Beginner's Guide to Neonicotinoids and derogation

All the questions you may have about Neonicotinoids - answered. If further information is required, please phone our press office on 02476 858686 and we can arrange for you to speak to an adviser knowledgable in this area. Spokespeople are available.

 

What is a Neonicotinoid?

A Neonicotinoid is one of a group of chemicals that are used in agriculture to control insect pests, so they are insecticides. There are a range of chemicals that are characterised as Neonicotinoids.


What is it used for?

It’s used to manage insects pests in crops.


What pests/diseases does it prevent?

It is used to manage a whole range of insect pests that munch crops such as flea beetle, aphids, pollen beetle and other sucking insects, like aphids, that also spread viruses leading to diseased plants.


What crops is it used on?

The use of certain Neonicotinoid has been restricted by the EU Commission on crops such as oilseed rape, maize and ornamental plants for a minimum of 2 years, but these Neonicotinoids continue to be used on a wide range of other commonly grown crops such as potatoes, sugar beet, winter wheat and a range of fruit crops. 


How is it used?

It is applied both as a spray and as a seed treatment, dependent upon the crop and the pest. The main restricted uses are in seed treatments or soil drenches.


How much is it used?

They are widely used as insecticides because they are effective, but also because there are few other effective insecticides that can control major pests. However, their use is limited both in terms of how they are applied and how much is used and when, based on safety restrictions laid down by regulators.


Why were restrictions placed on Neonicotinoids in the first place?

The EU Commission chose to restrict the use of certain uses of Neonicotinoids because there were gaps in the data provided by chemical companies on certain Neonicotinoid actives. The reason for these gaps was that European Food Standards Agency had developed new criteria (not based on international standards) for its assessments based on ‘theorised risk.’

The research that led to this was able to demonstrate harm to bees under controlled conditions but significant bodies of field studies based have not been able to assert comparable results. A commission representative recently indicated that the restriction was not imposed because Neonicotinoids are the main threat to bee health, but because they are a factor that could be quickly regulated by the European Commission.


Who called for the derogation?

Emergency authorisations on plant protection products are part of existing European regulations. They are available when crop production and/or the environment are at imminent risk from a pest threat and a plant protection product (e.g. a pesticide) is available that could alleviate the pressure. Farmers need crop protection products to grow their oilseed rape crops productively; Syngenta responded to the industry need for the product.


Why is Sygenta asking for a derogation?

Syngenta is asking for a derogation to help UK growers in areas where flea beetle and aphid pressures are historically a major issue, both to help safeguard these crops but also to reduce the risk of resistance developing to pyrethroid products, which are the only other control.


What is Cruiser and how is it different?

Cruiser OSR is a specific product produced by Syngenta. It contains the active ingredient Thiamethoxam, this is applied as a seed treatment to oilseed rape.


Has it got more environmental benefits?

The use of insecticides in seed treatments has long been seen as a step forward in a truly intergrated approach because you can minimise use by targeting only insects that attack the seed or the plant in the crucial period when the seed is sown and begins to grow.

The result has been that total weight of pesticides applied had decreased steadily since 1990 and had fallen by 50% by 2012. The weight of active per ha has fallen steadily from 0.774kg/ha in 1991 to the lowest level in 2012 at 0.22kg/ha in 2012, a decrease on average of over 71%. While this cannot all be attributed to just Neonicotinoids or seed treatment, it has been a contributing factor. Access to a range of active ingredients is an important factor in integrated crop management, particularly in reducing the chance of resistance developing in pest populations.


What crop will it be used on?

The emergency authorisation request in England was for use on autumn sown oilseed rape only.


If the exemption is disallowed, what will the effect on the ground be for farmers?

Growers have been very concerned that crops are at increased risk from flea beetle and aphids that spread infection to the crop.HGCA research on the implications of the restrictions on Neonicotinoids in oilseed rape states that without insecticides the average yield loss to TuYV is 15 per cent although yield losses of up to 30 per cent can occur.

Farmers also have been reluctant to plant spring crops without neonicotinoids. We have already seen evidence in the first spring without Neonicotinoids that reduced area and difficulty in controlling insect attack on seedlings has happened in the UK and in other countries around Europe such as Sweden who have reported loss of up to 70% of their national spring sown oilseed rape crop. Crops that were planted, even in the lowest-risk situations, came under severe attack from insect pests.


Why is Cruiser so important to farmers?

Cruiser OSR is specifically produced for use on oilseed rape with an understanding of the key pest threats, the threat from flea beetle in particular is that it can destroy the seedling before it even gets out of the ground. There is no other way to protect the seed from flea beetle pre-emergence than to use a seed treatment that contains a Neonicotinoid.

For aphid control the use of Cruiser OSR offers 6-8 weeks of protection to the establishing plant which also allows beneficial insects to forage on pests as part of an intergrated approach. We support a derogation because without these important chemicals we are undermining our immediate production potential but also our long term pest management strategy by increasing the pressure for resistance to develop in the remaining active ingredients.


Why is this derogation being put forward when the Task Force report has just been published?

The task force report was developed on a completely different timeframe to the derogation to use Cruiser OSR. The task force report has not been published, although the conclusions have been given to the press and so it is impossible to know if there is any new science behind the claims until the report is published.

The government's Advisory Committee on Pesticides evaluated the 2014 application and was happy that the derogation be given they would not have done so if they had safety concerns. They also stated that the ACP had not supported the commission restriction of Thiamethoxam (the active ingredient in Cruiser) in 2013. It is also important to note that the Oxford Martin School ‘independent review of the evidence around Neonicotinoids and bees’ published in May 2014. This review, by an international group of independent scientists, concluded that there is a limited evidence base to guide policy makers on the issue of Neonicotinoids and insect pollinators. The review also made clear that declines in bees started to occur decades before Neonicotinoids were introduced, and that since their introduction there is some evidence that these declines have actually slowed down, or even reversed for groups like solitary bees in the UK (which make up the majority of our bees species).


When is the deadline for the decision?

Applications are as time critical as any emergency request is. For 2015 harvested crops, Syngenta indicated it was difficult to gurantee supply after Friday 27th June 2014.


If allowed, when would Cruiser be applied?

It would be applied to seed that will be sown mainly in August.


When will the crop affected by a derogation be harvested?

The 2014 planted crop will be harvested in the summer 2015, normally in July.


Who was making the decision on whether the derogation was to be allowed?

The decision appears to have become a political issue, because the ACP as the independent advisory group with scientific expertise has recommended to Defra it be issued, which would normally mean the decision would be passed and the emergency authorisation granted.


How many farmers would be affected by this?

Hundreds of growers will be affected as this derogation would cover around a quarter of the oilseed rape hectarage.


How many hectares did the derogation ask for Cruiser to be applied to?

186,000ha maximum.


Whereabouts in the country would Cruiser be applied if the derogation was allowed?

The derogation was for England only, it will be for use on early sown crops and those where is a known historic risk from specific pests of oilseed rape.


Whereabouts in the country has the most OSR?

Oilseed rape is grown nationally as a break crop and alternative to cereal crops. It is essential for appropriate management of soils and grass weeds.


Our response to some misconceptions:

 

Farmers or NFU do not generally claim ‘yield’ loss before harvest. At the stage while an emergency use authorisation request for 2014 planting of winter rapeseed crops was still live, NFU reported crop damage along with the damage to farmers ability to plant crops with a realistic prospect of these surviving due to high risk of failure from insect pest attack. This was demonstrated in vastly reduced area of spring oilseed rape established in 2014 in a number of Member States, including Sweden. Direct crop loss from physical attack after crops have been planted in an individual year is one part of the NFU position on neonicotinoids, but not the only element.

  • Research about bees damaged by neonicotinoids is based on experiments where bees are dosed artificially with the insecticide. The few true field experiments that have been conducted, where bees are exposed to neonicotinoids by foraging naturally in and around treated crops, have failed to demonstrate harmful impacts.
  • European farmers have been able to grow spring rapeseed, at recent scale, in response to market demand for animal feed and vegetable oil and providing early wide scale pollen and nectar sources each year partly due to availability of insecticides in the past. From the introduction of restrictions on neonicotinoids farmers are now much less able to plant and harvest this crop, with all its environmental and economic benefits, due to the risk of pest attack. The very large reduction in spring oilseed rape planting in northern European countries for 2014 harvest and damage to crops that were planted is in the main due to current neonicotinoid seed treatment restrictions. Increased winter crop planting in 2013 was largely undertaken because farmers knew that was the last chance to grow a crop reliably protected with neonicotinoid seed treatment. Sweden for example has in fact lost overall oilseed rape area in 2013/14 and very dramatically reduced spring rapeseed area, losing 70%, despite the very best planting conditions and one of the mildest winters, with almost no winter-kill, probably in living memory. The reduced area will only be maintained by 2015 harvest if exceptionally favourable conditions are repeated for the second year in a row, including allowing above average area planting of winter rapeseed in the first place. The lost area of spring oilseed rape is unlikely to be regained without an effective insecticide solution. Swedish, Finnish and some other European rapeseed growers farmers normally suffer high losses if planting winter rapeseed plantings due to the cold northern winters, but up to now have been able to reliably replace failed winter crops with spring seed - treated with insecticide. Harvesting anywhere near 100% of winter crops in colder climate countries is not normally a choice, and risks are increased for insect attack in the summer and autumn of 2014 as well as through 2015 with neonicotinoid restrictions in place. Latvia lost around 90% of winter oilseed rape plantings in 2013/14 due to winter-kill.
  • The EU Commission has imposed a restriction, not ban, on neonicotinoids which are legitimately still in use in Europe on cereal crops.
  • Before committing to plant winter rapeseed in summer 2014 farmers should remain concerned as the risks of crop losses in the absence of neonicotinoids are much higher, as is the work involved in field spraying compared to seed treatment, and they will need to be aware of this in making decisions in establishing crops.
  • Some have referred to the story about a ‘task force report’ developed on a completely different time frame to the derogation request to use Cruiser OSR. The ‘taskforce on systemic pesticides’ Worldwide Integrated Assessment had not been published at the time despite conclusions provided to the press and so it was impossible to know if there is any new science behind the claims before the report was published. To date it appears as though just two papers have been published – one talking about impacts on vertebrates and the other being the ‘conclusions’ paper.
  • Relatively few crop protection products, including insecticides, deliver an increased yield. Most pesticides are instead used to limit damage cause by pest attack. Yields are increased by other inputs, such as more light, water or nutrition inputs than would otherwise be available while crop protection products allow more of a crop’s potential yield to be achieved. It is basic agronomic understanding that using neonicotinoids, or most other pesticides, would not improve crop yield per se.



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