The EFSA proposed risk assessment scheme leads to the conclusion of potential risks for almost all products in the complex first-tier calculations, which are expected to remain unresolved due to the lack of practicable or available testing tools. The EFSA guidance document, therefore, fails in its self-stated description in which it “suggests the implementation of a tiered risk assessment scheme with a simple and cost-effective first tier to more complex higher tier studies under field conditions”. Several actions to improve and correct the risk assessment presented by EFSA in their guidance document are presented in this paper. A revised risk assessment is needed which better reflects the level of concern for different substances and uses (i.e. lower concern for non-toxic substances, higher concern for highly toxic substances). The outcome of a revised risk assessment should also be checked and be subject to a multi-stakeholder testing phase to ensure that the objectives are met before being implemented. In addition, to enable any new procedures to be adopted by member states and industry a suitable implementation phase is necessary to ensure that testing and risk assessment requirements for affected compounds can be adequately covered, taking into account testing time scales and availability of contract testing resources.