with pesticide regulatory-testing requirements, in contrast, are quite large relative to the fixed costs of developing new crop varieties. For example, the estimates presented here suggest that the sales volume needed to offset the cost of regulatory testing under FIFRA is almost triple the sales volume needed to meet the cost of developing a new variety of wheat from existing germplasm and 14 times the sales volume needed to meet the cost of developing a new small fruit variety from existing germplasm. As a result, regulating transgenic pest-protected plant products as “plant-pesticides” is likely to increase the expected annual sales needed to justify R&D investment substantially, making R&D related to crops with small seed markets less attractive and making it more difficult for smaller, less well-capitalized entities to enter the market.



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