The Unregulated Spread of Bt-3 and Roundup Ready Cotton in India: A Growing Biosafety and Public Health Concern

Tarak Dhurjati

India’s cotton story over the last quarter century has been a striking mix of scientific achievement, farmer adoption, regulatory lapses, and environmental concern. From the introduction of Bollgard-I (the first genetically modified Bt cotton) in 2002, to Bollgard-II with stacked insecticidal genes, and now the unregulated proliferation of Bt-3 or “Roundup Ready Flex” cotton, the technology trajectory has outpaced policy and oversight.
The latest phase — the spread of unapproved herbicide-tolerant (HT) Bt cotton — presents a new and serious challenge: unauthorized use of glyphosate, an herbicide whose agricultural use in row crops like cotton remains banned in India.

1. The Genesis: India’s Tryst with Bt Cotton

Bt Cotton – The First Generation (Bollgard-I)

Introduced: 2002, officially approved by the Genetic Engineering Appraisal Committee (GEAC).
Technology: Contained a single Cry1Ac gene from Bacillus thuringiensis (Bt) — a soil bacterium that produces insecticidal proteins toxic to bollworms (Helicoverpa armigera).
Impact: Provided effective control against American bollworm and led to a rapid increase in cotton yields and reduced insecticide use in the early years.
Adoption: Within a decade, over 90% of India’s cotton area was under Bt hybrids, turning India into the world’s second-largest cotton producer.

The Second Generation (Bollgard-II)

Introduced: Around 2006, formally approved by GEAC in 2006–07.
Technology: Contained two insecticidal genes — Cry1Ac and Cry2Ab2.
Advantage: Broader and more durable pest control against multiple bollworm species; delayed pest resistance compared to single-gene Bt.
Result: Bollgard-II largely replaced the first-generation Bt cotton by 2010, bringing renewed productivity gains and farmer enthusiasm.

2. The Third Wave: Bt-3 / Herbicide-Tolerant (HT) Cotton

What is Bt-3 Cotton?

The so-called Bt-3 or HT Bt cotton is an unauthorized variant carrying:

Cry1Ac and Cry2Ab2 (from Bollgard-II), plus
an additional EPSPS (5-enolpyruvylshikimate-3-phosphate synthase) gene conferring tolerance to glyphosate — the active ingredient in Monsanto’s “Roundup” herbicide.

This combination allows farmers to spray glyphosate directly on cotton fields, killing surrounding weeds without harming the cotton plant — a major labour-saving convenience.

Regulatory status

Not approved by India’s GEAC or the Ministry of Environment, Forest and Climate Change (MoEFCC).
Glyphosate use in India is legally permitted only for non-crop applications — i.e., in plantation crops (like tea) and non-agricultural areas (wastelands).
Therefore, any sale, possession, or planting of HT cotton seeds is illegal under the Environment (Protection) Act, 1986.

3. How HT Cotton Spread Despite the Ban

Seed leakage and illegal propagation

Around 2014–15, reports emerged from Gujarat, Maharashtra, Telangana, and Andhra Pradesh that farmers were planting “herbicide-tolerant” cotton.
The trait likely entered Indian seed stocks through illegal backcrossing — where domestic seed companies or rogue breeders bred the HT gene into local hybrids, distributing them without regulatory clearance.
By 2019, the Central Institute for Cotton Research (CICR, Nagpur) estimated that up to 15–20% of India’s cotton area (2–3 million hectares) could be under unapproved HT Bt cotton.

Farmer incentives driving adoption

Labour costs for manual weeding have doubled in the last decade.
Glyphosate-tolerant cotton allows farmers to spray a single herbicide instead of hiring labour for weeding — cutting weeding costs by 50–70%.
Seed packets labeled as “BG-II HT” or “RR Flex” are sold covertly through informal seed networks, especially in Telangana, Andhra Pradesh, Maharashtra, and Gujarat.
The demand is entirely farmer-driven — reflecting economic compulsions rather than corporate marketing.

4. The Regulatory and Governance Breakdown

Despite repeated crackdowns by state agriculture departments and GEAC advisories, HT cotton has spread unchecked.
Seed certification systems are weak — most cotton seed trade happens through unregulated local dealers.
Testing infrastructure to detect HT genes is limited. Random testing of seeds in Maharashtra and Telangana revealed that up to 50% of sampled packets contained glyphosate-tolerance genes.
Legal penalties (under EPA 1986) are seldom enforced.
Farmers claim they are unaware of the legal status, while state authorities struggle to trace the original source of transgenic contamination.

5. Glyphosate — The Controversial Herbicide

What is glyphosate?

Glyphosate is a broad-spectrum herbicide that inhibits the shikimic acid pathway in plants, preventing growth and leading to weed death.
It is marketed globally under the brand “Roundup”.

Legal status in India

Permitted only for non-crop applications, such as controlling weeds in tea plantations, non-crop areas, and railway tracks.
Its use on row crops like cotton, soybean, maize, or pulses is prohibited.
Despite this, unregulated glyphosate use on HT cotton is widespread, with farmers often unaware of the restriction.

Health and environmental concerns

In 2015, the International Agency for Research on Cancer (IARC), a WHO body, classified glyphosate as a “probable human carcinogen” (Group 2A).
Chronic exposure is linked to DNA damage, hormonal disruption, and potential cancer risks.
Glyphosate residues have been detected in water bodies, soils, and even food grains in high-use areas.
The unregulated use also destroys weed biodiversity, leading to herbicide-resistant weeds — a phenomenon already seen in the U.S. and Brazil.

6. Economic, Ecological, and Policy Implications

Economic

In the short term, farmers benefit from reduced labour costs.
In the long term, dependence on unapproved seed systems and herbicide resistance could increase input costs and reduce productivity.

Ecological

Continuous glyphosate use depletes soil microbial diversity and affects beneficial arthropods.
The cotton ecosystem risks a collapse of integrated pest management (IPM) — bollworms have already developed resistance to Bt toxins, forcing farmers back to insecticides.

Regulatory

India’s biosafety framework under the EPA 1986 and GEAC guidelines is being circumvented at scale.
The lack of enforcement weakens future regulation of other GM crops (like GM mustard or maize).
If left unchecked, India risks an irreversible spread of unauthorized transgenic traits into its cotton germplasm pool.

7. The Way Forward

Strengthen seed regulation: Establish molecular testing facilities in all cotton-growing districts and enforce penalties for illegal seed sales.
Public awareness: Educate farmers about the legal status and health risks of glyphosate and HT cotton.
Alternative weed management: Promote mechanical and biological weed control tools to reduce dependence on herbicides.
Reassess biosafety policy: India needs a transparent, science-based GM policy that weighs farmer economics, ecological safety, and public health rather than allowing unregulated technological creep.
Integrated approach: Combine resistant-variety breeding, crop rotation, and weed ecology research to sustain cotton productivity without chemical overdependence.

Conclusion

The story of India’s genetically modified cotton began as a tale of innovation and productivity. But the illegal spread of Bt-3 (HT) cotton and glyphosate misuse has transformed it into a cautionary narrative on regulatory fragility and biosafety risks.
While the technology itself promises efficiency, its unregulated use threatens to undermine both agricultural sustainability and human health. Unless India rebuilds its biosafety governance and farmer outreach, the lessons of the Bt cotton saga could soon repeat themselves — this time, with far greater consequences for ecology, health, and policy credibility

Disclaimer: This content is for educational purposes. The author does not advocate or endorse the use of unapproved genetically modified crops or herbicides. The author has used AI tools for creation of the article.