Description
Following the publication of EFSA’s final protocols supporting the revision of the ecotoxicological guidance for non-target terrestrial organisms, CropLife Europe as part of this letter would like to share views as we have identified several aspects that merit further consideration.
Specifically, maintaining Tier 1 as a proportionate screening assessment, with additional complexity addressed through higher-tier approaches as appropriate is a key element. Additionally, it’s important to ensure the overall framework remains proportionate and workable to supports predictable and timely assessments, while maintaining a high level of environmental protection.