Research and analysis

Advice on applications to import and process food and feed from GM crops in the UK

Updated 20 October 2025

Advice of the Advisory Committee on Releases to the Environment (ACRE) under S.124 of the Environmental Protection Act 1990 (Part VI)  

This advice applies to the applications listed below.  

These applications are for the import of GMOs and their processing and consumption as food or feed. The advice is specific to GMOs (usually seed) derived from crops that are able to grow, for example, establish a viable growing population in agricultural (managed) conditions in the UK. However, feral populations of the crops listed below are not self – perpetuating and cannot establish a viable growing population, for example, if spilled during transportation or processing. This advice does not refer to the cultivation of such GM crops within the UK, hence it does not refer to potential volunteer plants linked to the cultivation of these crops. 

ACRE is satisfied that, in the UK, the import and processing of the GMOs listed below does not pose a greater risk to the environment or human health than do their non-GM counterparts. 

Authorisation will only be granted if the applicant has demonstrated that the GMOs in question are as safe as their non-GM equivalents. The Food Standards Agency (FSA) is responsible for food and feed safety. It is ACRE’s responsibility to assess the potential environmental impacts. This advice concerns the environmental risk assessment (ERA) and post-market environmental monitoring (PMEM) components of the applications listed below.  

Comment  

Environmental risk assessment (ERA) 

This advice applies to crops that have been genetically modified with traits that do not increase the ability of feral crop plants to establish and persist, unmanaged, under UK conditions” 

We have considered the ERA, and the PMEM plan and reports for each application on a case-by-case basis before deciding whether this advice reflects the conclusions of the specific risk assessment.  

We have considered the following potential pathways to environmental exposure.  

The ability of reproductive material, for example, seed to germinate and establish if spilled during transportation and processing is a crucial aspect in terms of the environmental consequences of importing GMOs. This is because the environmental risk posed by the GMO is a function of any hazards it presents to the environment and the exposure of the environment to these hazards.  

In the case of the GMOs listed below, seed spilt during transport and processing, and left unmanaged will not perpetuate to establish a viable growing population. Feral populations will decrease over time unless further spillage occurs. This restricts environmental exposure.  

Exposure of soil organisms to the GMOs listed below will be minimal due to a combination of the low risk of spillage and these plants being unable to persist, unmanaged in the UK’s climate.  

Regarding indirect exposure of organisms to transgene-encoded proteins that might remain in decomposing food, feed or reproductive material and/or in manure or faeces from animals fed these GMOs, our assessment is that such exposure would be extremely low and of no ecological relevance.  

Theoretically, it is possible that environmental exposure to GM proteins could increase if the transgenes encoding these proteins transferred to, and were expressed by, soil bacteria. Our view is that horizontal gene transfer (HGT) between plants and soil bacteria under field conditions can occur but is a very rare phenomenon. ACRE is content that if the transgenes encoding these proteins did transfer from plants to soil bacteria, fungi or other plants, they would not pose a greater risk to the environment than their non-GM counterparts.   

GM crops that have been processed into food or feed products do not pose an environmental risk as they cannot germinate.  

This advice is relevant to the UK only and we recognise that the situation regarding germination and survival of spilled seed or grain may be different in other countries.  

Post-market environmental monitoring plans (PMEMs) 

All applications to market GMOs must include a PMEM plan. This plan should incorporate general surveillance for unanticipated adverse effects and, if necessary, case specific monitoring focusing on specific adverse effects identified in the ERA.  

The ERAs relating to applications covered by this advice do not identify any requirement for case-specific monitoring in the UK.  

Consequently, general surveillance PMEMs are appropriate for applications covered by this advice.  

We recommend that PMEM plans should include details of who will be responsible for providing any required information – what type of information is to be provided, the frequency and how the applicant will ensure participation to allow a robust assessment to be performed. 

Additionally, we recommend that in all cases applicants provide clear guidance to operators to ensure that environmental exposure is further minimised. The guidance should specify that good port practice needs to be employed to minimise spillage of imported seed and clean up any spillage should it occur. The applicant should also provide information on how to identify and control any volunteer plants occurring within port or processing areas. It should be specifically stated that control must not include the use of the herbicide to which imported oilseed rape is tolerant. This is in line with existing schemes, based on Hazard Analysis of Critical Control Point (HACCP) principles, which are currently implemented by operators.  

Summary conclusion 

Viable feral populations of the crop plants listed below will not establish in UK conditions. This advice applies to GMOs that do not show altered characteristics that could indicate a greater potential to persist or invade new habitats. As such, any GM plants carrying the transgenic events listed below that may germinate from grain spilled during importation or transport will not persist or survive in the receiving feral environments of the UK. They do not pose a greater risk to the environment than their non-GM counterparts. We advise that it is not necessary to control plants containing the GM events listed below. Due to the lack of significant environmental exposure, we consider that general surveillance is appropriate.

Applications advice relating to oilseed rape

Reference	Crop type	Event	Applicant	Advice agreed by ACRE
EFSA/GMO/UK/2005/25	Oilseed rape	T45 Glufosinate- ammonium tolerant	Bayer Bioscience	4 June 2008
EFSA/GMO/NL/2010/87	Oilseed rape	GT73 Glyphosate tolerant	Monsanto	28 October 2013  (see note 1)
EFSA/GMO/BE/2011/101	Oilseed rape	MON88302 Glyphosate tolerant	Monsanto	4 August 2014
EFSA/GMO/NL/2009/68	Oilseed rape	Ms8 x Rf3 x GT73 Glufosinate- ammonium Glyphosate tolerant	Bayer CropScience and Monsanto	10 June 2016
EFSA/GMO/NL/2013/119	Oilseed rape	MON 88302 x MS8 x RF3 Glufosinate- ammonium Glyphosate tolerant	Monsanto Company and Bayer CropScience	22 May 2017
EFSA-GMO-BE-2016-138	Oilseed rape	MS11 Glufosinate-ammonium tolerant	Bayer CropScience	11 June 2020
RP1372	Oilseed rape	DP 073496-4 Glyphosate tolerant	Pioneer Hi Bred International	25 July 2023
RP1869	Oilseed rape	MON94100 Dicamba herbicide tolerant	Bayer Agriculture BV	7 Nov 2023
RP1585	Oilseed rape	MS8 Glufosinate-ammonium tolerant	BASF Agricultural Solutions Seed US LLC	7 June 2024
RP1585	Oilseed rape	MS8xRF3 Glufosinate-ammonium tolerant	BASF Agricultural Solutions Seed US LLC	7 June 2024
RP1585	Oilseed rape	RF3 Glufosinate-ammonium tolerant	BASF Agricultural Solutions Seed US LLC	7 June 2024
RP2065	Oilseed rape	LBFLFK Imidazolinone-based herbicide tolerant	BASF Plant Science (GmbH)	10 February 2025
RP2029	Oilseed rape	MS11xRF3xMON88302 Glyphosate tolerant	BASF Agricultural Solutions	10 March 2025

Table notes 

1. The scope of this application covers placing on the market food or food ingredients produced from GT73 oilseed rape, including its pollen and the accidental presence of viable seeds.