EFSA’ s final version of Guidance on environmental risk assessment (ERA) is inadequate to assess the risks of genetically engineered plants. It is based upon comparative assessment – a concept that is far too narrow and biased. It does not define any cut off criteria even for plants that are persistent and might become invasive. It is not sufficiently clear on the risk assessment of stacked events and does not integrate all relevant levels of the food web. For example, wildlife vertebrates are completely omitted. Further deficiencies are listed in previous documents prepared by Testbiotech.