Robin Blake, Senior Consultant Pens Editorial on EU Neonicotinoid Ban Removes Vital Tools in Global Fight Against Pests in October 2018 Issue of AgriBusinessGlobal
Importance of Neonicotinoids to Agriculture
Neonicotinoids have dominated global agriculture since their introduction in the 1990s and have become the most widely used insecticides accounting for over 25% of the global insecticide market with a value of approximately $4 billion in 2014. Their success is thought to be due to their unique chemical and biological properties, including broad‐spectrum insecticidal activity, low application rates, high target specificity and relatively low risk for mammals and the environment such that they have largely replaced older and more toxic insecticide classes such as organophosphates, carbamates, and pyrethroids. Neonicotinoids also benefit from versatility in application methods — as a targeted seed treatment, soil drench applied to the roots, or foliar spray, and they are systemic such that the insecticide moves from the site of application to protect all parts of the plant as it grows. They are used to control many agronomically important foliar and soil-borne pests in crops including corn/maize, soybean, oilseed rape (OSR)/canola, potatoes, rice, and wheat.
Current Regulatory Status of Neonicotinoids in the EU
On 30 May 2018, European Member States endorsed proposals from the European Commission to completely ban all outdoor uses of three neonicotinoids: imidacloprid and clothianidin (manufactured by Bayer), and thiamethoxam (manufactured by Syngenta), due to concerns over their impact on bees. The decision followed an EU-wide moratorium that was put in place in 2013, on the advice of the European Food Safety Authority (EFSA), to prohibit the use of these three neonicotinoids in bee-attractive crops (including corn/maize, oilseed rape/canola, and sunflower), with the exception of uses in greenhouses, of treatment of some crops after flowering, and of winter cereals.
In addition, Syngenta and Bayer were requested to provide confirmatory information for each of their substances to confirm the safety of the uses still allowed. Following the assessment of these additional data by EFSA, it was concluded that the outdoor uses could not be considered safe due to the identified risks to bees. The ban commences on 19 December 2018. Some EU Member States have gone a step further. For example, France has already banned the use of clothianidin, imidacloprid, and thiamethoxam in greenhouses as well as outdoors, and has also extended the ban to include two more neonicotinoids, acetamiprid and thiacloprid.
The EFSA Draft Bee Guidance Document
The EFSA assessment of the confirmatory information was based on the controversial Bee Guidance Document which, although first published in 2013, remains in draft format and thus has not been ratified by EU Member States. An impact analysis conducted by the European Crop Protection Association (ECPA) in 2017 concluded that the multiple exposure routes, numerous endpoints, and calculations required make the Bee Guidance Document extremely complex and overly-burdensome for the user, resulting in a risk assessment which is overly conservative and not representative of the actual risk under field conditions.
For example, the guidance stipulates that all honeybee field trials must have a mortality rate ≤ 7%, whereas normal hive mortality is closer to 15 %, and data from field trials are only accepted where the minimum trial area is 168 km2, far greater than the distance normally travelled by honeybees. Using the draft Bee Guidance Document, the ECPA analysis demonstrated that registration would be denied for most pesticides currently on the market in the EU, including those used in organic agriculture, even though many of these pesticides show no inherent bee toxicity. For neonicotinoids this effectively meant that all field trials conducted by industry were rejected as inadequate and thus only data from laboratory feeding studies, where bees were kept in small cages and fed unrealistically high doses of insecticides, were considered. Based on insufficient evidence of solely laboratory feeding test results, it is not surprising that EFSA could only recommend a precautionary approach on neonicotinoids.
Are Neonicotinoids Really to Blame for Bee Losses?
Numerous studies have shown that honeybees, bumblebees, and solitary bees are suffering global declines in abundance and species richness and various factors have been attributed to this including habitat loss, use of herbicides and insecticides, bee viruses, parasites and pathogens, poor beekeeping practices, and climate change. Insecticides, by their very nature, kill insects, so it is not difficult to assert that neonicotinoids can kill bees. Whilst it might be easy to focus on neonicotinoids as the major cause of bee declines, many beekeepers, both in Europe and North America, believe that parasites such as the Varroa mite and poor hygiene practices fuelled by an increase in hobby beekeepers are the leading causes (e.g. USDA, 2013).
Data from the European Commission show that managed honeybee colony numbers have been steadily increasing from 11.6 million beehives in 2004-2006 to 15.7 million in 2014-2016, despite the fact that this period has seen intensive neonicotinoid use. Similar trends have been observed in other regions, such as in New Zealand, where the number of managed beehives increased nearly threefold between 2000 and 2017, despite neonicotinoids being introduced there in 1992. Numerous studies, both in the public literature and from industry, demonstrate that when neonicotinoids are used in typical field applications and in accordance with label instructions that they are not harmful to bee colonies and do not pose a significant risk to bees. The challenge is that the factors attributed to bee losses often do not occur in isolation such that the reality is complex and multi-causal. Neonicotinoids may not be the leading stressor to bees; however, they are the one that humans have the greatest control over and so it is perhaps not surprising that a ban has been introduced.
Impact of Ban on EU Agriculture
The EU-wide moratorium has had a direct impact on crops such as OSR and sugar beet where neonicotinoid seed treatments previously provided effective early-season control of key pests, thereby reducing the need for subsequent foliar insecticide applications. For example, there were serious losses in OSR between 2014 and 2016 in the United Kingdom and other EU countries due to Psylliodes chrysocephala (cabbage stem flea beetle) and Myzus persicae (Peach-potato aphid). In the absence of neonicotinoids, farmers have relied on foliar pyrethroids. However, high levels of pyrethroid resistance in both flea beetles and aphids makes the treatments less effective and increases the number of applications necessary.
A meta-analysis conducted by the Humboldt Forum for Food and Agriculture (HFFA) in 2017 entitled Banning neonicotinoids in the European Union – An ex-post assessment of economic and environmental costs has found that the current ban has reduced annual OSR production in the EU by approximately 912,000 tonnes (4% yield reduction) at a cost of almost €900 million ($1050 million). Foliar applications have increased such that there are now an additional 0.73 applications per hectare (weighted average), mainly of pyrethroids. Sugar beet is not considered attractive to bees, yet it is still subject to the same neonicotinoid ban. Neonicotinoid seed treatments accounted for almost 100% of conventionally cultivated beet prior to the moratorium, and whilst some fields were also treated with foliar applications of carbamates and pyrethroids, their use is now expected to increase significantly, with corresponding decreases in yield predicted in Germany, France, and the UK.
The restrictions for neonicotinoids in the EU do not currently affect Maximum Residue Levels (MRLs) or import tolerances as use in indoor crops is still permitted and the restrictions are not related to human health concerns. However, the EU neonicotinoid ban will likely make it more difficult to produce high quality food crops such as wheat, barley, and sugar beet at a competitive price, and reduce the ability of EU farmers to compete with imports from countries that still use neonicotinoids in outdoor crops.
Neonicotinoid Use Outside the EU
A 2015 report from AgInformatics assessed the socio-economic benefits of neonicotinoids to agriculture in North America, and concluded that if neonicotinoids were no longer available, there would be reduced yields, greater pest control challenges and resistance issues, lower quality agricultural products, higher food costs, and harm to beneficial insects and integrated pest management (IPM) through the use of older broad-spectrum insecticides. Higher insecticide use, as older and less effective alternatives are used, will increase the total number of pounds of insecticide active ingredients applied to crops from 13 million to 28.2 million pounds. Operating costs will increase, due to the increased spend on insecticides and costlier application methods, with the average cost per acre projected to increase by greater than $8.30 for corn and $3.30 for soybean. In addition, the quantity of cropped land in the U.S. would need to increase between 340,000 and 410,000 acres to offset losses in yield and quality.
Presently, neonicotinoids continue to be used in the U.S. despite opposition from environmentalists and NGOs, although the U.S. Environmental Protection Agency (EPA) has pushed back a planned decision on neonicotinoids to 2019. In addition, the U.S. Fish and Wildlife Service (FWS) has reversed its 2014 decision to phase out neonicotinoids from U.S. national wildlife refuges, and instead consideration of their use will be decided on a case-by-case basis.
Health Canada’s Pest Management Regulatory Agency (PMRA) has recently announced plans to phase out outdoor uses of thiamethoxam and clothianidin, not because of bees, but due to concerns over aquatic invertebrates such as mayfly and subsequent impacts on the food chain, with farmers given three to five years to find alternatives. Neonicotinoids are currently applied to most of the corn and canola acreage in Canada. A decision on imidacloprid is expected by the end of 2018. Bayer has since questioned the PMRA’s overly conservative decision to set safe levels at 1.5 parts per trillion (ppt) in its ban proposal, which is below both the limit of sensitivity of water quality tests (5-10 ppt), and the safe level in the US (50 ppt).
In New Zealand, the use of neonicotinoids near beehives or on flowers that bees visit is prohibited. However, the NZ EPA has started an investigation to determine if a complete ban would be beneficial, a move that has alarmed the agricultural sector where a ban could cost 1.2 billion NZ dollars. The Australian Pesticides and Veterinary Medicines Authority (APVMA) has previously stated that “All neonicotinoids registered for use in Australia have been through the APVMA’s robust chemical risk assessment process and are safe and effective — provided products are used as per the label instructions.” Whilst this is a pragmatic approach, there is continued pressure from environmentalists seeking a ban.
Future of Regulatory Decision-Making in the EU
The recent neonicotinoid ban in the EU represents an overly conservative approach to pesticide regulation, and in using the Draft Bee Guidance Document, one where the majority of pesticides currently on the market will fail. There is no definitive scientific evidence that neonicotinoids are the primary cause of declines in bees, and although banning these insecticides is the factor that humans have the greatest control over, it represents an overly simplistic solution to a very complex problem, and one that alone may not improve bee health. Whilst extreme pressure from environmental NGOs and politicians have undoubtably helped shape these decisions, it is imperative that the regulatory process allows scientific innovation to help achieve food security and protect the environment.
Ruling against recent lawsuits brought by Syngenta and Bayer CropScience to contest the bans on their respective neonicotinoids, the General Court of the European Union, said that the EU’s “precautionary principle” meant that the EU could take measures if there was scientific uncertainty about risks to human health or the environment. The precautionary principle lies at the heart of EU regulation and effectively puts the burden of proof to demonstrate that a pesticide poses no unacceptable risk onto the manufacturers. Given that neonicotinoids are insecticides, and insecticides kill insects, it is not difficult to connect how the use of the precautionary principle led to the neonicotinoid ban. However, this principle is at odds with the desire to innovate – the so-called “Innovation principle” – “whenever policy or regulatory decisions are under consideration the impact on innovation as a driver for jobs and growth should be assessed and addressed.”
The innovation principle and precautionary principle should be complementary, recognizing the need to protect society and the environment while also protecting the EU’s ability to innovate. Neonicotinoids represent one such innovation where their highly targeted nature, especially as seed treatments, makes them effective within Integrated Pest Management (IPM) strategies, in comparison to alternatives such as pyrethroids, OPs, and carbamates, that are known to be highly toxic to bees (and other non-target invertebrates) through spray drift. Replacing neonicotinoids with these products will also result in higher overall environmental risks, including risks to taxonomic groups that are not adversely affected by neonicotinoids such as birds, mammals, and fish, together with higher risks to humans, particularly applicators.
The HFFA report recommends that potential environmental concerns must be balanced against the need to boost agricultural productivity, and if such an assessment results in societal benefits outweighing the costs, then the technology should be applied. The hope is that regulators in other regions of the world will judiciously balance innovation and precaution, and base decisions on science rather than opinion or fear, and thus allow the continued use of neonicotinoids as vital tools in the global fight against crop pests.
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