The HSE (Health and Safety Executive) says the changes it published in September 'clarify and strengthen' the guidance to ensure that anyone applying for an EA (emergency authorisation) must take full account of any risks posed to pollinators.
They come as part of a government pre-election pledge to end the use of neonicotinoids under the EA regime. But when you assess patterns of EA use over time, it quickly becomes clear there’s only been a handful of EAs for neonicotinoids, and by far the majority granted in the UK have been for other pesticides, to combat issues such as new invasive pests and diseases, affecting both conventional and organic crops.
“We are concerned this latest approach taken by Defra could have unintended consequences on the future availability of these emergency measures.”
NFU Deputy President David Exwood
Unintended problems
Cruiser SB, containing the neonicotinoid thiamethoxam, has previously been used as a seed dressing to fight virus yellows disease in sugar beet, with strictly controlled EAs granted between 2021 and 2024. An application for the use of Cruiser SB in the 2025 sugar beet crop was rejected.
Prior to the seed treatment’s availability, some beet growers had lost up to 80% of their crops to the disease. In 2020, 38% of the crop was affected nationally, and overall yields were down 25% on the five-year-average.
In recent years, EAs have been vital in controlling invasive non-native pests such as Spotted Wing Drosophila, which attacks soft fruit and stone fruit, and in tackling fungal diseases affecting organic apples and pears, sweetcorn and many vegetable seed crops.
With so few EAs having been granted for neonicotinoids, and the sole reason for updating the guidance, which applies to all EAs, being to seemingly specifically prevent neonicotinoid EAs being granted in the future, the concern is the new guidance will create unintended problems for other EA applications needed to tackle serious crop pest and disease issues.
‘EAs must be judged on case-by-case basis’
Responding to the news, NFU Deputy President David Exwood said: “Emergency authorisations are only applied for in extreme circumstances where there are no other viable options to protect crops from severe threat of disease, pests or weeds, and farmers from economic loss.
“Strict controls limit how long these products can be used for and the area they can be used on. Each emergency authorisation application should be assessed on a case-by-case basis, taking a science and evidence-based approach.
“We are concerned this latest approach taken by Defra could have unintended consequences on the future availability of these emergency measures, upon which farming sectors – facing new pest issues across hundreds of crops – can be reliant.”
EAs must tackle gaps in the armoury effectively
In an ideal world, we’d have a holistic and future-proofed pesticide regime that horizon scans for issues and ensures more effective lower-risk control options are available for all crop pest, disease and weed situations. But we are far from that situation.
The reality is we have a pesticide regulatory regime that creates arbitrary but significant gaps in the armoury, and short of not growing the crop (which is happening in some cases), EAs are the only option we have currently to plug these gaps.
Farmers and growers need HSE as the risk assessor, and Defra as the risk manager, to ensure the EA process is fit for purpose. The NFU believes this requires the EA approach to be more straight-forward, pragmatic, scientifically robust, risk-based and timely, to ensure consumer safety, and enable UK crop production.
The NFU is working with Defra to fully understand what the updated guidance means for prospective EA applicants such as NFU Sugar.
