Advisory letter on the ‘Representativity of non-target organisms’
When permit applications are made for the cultivation of insect-resistant genetically-modified (GM) crops, the assessment of potential effects on non-target organisms forms an important part of the environmental risk assessment. For this purpose, laboratory experiments are conducted to investigate whether the insects concerned will be affected by the GM crop. By necessity, such a study is carried out using a small number of species because it would be impossible to investigate all the hundreds of species which may be found in a crop.
To be able to obtain information which may be used to assess the potential effects of the GM crop on non-target organisms, experiments must be carried out with non-target organisms which will be exposed to the GM crop in the field or which are sufficiently representative of these non-target organisms.
COGEM considers species that belong to the same genus as species that are found in the crop in Europe to be sufficiently representative as it may be expected that species which are closely-related genetically will be functionally similar to one another and react in a similar way to toxic substances. Species belonging to the same genus as the non-target organisms that will be exposed to the GM crop, therefore, will generally provide sufficient information to be able to assess the risks to European non-target organisms.
This position implies that investigations with species which belong to genera that are not found in the crop in Europe will not be suitable for assessing the risks to European non-target organisms.