“…Critical gaps in the re-registration of glyphosate, including the EU re-registration process itself, have been addressed (European Parliament Council, 2002;Myers et al, 2016), particularly those considered more pressing by recent scientific findings. These include: (a) increasing exposures of EU citizens to glyphosate residues, supported by human and environmental biomonitoring data in limited number (Curwin et al, 2007;Mesnage et al, 2012;Krüger et al, 2014;Niemann et al, 2015;Connolly et al, 2017;Conrad et al, 2017;Mills et al, 2017;Vandenberg et al, 2017), but identifying a clearly rising trend; (b) carcinogenicity classification by IARC, evidence of linkages of glyphosate or its formulated products to non-Hodgkin's lymphoma (Hardell et al, 2002;De Roos et al, 2003Eriksson et al, 2008;Schinasi and Leon, 2014;Mesnage et al, 2015b), and effective dose levels indicated in rodent oncogenicity studies being 1-2 orders of magnitude lower when formulated glyphosate-based herbicides were used compared to those obtained with the pure active ingredient; (c) evidence of contributions to fatal chronic kidney disease by glyphosate in areas with heavy metals in water (Jayasumana et al, 2014(Jayasumana et al, , 2015 and the finding of nonalcoholic fatty liver disease upon exposure to a glyphosatebased herbicide (Roundup R ) (Mesnage et al, 2017b), coupled with the powerful animal metabolism data embedded within the re-registration document appendices (showing glyphosate and AMPA levels higher in kidney than in liver, and much higher than in muscle tissue); as well as (d) problems (e.g., risk assessment studies for regulatory purposes of re-registration of glyphosate being carried out with pure glyphosate) arising from the dual character of pesticide registration in the EU with active ingredients authorized at EU and formulated products at MS level (Klátyik et al, 2017a). In light of these findings, earlier risk assessment statements (Williams et al, 2000) are untenable for both hazard and exposure levels.…”