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Application A615 – Food derived from Insect-protected cotton Line COT67B – Draft Assessment Report

23 September 2008

Dear Sir/Madam

Thank you for the opportunity to comment on this application. The New Zealand Food Safety Authority (NZFSA) has the following comments to make.

NZFSA has had the safety assessment prepared by FSANZ reviewed by the Institute of Environmental Science and Research Limited (ESR). As a result of this review, there is one comment we wish to make on the Draft Assessment Report (DAR). In the compositional analysis of cotton COT67B, data was not presented to indicate whether the level of the cotton antinutrient phytic acid was equivalent in cotton COT67B compared to the non-transgenic parent line. Although phytic acid is only found in cottonseed flour, and this product is not sold as a food in Australia or New Zealand, the approval is for all food products.

Yours sincerely