—

annul the defendant’s decision of 8 July 2021, refusing to revoke or to amend the defendant’s implementing decision (EU) 2021/61 (1), by which Monsanto Europe SA has been permitted, under the GM Regulation (2), to market genetically modified maize MON 87427 x MON 87460 x MON 89034 x MIR162 x NK603 and its sub-combinations in the EU;

—

order any other measure deemed appropriate; and

—

order the defendant to pay the costs.

1.

First plea in law, alleging that the defendant committed a manifest error of assessment in failing to give any or any adequate consideration to the potential impact of gene stacking on gene expression in combination with exposure to drought conditions and/or failed to require an adequate assessment under drought conditions to be conducted.

2.

Second plea in law, alleging that the defendant committed a manifest error of assessment in failing to give any or any adequate consideration to the potential impact of gene stacking on gene expression in combination with herbicide applications and/or failed to require an adequate assessment under conditions of repeated and/or high application of herbicide.

3.

Third plea in law, alleging that the defendant committed a manifest error of assessment in failing to give any or any adequate consideration to the potential impact of gene stacking on plant composition and agronomic characteristics in combination with exposure to drought conditions and herbicide applications.