3. Why Develop a Comprehensive Bioprospecting Policy?
New Zealand currently has no comprehensive policy framework for bioprospecting activities. Creating such a framework could enhance co-ordination between providers of biological resources as well as optimise benefit capture for our country. In thinking about policy development, consideration must be given to a number of issues. These include the Mäori dimension, related government policies, and the interaction with existing and developing international legal and policy frameworks. Other considerations are the potential benefits and costs of a comprehensive bioprospecting framework.
3.1 Where are we now and where could we go?
Current legal and policy frameworks that govern access to New Zealand's biological resources have some differences between them. A few central government departments have developed processes for allowing access to the biological resources that they manage. However, not all of these existing government processes have a benefit-capture focus. These current systems are detailed in section 4.
In addition, access to biological material on privately-owned land is currently negotiated between the private land owner and the bioprospector. Without any comparison to other potential bioprospecting agreements, private land owners may not be realising reasonable levels of benefit capture.
If New Zealand co-ordinated the management of bioprospecting activities at a centralised level, this co-ordination could promote consistency, certainty and transparency in the negotiation of benefit sharing between bioprospectors and all respective access providers to biological resources.
A co-ordinated approach would:
- enable a broader view of bioprospecting activities;
- provide a central contact point for international as well as domestic bioprospectors, where information could be gained about how to access biological resources and the appropriate access providers;
- where required, co-ordinate and help with the streamlining of bioprospecting processes;
- ensure that frameworks are in place that seek to optimise possible benefit return to New Zealand. For example, managing a co-ordinated system for foreign activities could ensure that benefits are not unduly flowing offshore and thereby leading to insufficient returns to New Zealand. Facilitating interaction between foreign and domestic organisations could promote the adding of value9 in New Zealand after the initial bioprospecting activity; and
- enable the systematic gathering and storing of information about what bioprospecting activities are occurring in New Zealand, as well as the associated costs and benefits of these pursuits. This information could be valuable for a number of reasons, including maintaining an overview of the scope and nature of bioprospecting activities in New Zealand, monitoring the general success of bioprospecting policy, and improving the alignment of the bioprospecting framework to policy objectives.
3.2 The Mäori dimension
3.2.1 Waitangi Tribunal Claim WAI 262
About the claim
WAI 262 was lodged with the Waitangi Tribunal on behalf of six iwi (Ngäti Kuri, Ngäti Wai, Te Rarawa, Ngäti Porou, Ngäti Kahungunu and Ngäti Koata) in 1991. The claim asserts tino rangatiratanga and kaitiakitanga rights over mätauranga Mäori and indigenous species of flora and fauna.10 The claim also asserts that the Crown is in breach of Article II of the Treaty of Waitangi through the enactment of legislation inconsistent with those rights, including that the Crown has failed to design systems that adequately recognise Mäori rights to indigenous flora and fauna and to mätauranga Mäori about that flora and fauna.
On 6 July 2006, the Tribunal released its final Statement of Issues. The scheduled hearings and closing submissions were completed very recently, in June 2007. The Tribunal's subsequent report is not expected to be available for at least a year.
There are important links between bioprospecting policy and the WAI 262 claim. It is important that the government develops its understanding of bioprospecting issues, in particular its understanding of the relationship between bioprospecting and mätauranga Mäori. Moreover, consultation and policy work on bioprospecting will not limit WAI 262 proceedings and should enhance the Crown's ability to respond to the Tribunal's findings and recommendations.
Policy development and the WAI 262 claim
Since the WAI 262 claim was lodged in 1991, some related policies and initiatives have been developed, including:
- the Matauranga Kura Taiao fund has been established to support hapü and iwi attempts to retain and promote mätauranga Mäori and its use in biodiversity management;11
- the Trade Marks Act 2002 established a Mäori Advisory Committee to advise the Commissioner of Trade Marks on whether a proposed use or registration of a trade mark derived from a Mäori text or image is, or is likely to be, offensive to Mäori; and
- the development of a draft Patents Bill. Once enacted, this legislation will set up a Mäori Consultative Committee to advise the Commissioner of Patents in relation to patent applications for inventions that involve traditional knowledge, or indigenous plants and animals. (This may lead to such applications being refused if the invention is found to be non-novel or obvious in light of existing traditional knowledge, or if commercial exploitation of the invention would be contrary to Mäori values.)
3.2.2 The use of traditional knowledge and mätauranga Mäori
Traditional knowledge relating to biological resources may be as valuable to bioprospectors as the resource itself. For this reason, a comprehensive bioprospecting policy in New Zealand would have to apply not only to these biological resources, but also to the associated traditional knowledge. Because the knowledge held by Mäori (mätauranga Mäori) makes up a major portion of New Zealand's traditional knowledge, this section will focus closely on this particular aspect.
Traditional knowledge and mätauranga Mäori
"Traditional knowledge" and "mätauranga Mäori" are terms frequently used in this discussion document. Traditional knowledge is a phrase in common domestic and international usage, encompassing knowledge arising from all local communities, including that held by indigenous communities. Usually, a link could be expected to exist between the location of specific biological material and local communities' knowledge about and relationship to that material. This phrase is also the language used in the Convention on Biological Diversity.
By comparison, mätauranga Mäori is the term often used in New Zealand to refer to Mäori knowledge originating from Mäori communities. Mätauranga Mäori is the generally preferred term used in the WAI 262 claim. As part of the consultation process, understanding of these concepts in relation to bioprospecting will be better developed.
Currently, New Zealand has no recognised guidelines or regulations on bioprospectors' use of traditional knowledge or mätauranga Mäori. This seems particularly undesirable from the point of view of Mäori who either may not wish their knowledge to be used in ways inconsistent with their customary laws and practices, or have their knowledge exploited without any benefits flowing back to them. It is also undesirable from the point of view of bioprospectors who want certainty that their use of mätauranga Mäori is legal and ethical.
New Zealand has signed and ratified the 1992 Convention on Biological Diversity (section 3.4.1). Article 8(j) of this convention relates to the use of traditional knowledge. It calls on parties to:
…respect, preserve and maintain knowledge, innovations and practices of indigenous and local communities embodying traditional lifestyles relevant for the conservation and sustainable use of biological diversity and promote their wider application with the approval and involvement of the holders of such knowledge, innovations and practices and encourage the equitable sharing of the benefits arising from the utilisation of such knowledge, innovations and practices.
In New Zealand, some bioprospectors may wish to draw on mätauranga Mäori to inform their research into uses of biological resources. For example, Mäori knowledge of the use of indigenous flora and fauna for medicinal purposes may be of interest to pharmaceutical companies. This information can, for example, reduce companies' search costs, thereby making the overall bioprospecting process comparatively less costly.
Mätauranga Mäori: indigenous plants as a source of medicines
Mäori have used indigenous plants as a source of medicines for centuries, for example:
- Harakeke or New Zealand flax: this plant had many uses. Aside from its fibre being widely used for clothing, matting and baskets, gum exuded from the base of flax leaves or cut leaves could be applied to burns, wounds and abscesses;
- Koromiko: an infusion of Koromiko leaves was a powerful astringent for dysentery, and bruised leaves were applied as poultices for ulcers and venereal disease;
- Ngaio: an infusion of Ngaio leaves was rubbed on the skin to prevent mosquito and sandfly attacks. Ngaio bark could be used to heal ulcers and eruptions of the skin;
- Nïkau: parts of this plant were used in childbirth due to its laxative properties and to relax the (pelvic) ligaments of the body;
- Northern Rata: the bark from this tree was used against ringworm, venereal disease, sores, wounds and abscesses; and
- Pöhutukawa: an infusion of the inner bark was valued as a remedy for diarrhoea, and to dispel inflammation and promote healing in wounds.
Sources: There is a broad range of websites and publications that have information about New Zealand flora and fauna, a selection of which is – M. Riley, Mäori Healing and Herbal, New Zealand Ethnobotanical Sourcebook, Viking Sevenseas N.Z. Ltd, 1994; Landcare Research People Plants Database website; Rongoa Maori - Matauranga Kura Taiao Project website; New Zealand Plant Conservation Network; and University of Auckland NZ Plants website
Overseas practices
A number of national bioprospecting frameworks include provisions related to the use of traditional knowledge. For example, Australian regulations require that a permit is obtained before taking indigenous specimens from Federal areas for bioprospecting. One of the conditions for obtaining a permit is that there must be a benefit-sharing agreement between the bioprospector and the traditional knowledge holders that includes "protection for, recognition of and valuing of any indigenous people's knowledge to be used…".12
In Colombia, Ecuador and Peru, patent applicants must present evidence of access agreements to biological resources and to any traditional knowledge that was used. This provides some degree of protection, but does not stop products being patented in other countries. (See section 3.4.1 "Certificates of Origin" for further discussion on this topic.)
In most countries that have developed bioprospecting frameworks, consent is required to use traditional knowledge that is not in the public domain,13 but is not required for the use of traditional knowledge that has already entered the public domain. However, in Peru, although consent is not required to use traditional knowledge in the public domain, the user is required to provide some benefit in return.14
In some countries, registers and databases of traditional knowledge have been developed to protect traditional knowledge by reducing the likelihood of intellectual property rights being granted where, in view of prior traditional knowledge, there is no uniqueness or novelty.
A patent revoked by the European Patent Office
In 1995, a patent based on the antifungal properties of an Indian medicinal plant, Neem (Azadirachta indica), was granted by the European Patent Office (EPO) to international concerns. A number of parties opposed this move on the grounds that the biological activity of this plant had been known in India for over 2,000 years. Neem is used by Indian communities in a range of products, for example, as an oil against fungus growth, in soaps, contraceptives, cosmetics and insect repellents. On this basis, the patent was eventually revoked in 2005.
Source: "Neem tree oil" case: European patent No. 0436 257 revoked [link to European Patent Office website]; D. Dickson, K. S. Jayaraman, Nature, 1995, 377, 95.
New Zealand context
As noted above, New Zealand has no recognised guidelines or regulations on bioprospectors' use of mätauranga Mäori. Under the status quo, and assuming a best practice approach, a bioprospector should attempt to identify and negotiate with the most appropriate knowledge holders. In cases where an individual or localised community holds the knowledge of interest, this might be a relatively straightforward process, but where there are multiple knowledge holders, it becomes more difficult to determine whose permission is needed for use of relevant knowledge, and who should receive any subsequent benefits. (For a discussion of potential benefits from bioprospecting, see section 3.5 below.)
Within groups that hold mätauranga Mäori, there may be certain customary practices and procedures that must be respected and followed for consent to be given to use that knowledge. There are no formal processes in place to ensure that these practices and procedures are followed.
Where mätauranga Mäori is already in the public domain, it may be difficult to find an organisation or organisations representing all the original holders of the knowledge being used.
An added consideration is that, without the establishment of clear guidelines, a bioprospector facing such complexities could decide to proceed with using mätauranga Mäori without identifying or negotiating use with the most appropriate holders of the relevant knowledge. Aside from the lack of consent or control, this would also make it less likely that benefits would be captured for the holders of that knowledge.
Mätauranga Mäori: indigenous plants as a potential source of food flavours
Crop & Food Research Ltd (a Crown Research Institute or CRI) has partnered with the largest Mäori business network, the Federation of Mäori Authorities (FoMA), to help identify the traditional use of native plants in foods and flavourings with the view to developing distinctive New Zealand food products.
This new research project has the potential to transform the current small-scale, wild source gathering of flavour materials into a commercial food ingredient industry capable of targeting niche, high-value export markets. Once flavours have been identified, scientists intend to extract them from the native plants and determine their suitability as food-flavouring ingredients. This work will be conducted in collaboration with companies exporting meat, dairy and seafood convenience food products.
Source: Distinctive New Zealand flavours [link to Crop & Food Research website]
3.3 Related government policies
In detailing the development of a bioprospecting policy, a number of related policy areas and processes would need to be considered to ensure compatibility of policy development.
New Zealand Biodiversity Strategy
The New Zealand Biodiversity Strategy (the NZBS) was launched in 2000 in response to New Zealand's obligations under the Convention on Biological Diversity. Although the NZBS concentrates on the conservation of biodiversity, it includes the aim of "the development of an integrated policy and legislative framework for managing bioprospecting in New Zealand". Indeed, the NZBS states that current piecemeal approaches to managing bioprospecting are no longer adequate, and that there is a need for a consistent national framework. Initial workstreams on bioprospecting flowed out of the NZBS, and were initially managed by the Department of Conservation. In 2001, this work was passed on to the Ministry of Economic Development.
New Zealand Biotechnology Strategy
The Biotechnology Strategy was launched in 2003. The Strategy was developed "to ensure New Zealand kept abreast of developments in biotechnology, and that these were used to national advantage while preserving essential social, cultural and environmental values". Bioprospecting is one of the many activities that come under the biotechnology umbrella. One of the actions the Biotechnology Strategy recommended in 2003 was to complete a review of regulations for bioprospecting, with the aim of establishing an overarching framework. The framework was to include a policy for benefit sharing, including recognising Mäori interests in biological resources.
3.4 International considerations
A number of international initiatives have provided additional impetus for the development of a bioprospecting policy in New Zealand. In particular, an international regime is being developed under the auspices of the Convention on Biological Diversity (CBD). This regime has the potential to influence national bioprospecting policy settings. In order to manage risks around discussions on an international regime, a better understanding of New Zealand's interests and policy options is required. This section provides some basic information about the CBD, and presents some of the other international agreements that are relevant to bioprospecting in New Zealand.
3.4.1 The Convention on Biological Diversity (CBD)
Prior to the CBD, there was no international regime that directly regulated access to genetic resources and the sharing of benefits derived from the utilisation of those resources. As a consequence, resources were taken from a number of environments for the purpose of developing new products and little consideration was given to the countries or communities that had provided that biological material. A number of major discoveries deriving from biological resources, sometimes involving the use of traditional indigenous knowledge, did not result in benefits being returned to the respective source country. An example of such a situation is given in the information box below.
Discovery of the anti-rejection drug Cyclosporin A – an example from Norway
A researcher spent a couple of weeks' holiday with his wife in Norway's Hardangervidda National Park. While there, he also collected a number of soil samples. One of the samples contained the soil fungus Tolypocladium inflatum that also happened to produce a compound called Cyclosporin A. This compound has a range of biological activities, the most important of which being its immunosuppressant properties. In fact, Cyclosporin A began a new generation of medicines that could be used to aid such procedures as organ transplants. In 1997, the annual sales revenue from Cyclosporin-based products totalled US$1.2 billion. In the absence of benefit sharing policies, Norway has not been able to capture a share of these financial benefits.
Source: H. Svarstad, H. C. Bugge, S. S. Dhillion, Biodiversity and Conservation, 2000, 9, 1521–1541.
New Zealand has signed and ratified the 1992 CBD. The main objectives of the CBD are:
- the conservation of biological diversity;
- its sustainable use; and
- the sharing of benefits derived from allowing access to "genetic resources".15
Concerning the third objective above, Article 15(2) of the Convention states that parties should:
…endeavour to create conditions to facilitate access to genetic resources for environmentally sound uses by other contracting parties. Access should be through the prior informed consent of the sovereign state and on mutually agreed terms.
Article 8j of the CBD is directly relevant to traditional knowledge and practices (see section 3.2.2).
Parties to the CBD have agreed to develop an international regime on access to biological material, and sharing benefits in return for allowing access. It is intended that work on this international regime will be completed before June 2010.
The Bonn Guidelines
In 2002, the Bonn Guidelines on Access to Genetic Resources and Fair and Equitable Sharing of the Benefits arising out of their Utilization were adopted by the parties to the CBD.16 These guidelines are voluntary and are intended to provide guidance for countries developing national frameworks to regulate bioprospecting activities. In essence, the Bonn Guidelines:
- have conservation and sustainable use of biodiversity as core objectives;
- emphasise the obligation for users of biological material to seek consent from the providers before taking any samples;
- clarify the roles and responsibilities of users and providers;
- suggest elements for inclusion in agreements to access biological material and for "material transfer agreements";17
- provide an indicative list of both monetary and non-monetary benefits that could be included in access agreements; and
- suggest that human genetic resources are excluded from national frameworks.
The Bonn Guidelines also cover accountability, means for verification and dispute settlement. They recommend that each country have two core elements in a national bioprospecting framework, namely a "National Focal Point" and one or more "Competent National Authority(ies)".
Certificates of Origin
Parties to the CBD are exploring whether there is value in an international certification system to verify the origin of particular biological material. If such a system was to be introduced, it might promote compliance with national bioprospecting policies, including that of New Zealand. Certificates of Origin are likely to be most useful in this respect if they not only verify where material is sourced from, but also that it has been taken in accordance with permit/access systems for both biological material and any traditional knowledge used.
At the World Intellectual Property Organization's (WIPO) meetings, there has been discussion about the desirability of instituting a system of voluntary or mandatory declarations of the origin of biological material used to contribute to a patent application. The idea of linking this with an international certification system has also been mooted.
3.4.2 Other international considerations
There are a number of other international legal and policy frameworks that could potentially influence the policy settings of a bioprospecting framework in New Zealand. These conventions and agreements are briefly outlined.
World Intellectual Property Organization (WIPO)
WIPO is an international organisation dedicated to protecting the rights of creators and owners of intellectual property. WIPO has established an Intergovernmental Committee on Intellectual Property and Genetic Resources, Traditional Knowledge and Folklore. The work of the committee includes considering ways to promote effective benefit sharing from the use of biological resources, including effective benefit sharing with indigenous people.
Trade Related Aspects of Intellectual Property (TRIPS)
The World Trade Organization Agreement on Trade Related Aspects of Intellectual Property Rights (TRIPS) sets the international framework for conventional intellectual property rights. Article 27(1) of TRIPS states that: "patents shall be available for any inventions, whether products or processes, in all fields of technology, provided that they are new, involve an inventive step and are capable of industrial application".
International Union for the Protection of New Varieties of Plants (UPOV Convention)
The 1991 UPOV Convention states that a plant breeder can be granted rights of protection if the plant variety developed is distinct, uniform, stable and new. This grant of "Plant Variety Rights" is, in some respects, comparable to that given to an inventor by a patent grant.18 In line with this, New Zealand legislation grants plant breeders' rights to those who breed new varieties, or discover and develop them. Plant breeders' rights granted in New Zealand apply only in this country.
International Treaty on Plant Genetic Resources for Food and Agriculture (ITPGRFA)
New Zealand has not yet determined whether it will ratify this treaty. Should it do so, it will oblige New Zealand to make certain plant genetic resources held in its public sector gene banks19 available on terms agreed under the ITPGRFA. The ITPGRFA applies to a list of species that are regarded as significant food crops.
3.5 Potential benefits of a comprehensive framework
New Zealand's natural resources provide a wide range of benefits. These potential benefits can be both non-monetary and monetary in nature.20 The sorts of benefits that could be captured with a bioprospecting policy would depend on what exactly was negotiated in terms of access to the desired biological material. These benefits can be captured immediately, for example in the form of access fees, or they can be captured at some stage in the future depending on the outcome of the bioprospecting project, for example, in the form of royalties.21 Overseas experience indicates that it is not easy to stipulate what a reasonable level of benefit is, because each application has its own characteristics and needs to be considered individually.
3.5.1 Potential non-monetary benefits
A range of potential non-monetary benefits could be negotiated in return for access to a particular biological resource including:
- institutional capacity-building through, for example, participation in product development and access to external facilities such as databases and equipment;
- increased connectivity and sharing of research and development results between research entities;
- joint ownership of relevant intellectual property rights;
- contributions to the local economy such as employment; and
- increased scientific and public knowledge of the natural environment, for example, taxonomic information.
Raising the capacity of New Zealand's scientific sector
In the New Zealand context, an important benefit that could be secured through a bioprospecting policy would be to help New Zealand institutions be involved in the flow-on benefits that might arise from initial bioprospecting activities, thereby adding as much value as possible to the chain of development in New Zealand rather than off-shore. This could create a number of spin-off benefits for the science sector in New Zealand including:
- enhancing the skills and knowledge of New Zealand researchers through investment in training and equipment, thereby aiding New Zealand's drive to have a knowledge-based economy;
- generating employment in the scientific sector; and
- promoting the exchange of information between New Zealand and international research institutions, thereby creating valuable networks.
Benefit to local communities
In addition, local and rural communities could benefit from value-adding through the later chain of development, for example, by being trained and employed to collect biological material. Investment into local research institutions could also increase employment in more specialised areas.
An example of partnerships providing opportunities for locals
New Zealand's mänuka honey is known for its antibacterial properties, on account of the so-called "unique mänuka factor" (UMF®). Mänuka honey can be taken for digestive health and used as a topical application to help heal wounds.
Especially high levels of the UMF® are thought to be found in mänuka honey from the east coast of the North Island. This discovery initiated a partnership in 2003 between the New Zealand company Comvita and the local iwi, Ngäti Porou. Reports suggest that positive outcomes have arisen from this collaboration, as well as from a collaboration between Horouta Manuka and CRI Crop & Food Research Ltd (funded by the Foundation for Research, Science and Technology or FRST). Examples include the training and employment of locals to collect honey and maintain beehives as well as the use of previously "unproductive" land to generate an income for local iwi land owners.
Source: First Honey Collection on East Coast Iwi, a Success [link to Comvita website]; Predicting the Unique Manuka Factor in honey [link to Crop & Food Research website]
Increased scientific knowledge of New Zealand's flora and fauna
Bioprospecting activities can also provide valuable information that assists with conservation and environmental management. Bioprospectors often need to record information on taxonomy, species distribution and the variation of species' density over time.
3.5.2 Potential monetary benefits
A range of potential monetary benefits could be negotiated in return for access to a particular biological resource including:
- up-front payments/access fees/fee per sample collected;
- milestone payments (commonly payable at certain stages of research or product development);
- payment of royalties and licence fees in case of the commercialisation of intellectual property;
- special fees to be paid to trust funds supporting conservation and sustainable use of biodiversity;
- research funding; and
- joint ventures and joint ownership of relevant intellectual property rights.
Royalties and licence fees from intellectual property rights
Royalty streams and licensing fees for New Zealand researchers, traditional knowledge holders and other stakeholders can be secured and retained through legal mechanisms, such as intellectual property rights. However, the capture of such monetary benefits is dependent on the product reaching a commercialisation stage, and being brought to market. In addition, because this commercialisation path is usually long and complex, monetary benefits may be only a small percentage of the returns from the final product.
3.6 Potential costs of a comprehensive framework
The previous discussion focused on the benefits that could arise from co-ordinating and managing bioprospecting activities. However, it is also important to bear in mind the possible costs associated with implementing such a framework, as well as how practically enforceable a framework could be.
3.6.1 Possible costs to stakeholders
When considering cost, it is important to consider how a comprehensive bioprospecting framework could affect different stakeholders.
Bioprospectors
There are some differences between domestic and international bioprospectors and how they are likely to use any potential framework which, in turn, influence the potential costs to these stakeholders. For example, for international bioprospectors, costs could also increase if New Zealand determined that certain phases of research had to be conducted here.
In very general terms, costs to bioprospectors can include the costs of:
- finding out about the bioprospecting process in New Zealand;
- finding and contacting the appropriate access provider;
- negotiating the terms of access and benefit sharing;
- gaining access to the desired resource;
- complying with any government monitoring and enforcement policies; and
- establishing certainty that samples were legally collected.22
Domestic bioprospectors are likely to incorporate any potential bioprospecting framework into their compliance procedures. This could mean that research organisations would seek to streamline procedures and build relationships with access providers in ways that make any framework easier to manage, and sufficiently reduce costs to make collection worthwhile. Domestic bioprospectors might often carry out bioprospecting as part of their organisation's research or data collection roles. Domestic bioprospectors are likely to compare the costs and benefits of a comprehensive framework, but will probably also be concerned with costs that could affect their ability to access biological resources for non-bioprospecting work.
International bioprospectors are more likely to want to interact with a framework through a focal point, before proceeding with any bioprospecting activity. Compared with domestic bioprospectors, they are likely to require considerably more relationship mediation with access providers, as well as information about legislation and regulations. International bioprospectors will probably usually be more interested in the bioactivity of collected material, rather than general information about the material, and so therefore might offer to provide the material to domestic organisations for more general research and collections. International bioprospectors are likely to compare costs with frameworks of other countries, and expect benefits from collaboration or good compliance.
Access providers
Compared with maintaining the status quo, a key consideration for access providers will be any additional costs for them, alongside possible benefits.
The design of a framework can affect costs in a number of ways, including:
- implementation and running costs; and
- monitoring and enforcement costs.
A number of factors need to be taken into account in determining what monitoring and enforcement measures may be appropriate, including:
- because of the vast areas of land and sea of potential interest to bioprospectors, it would be difficult to physically catch bioprospectors illegally taking samples. In addition, it would be very difficult to use border control measures to prevent small biological samples being sent overseas;
- if a product derived from illegally-taken biological material is patented in another country, under existing international arrangements, the source country cannot claim redress; and
- it may be difficult to determine whether samples collected or purporting to be collected for non-commercial research are subsequently used for commercial purposes, especially overseas.
The more a comprehensive bioprospecting framework is aligned with and utilises existing resources and systems, the more costs can be kept to a minimum.
Consumers
Depending upon the design of a comprehensive bioprospecting framework, the costs borne by bioprospectors could, in the long term, be passed on to consumers who use the products and services generated from bioprospecting activities.
Back to Top