Benchmarking environmental risks of plant protection products: Toward a comparative and systems-based approach in the EU pesticide regulation

Environmental risk assessment (ERA) of plant protection products (PPPs) in the European Union is conducted on a substance-by-substance basis. This hampers the comparison of risks across substances, taxa, uses, or ecosystems, thereby limiting the identification of lower-risk alternatives. We propose a conceptual framework for benchmarking, i.e., systematic comparison and ranking of PPPs based on standardised risk profiles. The framework builds on our analyses of key challenges in the current ERA, including heterogeneity in higher-tier data, divergent representative use scenarios, inconsistent time scales, and the absence of a centralised data repository. The framework addresses these issues by promoting consistent criteria, streamlining input variables, and enhancing data integration. The practical applicability is illustrated with a proof-of-concept using Tier 1 aquatic effect data and FOCUS Step 1 exposure. Benchmarking outcomes may be influenced by current gaps in hazard assessment, but the framework is designed for iterative updates and can be extended to biocontrol agents through adjustable endpoints. By leveraging harmonised test methods and existing regulatory data, the framework aims to support science-based, comparative, and adaptive ERA processes. This approach supports a shift from a substance-by-substance review to a comparative, systems-based ERA. Implementing benchmarking would enhance regulatory efficiency, improve transparency, and promote a more sustainable pesticide use in line with biodiversity protection goals.