Environmental risk assessment of import and processing of genetically modified oilseed rape MS11 x RF3 x MON 88302

The present application (EFSA/GMO/NL/2020/167) concerns the authorisation for the import and processing of genetically modified (GM) oilseed rape MS11 x RF3 x MON 88302, and its possible subcombinations, for use in food and feed. The stacked event MS11 x RF3 x MON 88302 was produced by conventional crossbreeding of the three GM parental oilseed rape lines and expresses genes of a pollination control system as well as genes confering tolerance to glufosinate-ammonium- and glyphosate-containing herbicides.
The molecular characterisation of MS11 x RF3 x MON 88302 meets COGEM’s criteria. The phenotypic and agronomic characteristics of MS11 x RF3 x MON 88302 are comparable to conventional oilseed rape, and do not give any indication that MS11 x RF3 x MON 88302 is able to grow in other habitats than conventional oilseed rape under natural conditions, except in places where glyphosate- and glufosinate-ammonium-containing herbicides are used for weed control.
Feral oilseed rape populations occur across the Netherlands, with a small number of plants (25 or less) per location, along distribution routes and handling areas as a result of spillage of oilseed rape seeds during transport and transshipment. Oilseed rape can hybridise with Brassica rapa which is a common plant along Dutch roadsides, and to a lesser extent with Brassica juncea and Brassica oleracea. Stable incorporation (introgression) of genes from B. napus into wild B. rapa and feral B. napus populations may be possible. Accidental spillage during transshipment and transport of GM oilseed rape seeds may lead to the establishment of feral oilseed rape populations. This could lead to feral GM B. rapa plants with for instance herbicide tolerance. COGEM is of the opinion that the post-market environmental monitoring (PMEM) plan for GM oilseed rape should always include monitoring along transport routes (including roadsides and railway beddings), transshipment areas and introduction through bird feed mixtures. As these aspects are not included in the PMEM of MS11 x RF3 x MON 88302, COGEM cannot advise positively on the application, import, and processing of oilseed rape MS11 x RF3 x MON 88302 and its possible subcombinations for use in food and feed. COGEM abstains from giving advice on the potential risks of incidental consumption as a food/feed assessment is carried out by other organisations.