Import and processing of herbicide tolerant oilseed rape MON88302xMS8xRF3

This advice concerns an application for import and processing of genetically modified (GM) oilseed rape (Brassica napus) MON88302xMS8xRF3. This line is tolerant for glufosinate
ammonium containing herbicides and glyphosate containing herbicides and expresses a pollination control system.
COGEM is of the opinion that the molecular characterisation of MON88302xMS8xRF3 is adequate. The environmental risk assessment of MON88302xMS8xRF3 indicates that the event in
itself does not pose a risk to the environment in the Netherlands. However, COGEM is of the opinion that the provided general surveillance plan does not meet the requirements for import and processing of MON88302xMS8xRF3.
The establishment of small populations of MON88302xMS8xRF3 oilseed rape cannot be excluded on locations where glyphosate or glufosinate ammonium are frequently applied to control weeds. Further cross-fertilisation can eventually lead to stacking of several transgenes in one plant. This phenomenon has been reported along roadsides in North America, which had been sprayed with herbicides.
Furthermore, interspecific hybridisation between oilseed rape and its wild close relative Brassica rapa occurs under natural conditions and has been reported in the Netherlands. It is
known that backcrosses between these hybrids and B. rapa may occur in the field. If stacking of transgenes occurs in the wild, it cannot be excluded that a possible new
combination of GM traits and/or a possible interaction between their genes may result in a potentially adverse effect. Therefore, general surveillance of feral GM oilseed rape populations
will be needed to identify such unanticipated, delayed or (in)direct adverse environmental effects in time. As these (stacked) GM oilseed rape plants are most likely to occur in handling areas and along transport routes, in particular when herbicides are used for weed control such as on railway tracks, general surveillance should focus on these areas. Where GM oilseed rape plants occur, transgene flow to B. rapa is possible. Any B. rapa populations in the vicinity of GM oilseed rape should therefore be included in the general surveillance plan and monitored for the presence of transgenes.
In summary, COGEM is of the opinion that the monitoring plan of MON88302xMS8xRF3 should be improved before a market authorisation is granted. Therefore, COGEM cannot advise
positively on the application for import and processing of MON88302xMS8xRF3 oilseed rape.