8 Conclusions

A stepwise increase of release scale, based on results from a gradually enhanced data base, is a precautionary principle required through Directive 2001/18/EC. The foundation to ensure this principle is to collect sufficient data during lab, greenhouse experiments and field trials. This is the only approach that enables a solid environmental risk assessment and the subsequent planning and design of the post-market environmental monitoring. It is crucial in helping to detect possible larger-scale and long-term effects and to avoid possible environmental damage.

For the GMHR sugar beet as a case study, we identified shortcomings in the presently available information for the environmental risk assessment at all levels of spatial scales: On the laboratory scale, data on potential environmental effects are few, inadequate or missing, and/or statistical designs of experiments are poor. Ecotoxicity tests for non-target organisms are too short-lived and do not use the real GMHR sugar beet material. Finally, the selection of test organisms is questionable. On the field scale, further experiments are required on adverse effects of GMHR sugar beet and different glyphosate formulations on various trophic levels of field organisms, aquatic communities and soil microbial communities. We therefore argue that more research experiments should be done initially to enable completing the environmental risk assessment.

Once approved, a case-specific monitoring should be carried out for a) possibly increased glyphosate formulation concentrations in soils and aquatic ecosystems, b) adverse effects on field organisms and aquatic communities, c) herbicide resistance in weeds, d) the possible increase and/or change in the herbicide application regime after years of glyphosate application, and e) a possible decrease in agrobiodiversity (weed communities, herbivores, pollinators and beneficial species) linked to the HR technology. General surveillance should be carried out on a) possible persistence and invasiveness of HR cultivated, feral and weed beets, and hybridised HR-related species in the agro-environment, b) sustainability of cropping systems and their rotations, c) potentially increased herbicide drift and pollution, and d) potential adverse effects on migratory and mobile species, soil functions, ecosystem food chain effects, and large-scale biodiversity.