Dear Commissioner Kyriakides,
On April 7, you announced the intention of the European Commission to proceed with adopting restrictions to greenhouse uses only for the insecticide active substance sulfoxaflor, despite the lack of qualified majority and opposition of many Member States whose farmers depend on this product for food production1.
As the authorisation holder for sulfoxaflor, we would like to share our comments in this open letter regarding this decision which would unwarrantedly deprive EU farmers of a safe and innovative food production tool.
An innovative insecticide designed to minimise impact on pollinators
As a company, we support the EU Green Deal objectives to continue reducing the risks associated with the use of pesticides and to foster biodiversity and pollinators safety across Europe. We are also confident that this ambition can be achieved with a science-based framework to evaluate pesticide safety, while ensuring farmers have better access to a full range of safe solutions, including conventional pesticides and biocontrol, to protect their crops as part of Integrated Pest Management programmes.
Authorised at EU level since 2015, registered in 18 EU Member States and 93 countries worldwide, sulfoxaflor controls economically important sap-feeding insects that damage or destroy many crops, leading to unnecessary food waste. Sulfoxaflor quickly degrades in the soil and displays a favourable toxicological profile with low residual toxicity and no unacceptable risks to pollinators.
Our industry strives to accelerate the development of new, better solutions to farmers’ problems of pests, climate, and diseases, and to advance enhanced farming practices that utilise better technology to produce our food while using less resource. We are developing pesticides that are highly selective and with short persistence to protect pollinators and the environment, aligning with expectations from policymakers, regulators and consumers.
Sulfoxaflor was developed specifically to focus on harmful insects and is fully compatible with Integrated Pest Management programmes which are key components of the Farm to Fork strategy. Extensive laboratory and semi-field studies have been conducted on sulfoxaflor and demonstrate low risks to pollinators. Sulfoxaflor has been used safely for over 9 years worldwide, and 4 years in Europe, with no reported adverse effects on bees or pollinators.
A solid basis for maintaining open field uses in the EU
The decision to adopt restrictions to greenhouse uses only for sulfoxaflor is disproportionate and unjustified considering the strong scientific evidence supporting open field uses, the availability of risk mitigation measures and compatibility with Integrated Pest Management. We regret to see such decisions driven by unsound political considerations rather than science.
How to ensure EU farmers have access to safe and innovative solutions?
In a context of depleting insecticide toolbox in Europe and increasing food security challenges, sulfoxaflor provides an essential tool for farmers to protect their crops.
The use of sulfoxaflor open field already benefits farmers on a wide range of crops that are critical for EU competitiveness and consumer choice. It includes uses on fruit such as apples, peaches, tomatoes, citrus, as well as on vegetables, potatoes, and cereals. Crops worth €129bn, on 31% of Europe’s total agricultural area, were estimated to benefit from sulfoxaflor4. As an example, the sugar beet sector and the entire sugar value chain are struggling to cope with the lack of solutions to control aphids and beet yellows virus. Adopting these restrictions to greenhouse uses will deprive sugar beet farmers from a safe and effective solution, negatively affect their productivity and generate unnecessary food loss. Arable farmers would also be penalised as sulfoxaflor products are authorised on cereals in 8 EU Member States and registrations on oilseed rape were underway.
Does the European Commission plan to reduce the use of pesticides by 50% by arbitrarily restricting uses regardless of their demonstrated safety and without considering risk mitigation measures and the consequences for European farmers and food security?
As a company, we stand behind the safety of our products. We expect EU decision-makers and the regulatory framework to provide us, as applicant, with a fair opportunity to demonstrate it. We are deeply concerned with the fact that arbitrary and questionable political decisions seem increasingly to be made, as shown here on sulfoxaflor, to eliminate without credible justification important tools for securing farmer livelihoods and food production in Europe.
We intend to submit in the coming months another comprehensive dataset including the studies that were not considered by EFSA and which will further support the safety of sulfoxaflor for open field uses. In its review of this new application, we urge the European Commission to respect the spirit and the objectives of EU pesticide legislation and of the wider context of the Green Deal objectives and food security.
President Europe, Corteva Agriscience
1 Link to the European Commission Press Release:
2 Link to the EFSA conclusions:https://www.efsa.europa.eu/en/efsajournal/pub/6056
3 The experts expressed the opinion that it is reasonably likely that the risk identified for the treated crop may be mitigated by restricting applications to a certain number of days before flowering. […] Situations where flowering weeds are not present in the field would result in a low risk to bees. […] It is reasonably likely that the risk identified for [the field margin] scenario could be mitigated by spray drift reducing measures” (EFSA 2020 conclusions)
4 According to a study conducted by Nomisma for Corteva: