Insufficient environmental protection by the European regulatory framework for pesticides

Ralf B. Schäfer, Thomas Backhaus, Juliane Filser, Mark Gessner, Matthias Liess, Martina Ross-Nickoll, Maj Rundlöf, Martin Scheringer, David Spurgeon, Teja Tscharntke, Paul J. Van den Brink, Andreas Schäffer

Schriever et al. (2025) argue that environmental risk assessment of pesticides in the European Union is sufficiently protective and that regulatory thresholds are rarely exceeded. Here, we re-examine these claims based on new and previous evidence from monitoring, systematic reviews, and different types of field studies. The clear outcome is that measured pesticide concentrations frequently exceed predicted concentrations and regulatory thresholds and that they relate to adverse impacts on ecological communities. The mechanisms driving this result include the joint action of pesticides applied in temporal and spatial proximity, varied environmental conditions, interactive effects of pesticides with additional stressors, and indirect ecological effects propagating within biological communities. These neglected intricacies explain why current single-substance prospective assessments tend to underpredict real pesticide exposure and impacts in field settings. The corollary is that the current regulatory framework in Europe proves insufficient to protect biodiversity and ecosystems. Necessary improvements embedded in a policy reform include strengthening post-registration monitoring, refining predictive exposure models, and explicitly considering landscape contexts, indirect and mixture effects, and interactions with non-chemical stressors.