LMOs intended for direct use as food or feed, or processing (LMOs-FFP) [1] include a large category of agricultural commodities – these might be, for example, bulk shipments containing genetically modified corn, soybeans or other agricultural commodities that are intended for direct use as food or animal feed or for processing, but are not intended for use as seeds.

The Protocol does not apply the AIA procedure to these LMOs. Instead, the communication and decision making processes are as follows:

• When a Party makes a final decision at the domestic level regarding the commercial growing or placing on the market (but not field trials) of an LMO, that might be exported for direct use as food or feed or for processing, then that Party must notify the BCH (thereby notifying other Parties) within 15 days of making the decision.
• Where such a decision has been taken, the Protocol specifies the minimum information that should be provided to the BCH.[2]

Parties of import can decide whether and how to subject LMOs-FFP to notification, risk assessment and approval procedures prior to first import, in accordance with their domestic regulatory framework and consistent with the objectives of the Protocol. The Protocol recognises that some developing countries or countries with economies in transition may not have a domestic regulatory framework for LMOs-FFP in place. It allows such Parties to declare through the BCH that decisions on the first import of LMOs-FFP will be taken in accordance with risk assessment as set out in the Protocol and within a 270 day timeframe for decision-making[3].  

In contrast to the bilateral AIA procedure, which is based on direct communication between Parties, the procedure for LMO-FFPs in the Protocol is essentially a multilateral information exchange mechanism, centred on the BCH.