4 specific concerns that have been raised about this question of "substantial equivalency" are: The term substantial equivalency is very vague and open to interpretation for the approval of any GMO submitted. To elaborate, according to the Permaculture Research Institute, the principle allows the comparison of a GM line to any existing variety within the same species. “This means that a GM variety can have all the worst traits of many different varieties and still be deemed substantially equivalent.” Many argue not enough extensive safety testing has been performed to state that genetically-modified crops are "substantially equivalent" to their non-GMO predecessors. The testing of "substantial equivalency” of GMO is flawed