, 20 Bt cotton hybrids,
presently covering an area of approximately 1.3 million hectares, have been
commercialized. Twenty additional Bt hybrids approved in April 2006 would be
available to farmers during the next cotton-growing season. This Status Report on Bt
Cotton in India gives details of the events that led to approval of the first Bt cotton
hybrids, performance of the commercialized hybrids under experimental as well as
farmer managed conditions, and the economic benefits realized from the adoption of
Bt technology. Based on the experiences gained, strategies have been suggested for
achieving improved pest resistance in cotton, revised protocol for large-scale field
trials and better economic benefits especially to small and marginal farmers.
This report, an in-house effort of APCoAB, has been prepared by Dr. J. L.
Karihaloo, Coordinator, Dr. R. K. Arora, ex-Consultant and Dr. Vibha Dhawan, exCoordinator, APCoAB. We acknowledge the help of several scientists, science
managers and policy makers in preparing this report. Especially, we express our
gratitude to Mr. Raju Barwale, Managing Director, Maharashtra Hybrid Seed Co.,
Mumbai, Dr. T. V. Ramniah, Director, Department of Biotechnology, Government
of India, Dr. B. M. Khadi, Director, Central Institute for Cotton Research, Nagpur,
Dr. P. Anand Kumar, Principal Scientist, National Research Centre on Biotechnology,
New Delhi, and Mr. B. Choudhary, National Coordinator, ISAAA, South Asia Office,
New Delhi for providing important information on research and development of
iv
Bt Cotton in India A Status Report
Bt cotton. We place on record our appreciation for Dr. James Clive, Chairman,
ISAAA for permitting the use of information and photographs from their reports in
this publication. Our thanks are also due to Dr. (Mrs.) Manju Sharma, ex-Secretary,
Department of Biotechnology, Government of India and Dr. S. R. Bhat, Principal
Scientist, National Research Centre on Biotechnology, New Delhi for their valuable
comments on the manuscript.
It is hoped that this publication will be of use to the scientists, research managers,
policy makers and the general public in the developing NARS of the Asia-Pacific
region who are interested in the application of biotechnology. The experiences
narrated in this report should help in evolving suitable systems of research, testing
and commercialization of transgenic crops for sustainability, productivity, greater food
security and poverty alleviation, while safeguarding the concerns of biosafety and
environmental protection. We are pleased that this is the second Status Report being
brought out by APCoAB, the first being on Bt Corn in Philippines.
(R.S. Paroda)
Executive Secretary
APAARI
CONTENTS
Foreword
iii
1.
Introduction
2.
National Regulatory Mechanism
3.
Development and Commercialization of Bt Cotton
Technology Involved
Chronology of Events
Trial Results
Biosafety Assessment
Risk Management
Other Safeguards
Field Performance and Socio-economic Impact
10
Conditions Stipulated by GEAC
10
Hybrids Approved
10
Commercial Cultivation
12
4.
Performance of Bt Cotton
15
5.
Emerging Concerns
21
Genetic Background
21
Low Bt Toxin Level
22
Refuge Crop
22
Genetic Uniformity of Cry Protein and Pest Resistance
23
Illegal Bt Cotton
23
Intellectual Property Rights Issues
24
Recommendations of National Commission on Farmers
24
vi
6.
Opportunities and the Way Ahead
26
7.
Epilogue
29
8.
Bibliography
31
Annexure I : Conditions Stipulated by MoEF for Release of

MECH-12 Bt, MECH-162 Bt and MECH-184 Bt
35
Annexure II : Acronyms
37
1. INTRODUCTION
Cotton cultivation in India covers an area of approximately 9 million hectares
representing about one quarter of the global area of 35 million hectares under cotton
(Sen, 2005). Cotton is planted by 4 million small farmers and involves many more
in processing, textile manufacture and trade. However, the average yield of cotton,
440 kg/ha, is far below the world average of 677 kg/ha and the production is only
about 16% (4.13 million tonnes) of the world production of 26.19 million tonnes
(Table 1). Main losses in cotton production are due to its susceptibility to about 162
species of insect pests and a number of diseases (Manjunath, 2004; Table 2). Among
the insects, cotton bollworms are the most serious pests of cotton in India causing
annual losses of at least US$300 million. The cotton bollworm complex comprises,
American bollworm, also called false America bollworm or old world bollworm,
Helicoverpa armigera; pink bollworm, Pectinophora gossypiella; spiny bollworm
Earias insulana and spotted bollworm, Earias vittella. Spodoptera litura, the leaf
worm, is mainly a foliage feeder but it also damages cotton bolls. Insecticides valued
at US$660 million are used annually on all crops in India, of which more than half
are used on cotton (Manjunath, 2004). Cost of the 21,500 metric tonnes (active
ingredient) of insecticides used on cotton in India in 2001 was US$340 million.
Further, the most destructive pest, Helicoverpa armigera, is known to have developed
resistance against most of the recommended insecticides (Kranthi et al., 2001;
Ramasubramanyam, 2004) forcing farmers to apply as many as 10-16 sprays.
Incorporating insect resistance has, thus, been the most important objective of cotton
improvement efforts in India. However, no sources of resistance to bollworm are
available in cotton germplasm or its near relatives.
In India, the efforts to harness genetic engineering technology for bollworm
resistance in cotton began in 1990s with the import of genetically modified (GM)
cotton and initiation of research programmes in national laboratories. At present, 40
cotton hybrids having gene for bollworm resistance have been approved for commercial
cultivation. The gene (cry) sourced from the soil bacterium Bacillus thuringiensis (Bt)
subspecies kurstaki produces a protein toxic to bollworm, thus providing resistance to
the plants and significantly reducing the need for chemical insecticides.
This report prepared by Asia-Pacific Consortium on Agricultural Biotechnology
(APCoAB), a programme operating under the umbrella of Asia-Pacific Association for
Table 1. Estimated cotton production and consumption during 2004-05 in major

cottonproducing countries of the world
Country
Production
Consumption
(million tonnes)
(million tonnes)
China
6.31
8.38
United States
5.06
1.41
India
4.13
3.26
Pakistan
2.46
2.34
Brazil
1.28
0.91
Uzbekistan
1.13
Turkey
0.90
1.52
Others
4.92
5.81
26.19
23.63
World Total
Source: Sen, 2005.
Table 2. Some major insect pests of cotton

Borers
Foliage feeders
Sap feeders
American bollworm
Leaf worm
Leaf hopper
Pink bollworm
Leaf roller
Aphid
Spiny bollworm
Semilooper
Whitefly
Spotted bollworm
Leaf perforator
Thrips
Stem weevil
Ash weevil
Red cotton bug
Shoot weevil
Surface weevil
Dusky cotton bug
Stem borer
Hairy caterpillar
Striped mealy bug
Red hairy caterpillar
Black scale
Cotton grasshopper
White scale
Tobacco budworm
Yellow star scale

Tea mosquito bug
Source: CICR, 2006.
Agricultural Research Institutes (APAARI), has attempted to provide the current status
of research and commercialization of Bt cotton, the first commercialized GM crop in
India. It is based on the reports emanating from both the public and private sectors.
Opinions expressed by different Civil Society Organizations (CSOs) have also been
included to present a broad spectrum of available information on the topic.
2. NATIONAL REGULATORY MECHANISM

Genetically modified crops are expected to play an important role in improving
agricultural production and economic betterment of farmers. It is also recognized that
the GM technology may entail rare unintended risks and hazards. Accordingly,
Government of India has adopted a policy of careful assessment of the benefits and
risks of GMOs at various stages of their development and field release to ensure
biosafety. The rules governing the handling of GMOs and products thereof were
notified in 1989 under Environment (Protection) Act 1986 (EPA) and guidelines
issued subsequently (Ghosh, 2001; http://www.envfor.nic.in/divisions/csurv/geac/
notification/html). Two nodal agencies, Ministry of Environment and Forests (MoEF)
and Department of Biotechnology (DBT), Ministry of Science and Technology are
responsible for implementation of the regulations. There are six Competent Authorities
to handle various issues, viz. Recombinant DNA Advisory Committee, Institutional
Biosafety Committee, Review Committee on Genetic Manipulation, Genetic
Engineering Approval Committee, State Biotechnology Coordination Committee and
District Level Committee. In general, these authorities are vested with non-overlapping
responsibilities.
Recombinant DNA Advisory Committee (RDAC): This committee is constituted
by DBT to monitor the developments in biotechnology at national and international
levels. RDAC submits recommendations from time to time that are suitable for
implementation for upholding the safety regulations in research and applications of
GMOs and products thereof. This committee prepared the first Indian Recombinant
DNA Biosafety Guidelines in 1990, which were adopted by Government of India for
handling of GMOs and conducting research on them. The guidelines were revised in
1998 (http://dbtindia.nic.in/thanks/biosafetymain.html and http://www.envfor.nic.in/
divisions/csurv/geac/biosafety.html).
Institutional Biosafety Committee (IBSC): This committee is constituted by
organizations involved in recombinant DNA (r-DNA) research. It has the mandate to
approve low-risk (Category I and II) experiments and to ensure adherence to r-DNA
safety guidelines. IBSC recommends category III or above experiments to Review
Committee on Genetic Manipulation (RCGM) for approval. It also acts as a nodal
agency for interaction with various statutory bodies.
Review Committee on Genetic Manipulation (RCGM): This committee is

constituted by DBT to review all ongoing projects involving high-risk (Category III
and above) and controlled field experiments. RCGM approves applications for
generating research information on transgenic plants. Such information may be
authorized to be generated in contained green house as well as in small plots. The
small experimental field trials are limited to a total area of 20 acres in multi-locations
in one crop season. In one location where the experiment is conducted with
transgenic plants, the land used should not be more than 1 acre. RCGM approval is
granted for one season and applicant must provide entire details of the experimentation
to the committee. Monitoring of field trials is carried out by Monitoring-cumEvaluation Committee of RCGM. The latter also directs the generation of toxicity,
allergenicity and any other relevant data on transgenic materials in appropriate
systems. RCGM can lay down procedures restricting or prohibiting production, sale,
importation and use of GMOs. It also issues clearances for import/export of etiologic
agents and vectors, transgenic germplasm including transformed calli, seed and plant
parts for research use only.
Genetic Engineering Approval Committee (GEAC): This committee functions
as a body in MoEF and is responsible for environmental approval of activities
involving large-scale use of GMOs in research, industrial production and applications.
Large-scale experiments beyond the limits specified within the authority of RCGM are
authorized by GEAC. GEAC can authorize approval and prohibitions of any GMOs
for import, export, transport, manufacture, processing use or sale.
State Biotechnology Coordination Committee (SBCC): This committee,
constituted in each state where research and application of GMOs are contemplated,
has the authority to inspect, investigate and take punitive actions in case of violations
of the statutory provisions. The committee also nominates state government
representatives in the committee constituted for field inspection of GM crops.
District Level Committee (DLC): This committee is constituted at the district
level to monitor the safety regulations in installations engaged in the use of GMOs in
research and applications. The District Collector heads the committee who can induct
representative from state agencies to enable the smooth functioning and inspection.
The overall mechanism and functional linkages among various committees and
departments concerned with the approval of GM crops for commercial release are
illustrated in a flowchart (Fig. 1).
National Regulatory Mechanism
Fig. 1. Procedure of approval of GM crops for commercial release. (Modified from Sharma et al., 2003).
3. DEVELOPMENT AND COMMERCIALIZATION

OF Bt COTTON
The first approval for commercial cultivation of Bt cotton in India was granted to
three cotton hybrids, MECH-12 Bt, MECH-162 Bt and MECH-184 Bt developed by
Mahyco (Maharashtra Hybrid Seed Co.), a leading seed company (Barwale, 2002;
Jayaraman, 2002). The insect resistance in these hybrids was introgressed from Bt
containing Cocker-312 (event MON531) developed by Monsanto, USA, into parental
lines of Mahycos propriety hybrids.
Technology Involved
The core genetic engineering experiments which culminated in development of
insect-pest resistant cotton (Bt cotton) were conducted by Monsanto, USA and
comprised isolation of gene from Bacillus thuringiensis and its further development
to ensure its expression in the fully grown plant. The plasmid construct comprised:
The cry1Ac gene, which encodes for an insecticidal protein, Cry1Ac.
The 35S promoter from Cauliflower mosaic virus that drives expression of the
cry1Ac gene in all parts of the plant leading to the production of Bt protein.
The nptII gene, the selectable marker, which encodes the enzyme neomycin
phosphotransferase II (NPTII). It is used to select transformed cells/plants on
media containing the antibiotic kanamycin.
The aad gene which encodes the bacterial selectable marker enzyme 3"(9)-Oaminoglycoside adenyltransferase (AAD) and allows selection of bacteria containing
the Cry1Ac plasmid on a medium containing spectinomycin or streptomycin.
Cotton tissue cultures (variety Cocker-312) were infected with the soil bacterium,
Agrobacterium tumefaciens containing the plasmid with the above sequences. The
transformed cotton lines were screened to identify those with desirable insect control
and agronomic performance.
Chronology of Events
Following several years of field trials with Bt cotton, based on the recommendations
of RCGM, GEAC in its 32nd meeting on 26 March, 2002 approved the commercial
cultivation of three Bt cotton hybrids: MECH-12 Bt, MECH-162 Bt and MECH-184
Bt (Barwale et al., 2004; http://www.envfor.nic.in/divisions/csurv/geac/bgnote.html).

The sequence of events that led to the development and approval of these is listed
below:
1996: After obtaining permission from DBT, Mahyco imported 100 g of Cocker-312
seed containing the cry1Ac gene from Monsanto, USA. Crossing with Indian cotton
breeding lines to introgress cry1Ac gene was carried out and 40 elite Indian parental
lines were converted for Bt trait.
1996-1998: Greenhouse, risk-assessment studies and limited field trials (1 location)
were conducted using Bt cotton seeds from converted Indian lines for pollen escape
studies, aggressiveness and persistence studies, biochemical analysis, toxicological
studies and allergenicity studies
1998-1999: Multi-location field trials were conducted at 40 locations in nine states to
assess agronomic benefits and biosafety.
1999-2000: Field trials repeated at 10 locations in six states.
July 2000: GEAC gave approval for conducting large-scale field trials on 85 ha and
also to undertake seed production on 150 ha.
2001: Large-scale field trials were conducted covering 100 ha. Field trials were also
conducted by All India Coordinated Cotton Improvement Project of the ICAR.
2002: GEAC approved three Bt cotton hybrids for commercial cultivation after taking
into account the data on their performances.
Trial Results
Mahyco conducted the following biosafety, risk management and field performance
trials on the Bt hybrids submitted for approval of GEAC. These studies were carried
out in the laboratories and experimental fields designated by RCGM/GEAC. Besides,
the socio-economic impact of Bt cotton cultivation was also assessed.
Biosafety Assessment
(i) Studies on Environmental Safety
Mahyco got the following studies conducted at a number of scientific institutes as per
the protocol approved by RCGM.
Pollen escape/out-crossing: Multi-location experiments conducted in 1996, 1997
and 2000 revealed that out-crossing occurred only up to two meters, and only 2%
of the pollen reached a distance of 15 m. As the pollen is heavy and sticky, the
range of pollen transfer is limited. The studies concluded that there is essentially
no chance that the Bt gene will transfer from cultivated tetraploid species such as
the present Bt hybrids to traditionally cultivated diploid species.
Aggressiveness and weediness: To assess the weediness of Bt cotton, the rate of
germination and vigour were compared with non-transformed parental lines by
laboratory test and in soil. The results demonstrated that there were no substantial
differences between Bt and non-Bt cotton for germination and vigour. Hence,
there is no difference between Bt and non-Bt cotton with regard to their
weediness potential.
Effect of Bt on non-target organisms: Studies conducted during the multi-location
field trials revealed that the Bt cotton hybrids did not have any toxic effects on
the non-target species, namely sucking pests (aphids, jassids, whitefly and mites).
The population of secondary lepidopteran pests, namely tobacco caterpillar
remained negligible during the study period in both Bt and non-Bt hybrids. The
beneficial insects (lady bird beetle and spiders) remained active in both Bt and
non-Bt varieties.
Presence of Bt protein in soil: Studies were conducted to assess the possible risk
of accumulation of Bt protein in the soil, by insect bioassays. Bt protein was not
detected in soil samples indicating that the Cry1Ac protein was rapidly degraded
in the soil in both the purified form of the protein and as part of the cotton plant
tissue. The half-life for the purified protein was less than 20 days. The half-life of
the Cry1Ac protein in plant tissue was calculated to be 41 days which is
comparable to the degradation rates reported for microbial formulations of Bt.
Effect of Bt protein on soil microflora: Studies were conducted to evaluate any
impact of Bt protein leached by roots of Bt cotton on the soil microflora. There
was no significant difference in population of microbes and soil invertebrates like
earthworms between Bt and non-Bt soil samples.
(ii) Studies on Food Safety
For evaluating food safety, the studies conducted included: compositional analysis,
allergenicity studies, toxicological studies, presence of Bt protein in Bt cotton seed oil,
and feeding studies on cows, buffaloes, poultry and fish. Salient results of these
studies are as follows:
Compositional analysis: Studies revealed that there was no change in the
composition of Bt and non-Bt cotton seeds, with respect to proteins, carbohydrates,
oil, calories and ash content.
Allergenicity studies: Allergenicity studies were conducted on Brown Norway rats.
No significant differences in feed consumption, weight gain and general health were
found between animals fed with Bt and non-Bt cotton seed. At the end of the
feeding period, the relative allergenicity of traditional cotton hybrids and Bt cotton
were compared to Bt and non-Bt protein extract in active cutaneous anaphylaxis
assays. Results of the study concluded that there was no significant change in
endogenous allergens of Bt cotton seed compared to non-Bt cotton seed.
Toxicological study: A goat feeding study was conducted for understanding the
toxicological effects of Bt cotton seed. The animals were assessed for gross
pathology and histopathology. No significant differences were found between
animals fed with Bt and non-Bt cotton seed.
Presence of Cry1Ac protein in Bt cotton seed oil: Studies have indicated that
Cry1Ac protein was not found in refined oil obtained from Bt cotton seeds.
Feeding studies on cows, buffaloes, poultry and fish: The feeding experiments
using Bt cotton seed meal were conducted at National Dairy Research Institute,
Karnal, on lactating cows; Department of Animal Nutrition, College of Veterinary
Sciences, G.B. Pant University of Agriculture & Technology, Pantnagar, on
lactating buffaloes; Central Avian Research Institute, Izatnagar, on poultry and
Central Institute of Fisheries Education, Mumbai, on fish. These experiments
indicated that Bt cotton seed meal was nutritionally as wholesome and safe as the
non-Bt cotton seed meal.
Risk Management
Pest populations exposed to Bt crops continuously for several years may develop
resistance to the Bt toxin through natural mutation and selection. To prevent
resistance build-up, it is recommended to plant sufficient non-Bt crops to serve as a
refuge for Bt-susceptible insects. Growing 20% non-Bt cotton in the periphery of Bt
cotton as refuge and taking necessary control measures against bollworm in the
refuge crop as and when required has been found to be adequate (Ghosh, 2001).
The refuge strategy is designed to ensure that Bt-susceptible insects will be available
to mate with Bt-resistant insects, should they arise. Available genetic data indicates
that susceptibility is dominant over resistance (Tuli et al., 2000). The offsprings of
these matings would most likely be Bt-susceptible, thus mitigating the spread of
resistance in the population.
Other Safeguards
Baseline Susceptibility Study
Project Directorate of Biological Control, Bangalore, carried out baselinesusceptibility study of Helicoverpa armigera to Cry1Ac protein in 1999 and 2001.
Geographical populations of H. armigera collected from nine major cotton-growing
states of India, viz. Punjab, Haryana, Rajasthan, Madhya Pradesh, Gujarat,
Maharashtra, Andhra Pradesh, Karnataka and Tamil Nadu were exposed to insecticidal
10
protein Cry1Ac through bioassays. LC50 (mean lethal concentration) ranged from
0.14 to 0.71 and LC90 from 1.02 to 6.94 g of Cry1Ac/ml of diet (Jalali et al., 2004).
The median molt inhibitor concentration MIC50 ranged from 0.05 to 0.27, and MIC90
from 0.25 to 1.58 g of Cry1Ac/ml of diet. The effective concentration (weight
stunting related) EC50 ranged from 0.0003 to 0.008 and EC90 from 0.009 to 0.076 g
Cry1Ac/ml of diet.
Confirmation of the absence of Terminator Technology
As per requirements, molecular detection test in the Bt cotton hybrids was performed
for cre recombinase gene which is an integral component of the so called terminator
technology. The study was carried out by the Department of Genetics, University of
Delhi (South Campus), Delhi. The PCR analysis of DNA samples isolated from
individual seedlings derived from Bt cotton hybrids showed that these lines were
positive for Cry1Ac genes but did not contain cre sequence. This conclusively
demonstrated the absence of terminator gene in Bt cotton hybrids.
Field Performance and Socio-economic Impact

On the recommendation of RCGM, two sets of replicated field trials were conducted
in 1998-99 to test the performance of the three Bt hybrids, MECH-12 Bt, MECH-162
Bt and MECH-184 Bt. In addition, ICAR conducted multi-location field trials in 2001
on these hybrids especially to make a cost benefit analysis of Bt cotton. Detailed
results of these studies are given in Chapter 4. In brief, the results proved the
effectiveness of Bt technology in reducing bollworm infestation and the number of
insecticide sprays, and increasing cotton yields and net incomes.
Conditions Stipulated by GEAC

The approval given to three Mahyco Bt hybrids for commercial release was
accompanied by 15 conditions as listed in Annexure I. MoEF also reserved the right
to stipulate additional conditions and the right to revoke the approval, if the
implementation of the conditions was not satisfactory.
Hybrids Approved
Till date, 40 Bt cotton hybrids developed by 13 seed companies have been approved
for commercial cultivation (Table 3) after going through a similar process of GEAC
approval as prescribed for the three Mahyco hybrids. All the hybrids, except four, have
the Monsanto-Mahyco Bt technology (event MON531) that has been sublicensed to the
respective seed companies (Rao, 2005; http://www.envfor.nic.in/divisions/csurv/geac/
geac-65.pdf). JKCH-1947 Bt and JK Varun Bt contain cry1Ac event 1 developed by
Indian Institute of Technology, Kharagpur while NCEH-2R Bt and NCEH-6R Bt contain
fusion genes cry1Ab/cry1Ac from China. The hybrids released up to 2004 were approved
11
for cultivation in Central and South Zones while in 2005, six Bt hybrids were for the
first time approved for cultivation in North Zone. Zone-wise, 14, 24 and 9 hybrids are
presently approved for growing in North, Central and South Zones, respectively.
Table 3. Bt cotton hybrids approved by GEAC for commercial cultivation
Hybrid
Year
Zone
Company
ACH-33-1Bt, ACH-155-1 Bt
2006
Central
Ajeet Seeds
Ankur-09 Bt
2005
Central
Ankur Seeds
Ankur-651 Bt
2005
North and Central
Ankur Seeds
Ankur-2534 Bt
2005
North
Ankur Seeds
Brahma BG
2006
Central
Emergent Genetics
GK 205 Bt
2006
Central
Ganga Kaveri Seeds
JK Varun Bt
2006
Central
JK Seeds
JKCH-1947 Bt
2006
North
JK Seeds
MECH-12 Bt*, MECH-162 Bt**, MECH-184 Bt**
2002
Central and South
Mahyco
MRC-6025 Bt, MRC-6029 Bt
2006
North
Mahyco
MRC-6301 Bt
2005
North and Central
Mahyco
MRC-6304 Bt
2005
North
Mahyco
MRC-6322 Bt, MRC-6918 Bt
2005
South
Mahyco
NCEH-2R Bt
2006
central
Nath Seeds
NCS-138 Bt, NCS-913 Bt
2006
North
Nuziveedu Seeds
NCS-145 Bunny Bt, NCS-207 Mallika Bt
2005
Central and South
Nuziveedu Seeds
NECH-6R Bt
2006
North
Nath Seeds
PRCH-102 Bt
2006
Central
Pravardhan Seeds
RCH-2 Bt
2004
Central and South
Rasi Seeds
RCH-20 Bt, RCH-368 Bt
2005
South
Rasi Seeds
RCH-118 Bt, RCH-138 Bt, RCH-144 Bt
2005
Central
Rasi Seeds
2005
North
Rasi Seeds
2006
North
Rasi Seeds
RCH-377 Bt
2006
Central
Rasi Seeds
Tulasi 4 Bt
2006
Central
Tulasi Seeds
VICH-111 Bt
2006
Central
Vikki Agrotech
VICH-5 Bt, VICH-9 Bt
2006
Central
Vikram Seeds
*Discontinued from South Zone. **Not approved for Andhra Pradesh.

North Zone: Haryana, Punjab and Rajasthan. Central Zone: Gujarat, Madhya Pradesh and
Maharashtra. South Zone: Andhra Pradesh, Karnataka and Tamil Nadu.
Source: Choudhary, 2005; DBT, 2006; http://www.envfor.nic.in/divisions/csurv/geac/geac-65.pdf
12
Commercial Cultivation
Following the approval of GEAC, commercial cultivation of Bt cotton was undertaken
during 2002 in six states in India: Andhra Pradesh, Gujarat, Madhya Pradesh,
Karnataka, Maharashtra and Tamil Nadu (Barwale et al., 2004). The three Bt hybrids
approved for cultivation covered a total area of 0.038 million hectares in this year
(Table 4).
Table 4. Area in hectares under commercial cultivation of Bt cotton hybrids during 2002
State
Area under Bt hybrids (ha)

MECH-12
MECH-162
Total (ha)
MECH-184
Andhra Pradesh
44
5,564
5,608
Gujarat
76
4,136
4,642
8,854
Madhya Pradesh
60
404
1,756
2,220
3,828
80
3,908
112
9,300
5,334
14,746
2,042
660
2,702
292
25,274
12,472
38,038
Karnataka
Maharashtra
Tamil Nadu
Total
Source: Barwale et al., 2004.
Fig. 2. Year-wise sale of 450 g seed packets of Bt cotton hybrids MECH-12 Bt, MECH-162 Bt and
MECH-184 Bt
Source : DBT, 2006.
13
The seed companies are required to submit to GEAC the yearly sales figures of
Bt cotton seed in different states. The seeds are sold in packets containing 450 g Bt
seed and 120 g of non-Bt seed, sufficient to plant one acre of Bt cotton and required
refuge. According to the figures available with DBT, the year-wise sale of 450 g seed
packets of the three MECH Bt hybrids released in 2002 increased from 73,000 to
913,000 in 2004 (Fig. 2). The release of 17 other Bt hybrids during 2004 and 2005
and the first approval for cultivation of Bt hybrids in North India vastly increased the
opportunity for farmers to adopt Bt technology. The number of Bt cotton seed packets
sold in 2005 was 3.1 million accounting for an area of 1.26 million hectares (Table
5). The latter comprises 14% of the 9 million hectares under cotton cultivation in India.
Table 5. Year-wise cultivation of Bt cotton hybrids
Year
Seed packets
sold*
Area covered
(million ha)
2002
72,682
0.29
2003
213,098
0.86
2004
1,326,134
0.55
2005
3,102,067
1.26
*Source: DBT, 2006.
Among the nine states in which Bt cotton was cultivated, Maharashtra, Andhra
Pradesh, Gujarat and Madhya Pradesh were leading with 49.7%, 18.1%, 11.8% and
11.4% of the national Bt cotton acerage, respectively (Fig. 3). Central Zone showed
the highest adoption of Bt cotton followed by South and North Zones (Fig. 4).
Fig. 3. State-wise area covered (thousand hectares) under Bt cotton during 2005.
Source of basic data: DBT, 2006.
14
Fig. 4. Bt cotton hybrids under commercial cultivation during 2005 in three cotton-growing zones of
India. Figures in circles represent area in million hectares under Bt cotton in each zone.
4. PERFORMANCE OF Bt COTTON
Several studies have been made on field performance of Bt cotton in India, initially
by the seed companies as a part of the approval procedure of RCGM and GEAC and
later by research scientists/organizations as independent studies or by CSOs. The first
section presents results of studies either monitored by RCGM and GEAC or carried
out by research scientists/organizations.
Two sets of field experiments were conducted by Mahyco in 1998-99 under the
monitoring of RCGM. In one set, MECH-12 Bt, MECH-162 Bt and MECH-184 Bt
along with their non-Bt counterparts were tested in replicated field trials at 15 sites
in nine states while in the other set, one Bt and one non-Bt hybrid along with check
were tested on large plots at 25 sites under typical farm conditions. Results of the first
set of experiments indicated a 40% higher yield of Bt hybrids (14.64 q/ha*) over their
non-Bt counterparts (10.45 q/ha) (James, 2000). Further, there was a significantly
lower incidence of bollworm damage to fruiting bodies in Bt hybrids (2.5% at 61-90
days from planting) than in non-Bt hybrids (11.4% at 61-90 days from planting).
The large-plot field trials at 21 sites (4 trials were damaged) yielded similar results
with Bt hybrids showing 37% (range 14% to 59%) higher yield over their non-Bt
counterparts (Table 6). The overall pesticide requirement for controlling bollworm
was reduced considerably.
Table 6. Results of Bt cotton field trials conducted by Mahyco at 21 sites during 1998-99
State
Number of
locations
Yield q/ha
Non-Bt
Bt
Number of sprays
Check
Non-Bt
Bt
Check
Andhra Pradesh
9.63
11.98
8.68
Gujarat
24.91
38.89
28.45
1.5
Haryana
12.42
15.83
9.06
Karnataka
10.01
13.62
9.20
Madhya Pradesh
14.20
20.30
14.04
Maharashtra
17.22
22.30
18.44
Tamil Nadu
3.70
10.12
4.40
13.59
18.61
13.75
0.5
Average
Source of basic data: Naik, 2001.
*Quintals (100 kg) per hectare
16
The data generated from the above detailed multi-location tests were analysed by
Naik (2001) to assess the potential economic advantage of Bt cotton in India. The
results showed that there was 78.8% increase in the value due to yield and 14.7%
reduction in pesticide cost with the growing of Bt cotton as compared to non-Bt
cotton (Table 7). When compared with the prevalent farmers practices, the benefit
from Bt cultivation increased to 110%. Taking into account the additional cost of Bt
seeds, the farmer would still get more than 70% greater benefits. The author further
opined that the reduction in expenditure on pesticides would adequately compensate
for the seed/technology cost increase. Hence, the total cost of cultivation of Bt cotton
would not increase making it possible for even small farmers to adopt the technology.
Table 7. Economic benefits of Bt cotton as estimated from 1998-99 field trials conducted
by Mahyco
Item
Average of
six states
% over average
net return
Value of the yield

increase over
non-Bt (per ha)
Value of reduced
pesticide over
non-Bt (per ha)
Total benefit
over non-Bt
(per ha)
Benefit over
farmer practices
(per ha)
Rs 11,554.7
(US$262.6)*
Rs 2,148.9
(US$48.8)
Rs 13,703.6
(US$311.4)
Rs 16,126.6
(US$366.5)
78.8
14.7
93.5
110.0
Source of basic data: Naik, 2001; *Rs 44 = 1 US$.
ICAR conducted multi-location field trials in 2001 on the three Mahyco Bt hybrids
specifically to make a cost benefit analysis of Bt cotton. Yield increases over local
check and national check were recorded to the magnitude of 60% to 92% (ISAAA,
2002) and gross income showed a 67% advantage from average Rs 14,112 (US$320.7)/
ha in local and national check to average Rs 23,604 (US$536.5)/ha in the
Bt hybrids. After adjusting the additional cost of Bt hybrid seed the net economic
advantage of Bt cotton ranged between Rs 4,633 (US$105.2)/ha and Rs 10,205
(US$231.9)/ha (ISAAA, 2002, Table 8).
In a widely quoted article, Qaim and Zilberman (2003) reported the results of
data collected from 157 farms in 25 districts of Maharashtra, Madhya Pradesh and
Tamil Nadu growing three Mahyco Bt hybrids along with their counterparts and a
local check as a part of RCGM recommended trial. On average, Bt hybrids received
three times less sprays against bollworm than non-Bt hybrids and local checks (Bt,
0.62; non-Bt, 3.68; local check, 3.63). The number of sprays against the sucking pests
was, however, same among the three. Insecticide amounts on Bt cotton were reduced
by about 70% both in terms of commercial products and active ingredients. More
interestingly, the article reported higher average yield of Bt hybrids exceeding those
17
Table 8. Performance of Bt cotton hybrids in ICAR field trials

Variety/hybrid
Yield
q/ha
Gross
income/ha
Insecticide
cost/ha
Additional
cost of Bt
seed/ha
Net income/ha
Rs
US$
Rs
US$
Rs
US$
Rs
US$
MECH-12 Bt
11.67
21,006
477.4
1,727
39.3
2,425
55.1
16,854
383.0
MECH-162 Bt
13.67
24,606
559.2
1,413
32.1
2,425
55.1
20,768
472.0
MECH-184 Bt
14.00
25,200
572.7
1,413
32.1
2,425
55.1
21,362
485.5
Local check
8.37
15,066
342.4
2,845
64.7
12,221
277.8
National check
7.31
13,158
299.1
2,001
45.5
11,157
253.6
Source of basic data: ISAAA, 2002.
of non-Bt counterparts and popular checks by 80% and 87%, respectively. Analysis
of the results showed that the general germplasm effect was negligible and the yield
gain was largely due to Bt gene itself. The authors further argued that the expected
yield effects of pest-resistant GM crops would be high in South and Southeast Asia
and Africa and medium to low in developed countries, China and Latin America. In
India, the pest damage in 2001 was about 60% in conventional trial plots whereas
in USA and China, estimated losses in conventional cotton due to insect pests
amounted to only 12% and 15%, respectively.
The above study was criticized in two subsequent articles (Arunachalam and Bala
Ravi, 2003; Sahai, 2003) on the argument that the study sites chosen did not cover
the entire spectrum of cotton-growing areas in India, the data collection and analysis
were faulty and that the reported yield effect of Bt gene was scientifically untenable.
Bennett et al. (2004) presented an assessment of the performance of Bt cotton
under typical farmer-managed conditions. Unlike previous studies, it analysed
commercial field data rather than trial plot data collected in Maharashtra from 9,000
farmers plots in 2002 and 2003. The study met the recommendations of FAO (2004)
for market-based studies that would accurately reflect the agronomic and economic
environments faced by growers. Over both the seasons, the number of sprays
required to control sucking pests (aphids and jassids) was similar for Bt and non-Bt
plots. However, the number of sprays required for bollworm was much lower for Bt
plots (1.44 for Bt versus 3.84 for non-Bt during 2002 and 0.71 for Bt versus 3.11 for
non-Bt during 2003). There was a corresponding reduction of 72% and 83% in 2002
and 2003, respectively, in expenditure. However, when balanced with higher cost of
Bt cotton seed, the results showed higher average costs for Bt cultivation compared
to non-Bt cultivation (15% and 2% in 2002 and 2003, respectively). The real benefit
came from the higher yield of cotton in Bt plots; in 2002, the average increase in
18
yield for Bt over non-Bt was about 45% while in 2003 this was 63%. Taking into
account the seed cost and variable cotton prices, the results showed a much higher
gross margin for Bt growers [(Rs 50,904/ha) (US$1,156.9)] than for non-Bt growers
[(Rs 29,279/ha) (US$665.4)] during 2003.
Bambawale et al. (2004) reported performance of MECH-162 Bt along with nonBt MECH-162 and a conventional variety/hybrid under integrated pest management
(IPM) in farmers participatory field trials conducted in Maharashtra. Under IPM,
11.5% of the fruiting bodies were damaged in MECH-162 Bt compared to 29.4% in
conventional cotton and 32.88% in non-Bt MECH-162. Population of sucking pests
was also lower in MECH-162 Bt. Seed cotton yield in MECH-162 Bt (12.4 q/ha) was
much higher than that of non-Bt MECH-162 (9.8 q/ha) and conventional cotton (7.1
q/ha). Net returns after taking into account cost of production and protection were Rs
16,231/ha (US$368.9) in MECH-162 Bt, Rs 12,433/ha (US$282.6) in non-Bt MECH162 and Rs 10,507/ha (US$238.8) in conventional cotton.
Notwithstanding the doubts raised by some workers (Arunachalam and Bala Ravi,
2003; Sahai, 2003), the overall finding of above detailed studies establish that Bt
cotton has significantly lower infestation of bollworms compared to non-Bt cotton
leading to fewer number of sprays required for bollworm control. The reduced pest
infestation is also associated with higher cotton yields, a major factor contributing to
economic advantage of Bt cotton in India (Figs. 5-10).
Other Reports: In 2003, ACNielsen ORG-MARG, unit of a Dutch publishing and
Fig. 5. Bt cotton hybrid MRC6304 Bt laden with bolls.
Fig. 6. Field view showing MRC-6304 Bt (left) and non-Bt cotton

(right). Note the prominently higher boll retention in the Bt hybrid.
Source: Mahyco.
Source: Mahyco.
19
Fig. 7. Non-Bt cotton being sprayed for pest

control.
Fig. 8. Spotted bollworm damaged cotton boll

from the field shown on the left.
Source: ISAAA.
Source: ISAAA.
information group, conducted a survey of more than 3,063 farmers in Andhra

Pradesh, Madhya Pradesh, Maharashtra, Gujarat and Karnataka growing Bt and nonBt cotton (ACNielsen ORG-MARG, 2004). The survey revealed that due to control of
bollworm, on an average Bt crop had an increase in yield by 29% and reduction in
pesticide sprays by 60% as compared to non-Bt cotton. The net profits thus accrued
averaged Rs 7,724(US$175.5)/ha). In this survey, 90% of the Bt cotton growers and
42% of the non-Bt growers expressed their intention to purchase Bt cotton seeds in
2004.
Gene Campaign conducted a survey of 100 farming families in Maharashtra and
Andhra Pradesh growing both Bt and non-Bt cotton (Sahai and Rahman, 2003). The
survey reported that: (i) Bt cotton yields were 15% lower than that of non-Bt cotton,
(ii) Bt cotton was of lower quality in terms of length and strength of fibre, and (iii)
the average net returns from Bt varieties were lower than those from non-Bt varieties.
Mahyco made a survey of the performance of their three Bt hybrids, MECH-12
Bt, MECH-162 Bt and MECH-184 Bt grown on over 1,000 farmers fields in five
states after their release in 2002 (Barwale et al., 2004). Yields of Bt hybrids (average
13.25 q/ha) were higher by an average of about 30% over non-Bt hybrids. Further,
there was significant decrease in the number of insecticide sprays (from an average
of 3.10 to 1.17) associated with the use of Bt cotton. These two factors added to the
total economic benefit providing an average additional income of more than Rs
18,000(US$409.1)/ha for Bt compared to non-Bt cotton.
Deccan Development Society and AP Coalition in Defense of Diversity conducted
a three year study (2002-03 to 2004-05) in four cotton-growing districts of
Pradesh, viz. Adilabad, Kurnool, Nalagonda and Warangal covering 440 farmers
growing Bt and non-Bt cotton under irrigated and rainfed conditions (Qayum and
20
Fig. 9. Bountiful yield from Bt cotton.
Fig. 10. Harvested Bt cotton being marketed.
Source: ISAAA.
Source: ISAAA.
Sakkhari, 2005). The study concluded that: (i) on small farms under rainfed
conditions, Bt cotton yielded nearly 30% less than non-Bt, (ii) there was a 7% cost
reduction on pesticides with the adoption of Bt, and (iii) the earnings with non-Bt
cotton cultivation were 60% more than with Bt cotton cultivation.
Gokhle Institute of Politics and Economics, Pune, conducted comparative study of
Bt and non-Bt cotton during Kharif 2003 in two prominent cotton-growing districts of
Maharashtra, Yavatmal and Buldhana (Vaidya, 2005a, b). The study involving 150
cotton farmers reported that substantially higher profits (79.2%) were realized from
Bt cotton cultivation [Rs 31,880/ha (US$724.5)] compared to non-Bt cotton cultivation
[Rs 17,790/ha (US$404.3)]. However, similar returns were not observed under
rainfed conditions and the report called for comprehensive study covering the crop
under both irrigated and rainfed areas to find out whether Bt cotton can be cultivated
without any risk under rainfed conditions. The study further noted complaints of
bollworm and other pest disease attacks in Bt cotton.
5. EMERGING CONCERNS
Bt cotton has evoked unprecedented interest and emotion among a large section of
Indian public comprising biotechnologists, plant breeders, social scientists,
environmentalists and CSOs. The amount of ongoing debate can be gauged from the
fact that a Google search for Bt cotton in India generates more than six hundred
thousand hits. The present publication is not intended to cover the entire spectrum
of opinion expressed on Bt cotton in India. That some of it can be ignored without
prejudicing the scientific facts is evident from widely reported incidents of 1998 and
1999 when activists of Karnataka Rajya Raitha Sangha uprooted and burnt
experimental plots of Bt cotton on the pretext that they contained Terminator
technology and they would cause gene pollution and sterility in surrounding plants
(http://www.krrsbtcottonsetafire.8m.com/; Manjunath, 2004). Nevertheless, some
genuine concerns have been reported from time to time in popular media and
scientific publications. NGOs like Gene Campaign, Centre for Sustainable Agriculture,
and Research Foundation for Science Technology and Ecology have been expressing
opinions about the performance and desirability of GM crops in general and Bt
cotton in particular for Indian agriculture and social environment. Some of the major
concerns that have not been covered in earlier chapters are presented below.
Genetic Background
As detailed in Chapter 4, some Bt cotton hybrids have been reported to perform
poorly under unirrigated conditions while others have yielded inferior quality cotton
staple (Arunachalam and Bala Ravi, 2003; Vaidya, 2005a, b). These observations
suggest that the genetic backgrounds in which the cry gene was introduced were not
the most desirable ones. The need for appropriate genetic background was further
highlighted in a recent article (Kranthi et al., 2005) which reported variation in Bt
toxin levels among eight commercial Bt cotton hybrids. Since all these hybrids have
the same cry gene (event MON531 in Cocker-312), the variation in toxin expression
has been attributed by the authors to the parental background of the hybrids. They
have suggested that the seed companies should evaluate their hybrids critically for
highest levels of toxin expression in fruiting bodies. This suggestion could be
extended to include the need for critical pre-release evaluation for all economic traits
under different agronomic situations so as to ensure high field performance and
remunerative prices for the produce.
22
Concern has also been expressed about the non-availability of Bt technology in

true breeding varieties (Sahai, 2005). In order to save seed cost, innocent farmers are
using seeds harvested from the F1 hybrids for planting next crop with disastrous
consequences. It is also alleged that even some unscrupulous traders are resorting to
this practice (see below). In India, the strategy for Bt incorporation in hybrid cotton
has been to transfer the gene into one of the parent lines of F1 commercial hybrids.
Thus, the hybrids are hemizygous for cry gene. When seeds from such hybrids are
used for planting (i.e. F2 seeds), 25% of the progeny plants would not carry the gene
at all and, hence, would be completely prone to bollworm attack. Thus, the use of
farmer-saved seeds gives a mixed stand of resistant and susceptible plants. Other
agronomically important traits show similar variation over generations. Comparative
studies on official Bt hybrids, unofficial Bt hybrids (seeds saved by farmers or
illegal Bt hybrids) and non-Bt hybrids grown in Gujarat state (Morse et al., 2005)
revealed that the gross margin of official Bt hybrids was 132% that of the non-Bt
varieties. The first generation "unofficial" seeds were the next best performers in terms
of gross margin, followed by second generation "unofficial" seeds.
Low Bt Toxin Level

A recent publication (Kranthi et al., 2005) reported a critical minimum level of 1.9
g/g of toxin in plant tissue to be essential for bollworm mortality. The leaves of Bt
cotton were found to have the highest levels of toxin expression followed by squares,
bolls and flowers. The toxin expression in the boll-rind, square and ovary of plants
was found to be inadequate to confer full protection to the fruiting parts. Cry1Ac
expression decreased consistently as the plant aged, the decline being more rapid in
some hybrids than others. This report was interpreted by some (Sahai, 2005) as the
failure of Bt cotton in India. However, the author of the earlier report published a
rejoinder arguing that Bt cotton is the most potent and best available option for
bollworm management in the country (Kranthi, 2005). Continuing the debate,
Manjunath (2006) opined that since bollworm starts its life cycle in the leaves and the
newly hatched larvae feed on chlorophyll in the tender leaves, the presence of high
level of Cry1Ac toxin in the leaves ensures the death of a large number of larvae.
Refuge Crop
One of the conditions for environmental release of Bt cotton, which includes
commercial cultivation, is that each field of Bt cotton is to be surrounded by a belt
of non-Bt cotton of the same variety to serve as a refuge for bollworms. The size of
the refuge belt should be either five rows of non-Bt cotton or 20% of total sown area
whichever is more. Due to small land holdings, these norms are not followed in
Emerging Concerns
23
practice which could lead to rapid build-up of Bt toxin resistance in bollworm.

However, some workers have questioned the need for refuge in the Indian farming
situations (Manjunath, 2004, 2005). The author argued that Helicoverpa armigera,
the most predominant bollworm in India has a large number of alternative hosts like
chickpea, pigeonpea, sorghum and tomato which serve as its natural refuge. Further,
since at present only about 14% of the cotton area is under Bt hybrids, the rest of
the non-Bt crop and other surrounding crops already serve as a refuge.
Genetic Uniformity of Cry Protein and Pest Resistance

All the 20 cotton hybrids under commercial cultivation in India have the same source
of resistance to bollworm, cry1Ac gene transferred through transformation event
MON531 in Cocker-312. The same technology is being utilized by several seed
companies for developing new Bt cotton hybrids (PTI, http://www.envfor.nic.in/
divisions/csurv/geac/geac-65.pdf). Resistance developed by the insect to protein toxin
encoded by this cry1Ac gene will make all the hybrids equally susceptible to
bollworm and pose a serious threat of widespread breakdown of resistance to the
insect. The need for using diverse resistance genes and pyramiding more than one
such gene in a hybrid/variety has been emphasised by a number of workers
(Krattiger, 1997; Tuli et al., 2000).
Illegal Bt Cotton
The high demand for Bt cotton has spawned a parallel industry of unapproved Bt
cotton seed which is of dubious origin and quality. In fact, illegal Bt cotton seed was
in the market even before the first approval of Bt cotton for commercial cultivation
was granted by GEAC (Jayaraman, 2001, 2004b). A recent news report
(Sainath, 2005) states that against 90,000 seed packets of legal Bt cotton sold in
Yavatmal district of Maharashtra the number of illegal packets sold was 250,000.
According to field reports of Research Foundation for Science Technology and
Ecology, illegal Bt cotton sold under 32 different names was sown in 2004 season
(Sharma, 2005). Not having been approved by GEAC, production, sale and use of
such seeds is a violation of rules and liable to punitive action under the EPA period.
Concerned by the reports of illegal Bt cotton being sold in Gujarat, GEAC got ten
packets of such seeds tested at Central Institute for Cotton Research, Nagpur, for
verification (http://www.envfor.nic.in/divisions/csurv/geac/vrguj.doc). PCR and ELISA
t e s t s re v e a l e d t h e p re s e n c e o f c r y 1 A c g e n e i n a l l t h e s a m p l e s .
Eight of these were F1 seeds while two were F2 seeds, one of the latter also having
mixtures.
24
Intellectual Property Rights Issues

The Plant Variety Protection and Farmers Rights Act 2001 of India has a crucial
provision according to which farmers are allowed to save, use, sell and exchange
seeds of a protected variety, the restriction being that the seed cannot be sold under
the breeders registered name (Brahmi et al., 2004). The cry1Ac MON531 technology
for incorporating bollworm resistance in cotton is patented in USA. While the nonBt hybrid seed is sold at approximately Rs 450 (US$10.2) per 450 g packet, the Bt
hybrid seed is sold at Rs 1,500 (US$35.2) to Rs 1,800 (US$40.9) per packet of which
Rs 1,250 (US$28.4) is charged towards trait value or technology fees (Mitta,
2006). Andhra Pradesh government has filed a case under Monopolies and Restrictive
Trade Practices Act claiming that the Indian farmers have to pay unusually high rates
for the trait value of Bt seed. On the other hand, the seed companies claim that
the Bt seed saves 4-5 insecticide sprays and gives a higher net profit to the farmer.
Recent reports of an agreement on a 30% reduction in technology fee of Bt cotton
seed is a welcome development (http://www.newkerala.com/news2.php?action=
fullnews&id=21312).
Another intellectual property related issue of concern is the restriction imposed on
commercialization of gifted or borrowed cry genes. Substantial research has been
done in public sector laboratories using gifted cry genes, but the efforts have not
culminated in release of commercial varieties since the genes were available for
academic and experimental purposes only and the required authorisation for their
commercialization could not be negotiated.
Recommendations of National Commission on Farmers

The National Commission on Farmers headed by Dr M.S. Swaminathan held
consultations with farmers on September 22, 2005. Information dated November 19,
2005 posted online by the Indian Society for Sustainable Agriculture provided details
of some concerns expressed on Bt cotton. Although none of the farmers reported
cases of any health, food or environmentally negative effects of Bt cotton, some
expressed concerns about the possible risks. Several farmers emphasized the need for
a cautious approach while exploiting GM technology and asked for a science-based
pre- and post-release testing and monitoring. The commission recorded that
Inadequate testing under the major cotton-growing agroclimatic conditions is a
serious problem. The commission also observed that Genetic literacy (amongst
farmers) has been generally low as most of the Bt cotton farmers grew no refugia and
did not provide recommended isolation distances needed for preventing crosspollination between Bt and non-Bt strains so as to reduce the chances for breakdown
of resistance to bollworm in Bt cotton varieties. A general misgiving prevails, may be
Emerging Concerns
25
partly due to aggressive advertisement by seed companies, that the Bt cotton needs
no pesticide applications, forgetting that the Bt provides protection (often not 100%)
only against bollworms. For controlling other pests, which at times assume serious
proportions, such as aphids and whitefly, pesticides will need to be applied as per
recommendations. The commission noted that some participants reported failure of
Bt cotton due to drought and multiple pest epidemics, while reporting additional net
profit of at least about Rs 12,000 (US$272.7) per hectare and about 40% to 50%
savings in the pesticide use and in the number of sprays. The commission also
expressed grave concern over proliferation of spurious Bt cotton seeds and suggested
that in order to curb this trend, The company must compensate the losses incurred
by the farmer. It also suggested insurance cover to be provided along with the sale
of GM seeds.
6. OPPORTUNITIES AND THE WAY AHEAD

Bt cotton has been under commercial cultivation in India since 2002. During these
four years, the number of Bt cotton hybrids released for cultivation has risen from 3
to 40 and the cultivated area under these hybrids has expanded to approximately 1.3
million hectares. Initially, GEAC had approved Bt cotton cultivation in Central and
South Zones. In 2005, approval was granted for cultivation of six hybrids in North
Zone, thus providing opportunity to cotton growers from almost the entire country to
benefit from Bt technology. During these years of technology demonstration, field
verification and commercialization, the feedback received from farmers, members of
the monitoring and evaluation teams, officials of the seed companies and state
agricultural departments, and NGOs provided important insight into the issues
involved in farmers field level application of this technology. These issues are related
to the technology per se, field evaluation, performance under different agroclimatic
conditions and trade.
Diversifying the insect toxin sources is essential to overcome the possibility of
bollworms developing resistance to Cry1Ac toxin as also to incorporate resistance to
a wider spectrum of insect pests. This is all the more important since many farmers
believes Bt cotton to be indestructible and do not take any protective measures
against pests and diseases (Sridharan et al., 2006). Worldwide, several microbial
genes for pest resistance have been identified and are at different stages of deployment
in cotton (Agbios, 2006; Table 8). Event MON531 commercialized as Bollgard has
been followed by Monsanto with event 15985 (Bollgard II). The latter, having the
dual genes cry1Ac and cry2Ab, is expected to provide growers with broader control
over a wide variety of insects like cotton bollworm, fall armyworm, tobacco budworm
and pink bollworm (Marchosky et al., 2001; Perlak et al., 2001). Syngenta Seeds has
commercialized COT102 containing vip3A(a) gene that imparts resistance, among
others, to cotton bollworm, tobacco budworm, pink bollworm and fall armyworm
(Agbios, 2006). Chinese Academy of Agricultural Sciences (CAAS) has developed a
modified fusion gene, cry1Ab/cry1Ac, which has been incorporated in more than ten
cotton varieties that are being grown over large areas in China (Dong et al., 2004).
Further, cowpea trypsin inhibitor gene, CPTi with a different mechanism of insect
resistance has been stacked with cry in cotton varieties by CAAS. In India, the fusion
gene has been incorporated in cotton hybrids NCEH-2R Bt and NCEH-6R Bt. Within
the Indian public sector, significant progress has been made to develop indigenous
Opportunities and the Way Ahead
27
genes for deployment in local true breeding cotton varieties. Noteworthy among
these is the development of modified cry1Ac and cry1E/C genes by National
Botanical Research Institute, Lucknow, Indian Institute of Technology, Kharagpur,
National Research Centre on Plant Biotechnology, New Delhi, Central Institute for
Cotton Research, Nagpur, and University of Agricultural Sciences, Dharwar (Anand
Kumar, 2004; Khadi, 2006). Transgenics with cry1Ac gene have been deployed in
Indian cotton genotypes, Bikaneri Nerma, Sahana, Anjali, LRA-5166 and RG-8.
Limited field trials have revealed that transgenic lines exhibit significant insect
protection. Bikaneri Nerma carrying cry1Ac has been crossed with elite cotton
genotypes DS-28, Surat Dwarf, Surabhi, Sahana and L761 to develop Bt version of
elite varieties of the country. Further efforts are required, particularly in the public
sector, to develop insect resistant locally adapted true breeding varieties that could be
made available to the farmers at affordable prices.
Table 8. Genes for insect resistance in cotton
Gene
Event
Company/Institute
cry1Ac
MON531
Monsanto Company
cy1Ac and cry2Ab
15985
Monsanto Company
cryIF
2581-24-236
Dow AgroSciences
cry1Ac
3006-210-23
Dow AgroSciences
cry1Ac
31807/31808
Calgene
vip3A(a)
COT102
Syngenta Seeds
cry1Ac and cryF
DAS-21023-5 x DAS-24236-5
Dow AgroSciences
cry1Ab/cry1Ac
CAAS/Nath Seeds
cry1Ac
NRCPB/UAS Dharwar
cry1E/C, cry1Ac
NBRI/Swarna Bharat Biotechnics

Pvt. Ltd.
cry1Ac
Event 1
IIT Kharagpur/JK Agri-Genetics
cry1c, CPTi
Mahyco
cry1c, CPTi
Nath Seeds, CICR
Source: PTI, 2003; Agbios, 2006; Khadi, 2006 and personal information.
As mentioned in Chapter 5, questions have been raised about the need for refuge
crops under the Indian multi-cropping system. Farmers in general have not been very
enthusiastic about growing refuge crops owing to their small land holdings. It would
28
be desirable to generate local data on insect populations and resistance build-up

under different cropping regimes to develop reliable and cost-effective strategies for
insect resistance management.
The need for improving the processes and protocols for large-scale field trials of
transgenic cotton has been expressed by some authors (Scoones, 2003; Das, 2005;
Rao, 2005; Sahai, 2005). A sub-committee constituted by GEAC has given a number
of recommendations for field testing of new Bt cotton varieties/hybrids (MoEF, 2005).
These include suggestions on; zone-wise number of locations for different types of
hybrids, parameters to be monitored, number of years of testing for different genes
and recipient varieties, and the stage at which the Bt lines should enter ICAR trials.
Implementation of these recommendations should expedite the commercial release of
Bt cotton varieties/hybrids without compromising biosafety considerations.
Curbing trade in spurious Bt cotton seed is essential for the survival of a good
technology that has proved its worth on farmers fields. Further, with no containment
measures adopted during the cultivation of spurious varieties, there is a real possibility
of Bt toxin gene contaminating contiguous non-Bt varieties and germplasm. Such
uncontrolled spread of toxin gene would lead to faster build-up of resistance in
bollworms. Measures like seed registration and strict field monitoring would be
required to control the proliferation of spurious Bt cotton seed.
Translating the potential of Bt technology into tangible benefits for farmers has
become possible through enormous and cooperative efforts of public and private
sectors. Mahyco took a leading initiative in introducing the technology into India and
following a long and rigorous testing procedure as directed by RCGM and GEAC.
The role played by DBT, MoEF and ICAR in conducting/monitoring the trials,
promoting technology dissemination and creating public awareness is well known. So
also is the role of CSOs and NGOs, particularly that of the network of local NGOs
engaged in monitoring Bt cotton performance in different zones. Further, stronger
public-private partnerships are being forged to accelerate development of new and
improved insect-resistant cotton varieties/hybrids. National Botanical Research Institute,
Lucknow, has licensed its Bt technology to a consortium of seven companies, Swarna
Bharat Biotechnics Pvt. Ltd. while Indian Institute of Technology, Kharagpur, has
licensed its Bt technology to JK Agri-Genetics (Jayaraman, 2004a; Krishna, 2004).
These and other models of public-private partnership need to be pursued vigorously
to make available the promised benefits of agricultural biotechnology to the stakeholders
and to achieve a competitive position in the globalized agricultural market.
7. EPILOGUE
In an article on the future of agricultural biotechnology, Giddings (2006) commented
in ten years time, we will likely look back and wonder how we ever could have
doubted.
In this status report, efforts have been made to synthesize information on the
events leading to Bt technology adoption, results of trials/experiments conducted to
meet the statutory requirements for their release, and research findings and observation
of various CSOs on the on-farm performance of Bt cotton. The key role of
organizations such as Department of Biotechnology, Ministry of Environment and
Forests, Indian Council of Agricultural Research, and seed companies like Mahyco in
initiating research and development of Bt cotton has been detailed.
The large-scale adoption of Bt cotton by Indian farmers is a testimony to the
success of Bt technology under diverse and highly complex Indian farming conditions.
Besides protecting the crop against bollworm attack that results in higher cotton yield
and increased net income, the technology offers promise of other benefits associated
with reduction in the use of broad-spectrum pesticides. These include, conservation
of natural enemies of bollworm, reduced soil and water contamination, and health
benefits to farm workers who would come in lesser contact with pesticides.
Any technological innovation takes time to stabilize and become widely acceptable.
This is particularly so in agriculture, as many factors are involved in its success at the
grassroots level. We still need to have Bt technology which could be afforded by small
farmers, diverse sources of insect-pest resistance in agronomically superior genotypes,
good public/farmer awareness programmes, well-regulated seed distribution system
and conducive market for the produce. Strict adherence to the prescribed procedures
and regulatory measures at all stages of development and cultivation of GM crops is
an imperative. Equally important is the cooperation between Bt variety developers in
both public and private sectors and CSOs in producing factual and reliable information
about the performance of these varieties at farmers field level.
It is hoped that the attempt made by APCoAB/APAARI in bringing out this
publication will serve to generate more interaction among different stakeholders to
benefit from the technology as also resolve various issues and concerns as expressed
30
in this status report. Ultimately, it should lead to greater realisation of the potential
of biotechnology for enhancing farm production, improving livelihoods and creating
safer environment. Further, in the regional context, dissemination of this report
should prove useful to other NARS of the Asia-Pacific where genetic modification
technology is under various stages of development and adoption for increased
productivity and resource conservation.
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Anand Kumar, P. 2004. Bt transgenic pigeonpea, rice and cotton for insect resistance.
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2002.
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genetically modified cotton in India. AgBioForum, 7: 96-100.
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CICR. 2006. Cotton Database. Central Institute for Cotton Research, Nagpur.
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Choudhary, B. 2005. Fact sheet on approved Bt cotton hybrids in India. International
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Das, K. 2005. Bt cotton cultivation: Facts and fiction.
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DBT. 2006. Personal communication: Department of Biotechnology, Government of
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Dong, H., Li, W., Tang, W. and Zhang, D. 2004. Development of hybrid Bt cotton in
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FAO. 2004. The state of food and agriculture 2003-2004. Agricultural biotechnology:
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Ghosh, P.K. 2001. National regulatory mechanism for development and evaluation of
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B. S. Transgenic Crops and Biosafety Concerns. National Bureau of Plant
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Giddings, L.V. 2006. Whither agbiotechnology? Nature Biotechnology, 24: 274-276.
ISAAA. 2002. Bt cotton: Indian case study. Global Knowledge Centre on Crop
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(Lepidoptera: Noctuidae) populations from India to Bacillus thuringiensis Cry1Ac
insecticidal protein. Crop Protection, 23: 53-59.
James, C. 2000. Global status of commercialized transgenic crops : 1999. ISAAA
Briefs No. 17. International Service for Acquisition of Agri-Biotech Applications.
Ithaca, NY.
Jayaraman, K.S. 2001. Illegal Bt cotton in India haunts regulators. Nature
Biotechnology, 19: 1090.
Jayaraman, K.S. 2002. India approves GM cotton. Nature Biotechnology, 20: 415.
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22: 255-256.
Jayaraman, K.S. 2004b. Illegal seeds overtake Indias cotton fields. Nature
Biotechnology, 22: 1333-1334.
Khadi, B.M. 2006. Personal communication.
Kranthi, K.R., Jadhav, D.R., Wanjari, R.R., Shakir Ali and Russell, D. 2001. Carbonate
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Kranthi, K.R., Naidu, S., Dhawad, C.S., Tatwawadi, A., Mate, K., Patil, E., Bharose,
A.A., Behere, G.T., Wadasker, R.M. and Kranthi, S. 2005. Temporal and intraplant variability of Cry1Ac expression in Bt-cotton and its influence on the
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Krishna, P.J. 2004. India produces indigenous GM cotton.
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Annexure I
Conditions stipulated by MoEF for release of

MECH-12 Bt, MECH-162 Bt and MECH-184 Bt
(i)
The period of validity of approval is three years from April 2002 March
2005.
(ii)
Every field where Bt cotton is planted shall be fully surrounded by a belt of

land called refuge in which the same non-Bt cotton variety shall be sown.
The size of the refuge belt should be such as to take at least five rows of nonBt cotton or shall be 20% of total sown area whichever is more.
(iii)
To facilitate this, each packet of seeds of the approved varieties should also
contain a separate packet of the seeds of the same non-Bt cotton variety
which is sufficient for planting in the refuge defined above.
(iv)
Each packet should be appropriately labelled indicating the contents and the
description of the Bt hybrid including the name of the transgene, the GEAC
approval reference, physical and genetic purity of the seeds. The packet
should also contain detailed directions for use including sowing pattern, pest
management, suitability of agro-climatic conditions etc., in vernacular
language.
(v)
MAHYCO will enter into agreements with their dealers/agents, that will
specify the requirements from dealers/agents to provide details about the
sale of seeds, acreage cultivated, and state/regions where Bt cotton is sown.
(vi)
MAHYCO will prepare annual reports by 31st March each year on the use of
Bt cotton hybrid varieties by dealers, acreage, locality (state and region) and
submit the same in electronic form to GEAC, if asked for by the GEAC.
(vii) MAHYCO will develop plans for Bt based Integrated Pest Management and
include this information in the seed packet.
36
(viii) MAHYCO will monitor annually the susceptibility of bollworms to Bt gene

vis--vis baseline susceptibility data and submit data relating to resistance
development, if any, to GEAC.
(ix)
Monitoring of susceptibility of bollworms to the Bt gene will also be

undertaken by an agency identified by the Ministry of Environment and
Forests at applicants cost. The Ministry has entrusted Central Institute for
Cotton Research, Nagpur, to carry out the above monitoring.
(x)
MAHYCO will undertake an awareness and education programme, interalia

through development and distribution of educational material on Bt cotton,
for farmers, dealers and others.
(xi)
MAHYCO will also continue to undertake studies on possible impacts on

non-target insects and crops, and report back to GEAC annually.
(xii) The label on each packet of seeds, and the instruction manual inside the
packet should contain all relevant information.
(xiii) MAHYCO will deposit 100 g seed each of approved hybrids as well as their
parental lines with the National Bureau of Plant Genetic Resources (NBPGR).
(xiv) MAHYCO will develop and deposit with the NBPGR, the DNA fingerprints
of the approved varieties.
(xv) MAHYCO will also provide to the NBPGR, the testing procedures for
identifying transgenic traits in the approved varieties by DNA and protein
methods.
Source: http://www.envfor.nic.in/divisions/csurv/geac/bgnote.doc
Annexure II
Acronyms
APAARI
APCoAB
Bt
CAAS
CICR
CSO
DBT
DLC
EPA
FAO
GEAC
GMO
GM
IBSC
ICAR
IIT
IPM
ISAAA
Mahyco
MEC
MIC
MoEF
NARS
NBPGR
NBRI
NGO
NRCPB
RCGM
RDAC
r-DNA
SBCC
UAS
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
Asia-Pacific Association of Agricultural Research Institutions

Asia-Pacific Consortium on Agricultural Biotechnology
Bacillus thuringiensis
Chinese Academy of Agricultural Sciences
Central Institute for Cotton Research
Civil Society Organization
Department of Biotechnology, Government of India
District Level Committee
Environment (Protection) Act
Food and Agriculture Organization of the United Nations
Genetic Engineering Approval Committee
Genetically Modified Organism
Genetically Modified
Institutional Bio-safety Committee
Indian Council of Agricultural Research
Indian Institute of Technology
Integrated Pest Management
International Service for the Acquisition of Agri-biotech Applications
Maharashtra Hybrid Seed Company
Monitoring-cum-Evaluation Committee
Molt Inhibitor Concentration
Ministry of Environment and Forests, Government of India
National Agricultural Research System
National Bureau of Plant Genetic Resources
National Botanical Research Institute
Non Government Organization
National Research Centre on Plant Biotechnology
Review Committee on Genetic Manipulation
Recombinant DNA Advisory Committee
Recombinant DNA
State Biotechnology Coordination Committee
University of Agricultural Sciences
ASIA-PACIFIC CONSORTIUM ON
AGRICULTURAL BIOTECHNOLOGY
The Asia-Pacific Consortium on Agricultural Biotechnology (APCoAB),
was established in 2003 under the umbrella of the Asia-Pacific Association
of Agricultural Research Institutions (APAARI) an initiative of Food
and Agriculture Organization that has been promoting appropriate use of
emerging agri-technologies and tools in the region.
APCoABs mission is To harness the benefits of agricultural
biotechnology for human and animal welfare through the application of
latest scientific technologies while safeguarding the environment for the
advancement of society in the Asia-Pacific Region.
APCoABs main thrust is:
To serve as a neutral forum for the key partners engaged in research,

development, commercialization and education/ learning of agricultural
biotechnology as well as environmental safety in the Asia-Pacific
region.
To facilitate and promote the process of greater public awareness and

understanding relating to important issues of IPRs sui generis systems,
biosafety, risk assessment, harmonization of regulatory procedures,
and benefit sharing in order to address various concerns relating to
adoption of agricultural biotechnology.
To facilitate human resources development for meaningful application

of agricultural biotechnologies to enhance sustainable agricultural
productivity. as well as product quality, for the welfare of both farmers
and consumers.

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Bt COTTON IN INDIA

Asia-Pacific Consortium on Agricultural Biotechnology

Citation: APCoAB. 2006. Bt cotton in India A status report. Asia-Pacific Consortium

For copies please write to:

Bt Cotton in India A Status Report

National Regulatory Mechanism

Development and Commercialization of Bt Cotton

Field Performance and Socio-economic Impact

Conditions Stipulated by GEAC

Low Bt Toxin Level

Genetic Uniformity of Cry Protein and Pest Resistance

Intellectual Property Rights Issues

Recommendations of National Commission on Farmers

Bt Cotton in India A Status Report

Opportunities and the Way Ahead

Annexure I : Conditions Stipulated by MoEF for Release of

Bt Cotton in India A Status Report

Table 1. Estimated cotton production and consumption during 2004-05 in major

Table 2. Some major insect pests of cotton

Red cotton bug

Dusky cotton bug

Striped mealy bug

Red hairy caterpillar

Yellow star scale

Source: CICR, 2006.

2. NATIONAL REGULATORY MECHANISM

Bt Cotton in India A Status Report

Review Committee on Genetic Manipulation (RCGM): This committee is

National Regulatory Mechanism

3. DEVELOPMENT AND COMMERCIALIZATION

Development and Commercialization of Bt Cotton

Bt (Barwale et al., 2004; http://www.envfor.nic.in/divisions/csurv/geac/bgnote.html).

Bt Cotton in India A Status Report

Development and Commercialization of Bt Cotton

Bt Cotton in India A Status Report

Field Performance and Socio-economic Impact

Conditions Stipulated by GEAC

Development and Commercialization of Bt Cotton

North and Central

Ganga Kaveri Seeds

MECH-12 Bt*, MECH-162 Bt**, MECH-184 Bt**

Central and South

MRC-6025 Bt, MRC-6029 Bt

North and Central

MRC-6322 Bt, MRC-6918 Bt

NCS-138 Bt, NCS-913 Bt

NCS-145 Bunny Bt, NCS-207 Mallika Bt

Central and South

Central and South

RCH-20 Bt, RCH-368 Bt

RCH-118 Bt, RCH-138 Bt, RCH-144 Bt

RCH-134 Bt, RCH-317 Bt

RCH-308 Bt, RCH-314 Bt

VICH-5 Bt, VICH-9 Bt

*Discontinued from South Zone. **Not approved for Andhra Pradesh.

Bt Cotton in India A Status Report

Area under Bt hybrids (ha)

Development and Commercialization of Bt Cotton

*Source: DBT, 2006.

MECH-12 Bt*, MECH-162 Bt, MECH-184 Bt