Interplay between GMO regulation and pesticide regulation in the EU

Abstract

Directive 2001/18/EC requires the assessment of “possible immediate and/or delayed, direct and indirect environmental impacts of the specific cultivation, management and harvesting techniques used for the genetically modified higher plant (GMHP) where these are different from those used for non-GMHPs.” For genetically modified herbicide tolerant (GMHT) plants this means that an assessment of the possible environmental impacts of the post-emergence use of the complementary herbicides compared to those of current weed control methods used in non-GM crops of the same species in the EU is required. On the other hand the post-emergence use of the complementary herbicide in a GMHT crop requires a new authorisation according to the EU pesticide Regulation because it is a new application of the herbicide. This raises the issue of interplay between genetically modified organism (GMO) and pesticide authorisation in the EU. An effective interplay would avoid a duplication of efforts, gaps in risk assessment and the possibility that conflicting decisions on pesticide usage could be made under the two systems. Principally, there are no scientific reasons for assessing the effects on the environment of the use of herbicides in GMHT-crops and in non-GM HT crops according to different standards. It also should be kept in mind that gene technology is only one method which can be used to generate crop plants which are tolerant towards broad-spectrum herbicides. The presentation identifies obstacles to an effective interplay between GMO regulation and pesticide regulation in the EU and discusses possible future developments.