Pre-market/prospective environmental risk assessments (ERAs) contribute to risk analyses performed to
facilitate decisions about the market introduction of regulated stressors. Robust ERAs begin with an
explicit problem formulation, which involves among other steps: (1) formally devising plausible pathways
to harm that describe how the deployment of a regulated stressor could be harmful; (2) formulating risk
hypotheses about the likelihood and severity of such events; (3) identifying the information that will be
useful to test the risk hypotheses; and (4) developing a plan to acquire new data for hypothesis testing
should tests with existing information be insufficient for decision-making. Here, we apply problem
formulation to the assessment of possible adverse effects of RNA interference-based insecticidal
genetically modified (GM) plants, GM growth hormone coho salmon, gene drive-modified mosquitoes and
classical biological weed control agents on non-target organisms in a prospective manner, and of
neonicotinoid insecticides on bees in a retrospective manner. In addition, specific considerations for the
problem formulation for the ERA of nanomaterials and for landscape-scale population-level ERAs are
given. We argue that applying problem formulation to ERA maximises the usefulness of ERA studies for
decision-making, through an iterative process, because: (1) harm is defined explicitly from the start; (2)
the construction of risk hypotheses is guided by policy rather than an exhaustive attempt to address any
possible differences; (3) existing information is used effectively; (4) new data are collected with a clear
purpose; (5) risk is characterised against well-defined criteria of hypothesis corroboration or falsification;
and (6) risk assessment conclusions can be communicated clearly. However, problem formulation is still
often hindered by the absence of clear policy goals and decision-making criteria (e.g. definition of
protection goals and what constitutes harm) that are needed to guide the interpretation of scientific
information. We therefore advocate further dialogue between risk assessors and risk managers to clarify
how ERAs can address policy goals and decision-making criteria. Ideally, this dialogue should take place
for all classes of regulated stressors, as this can promote alignment and consistency on the desired level
of protection and maximum tolerable impacts across regulated stressors.