Import of herbicide tolerant oilseed rape MS8xRF3xGT73

This advisory report concerns an application for import and processing of genetically modified (GM) oilseed rape (Brassica napus) MS8xRF3xGT73. MS8xRF3xGT73 is tolerant for glufosinate ammonium containing herbicides, tolerant and resistant for glyphosate containing herbicides and expresses a pollination control system.
COGEM is of the opinion that the molecular characterisation of MS8xRF3xGT73 has been performed adequately. The environmental risk assessment of MS8xRF3xGT73 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 minimal requirements for import and processing of MS8xRF3xGT73.
The establishment of small populations of MS8xRF3xGT73 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 in time such unanticipated, delayed or (in)direct adverse environmental effects. 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 MS8xRF3xGT73 should be improved before a market authorisation is granted. Therefore, COGEM cannot advise positively on the application for import and processing of MS8xRF3xGT73 oilseed rape.