Insufficient Environmental Protection by the European Regulatory Framework for Pesticides

Abstract

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 reexamine these claims based on existing evidence from monitoring, systematic reviews, and different types of field studies. The available evidence indicates that measured pesticide concentrations frequently exceed predicted concentrations and regulatory thresholds and are associated with adverse ecological impacts. 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 that propagate within biological communities. These neglected intricacies explain why current single-substance prospective assessments tend to underpredict real-world pesticide exposure and impact in field settings. The corollary is that the current regulatory framework in Europe proves to be insufficient to protect biodiversity and ecosystems. Priority regulatory reforms include strengthening postregistration monitoring, refining predictive exposure models, and explicitly considering landscape context, indirect and mixture effects, and interactions with nonchemical stressors.