Open letter to Commissioner Kyriakides on sulfoxaflor

Something went wrong. Please try again later...

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.

  1. EFSA conclusions support the safety of open field uses
    In your statement, you refer to the conclusions from the European Food Safety Authority2 as showing “that outdoor use of sulfoxaflor can be harmful for bumble bees and solitary bees”. In our view, this characterisation of EFSA conclusions does not align with the facts. Throughout its conclusions, EFSA refers to the availability of safe uses and low risks with appropriate risk mitigation measures, as highlighted in the excerpts quoted in footnote3. In addition, the fact that exposure is negligible for crops that are not attractive to pollinators (as they do not flower or are harvested before flowering, e.g., cereals and sugar beet) raise the question of why farmers are to be deprived of these safe uses.
  2. The latest scientific data has not been considered
    Only data submitted in 2017 has been reviewed in EFSA confirmatory data evaluation. During the past five years, additional studies were generated on sulfoxaflor which address further questions from EFSA. As an applicant, we have regularly shared our studies with the European Commission and Member States, but these were not reviewed by EFSA. And a perfect illustration of the misfunctioning of this system is when we consider why EFSA could not conclude on a low risk for wild bees, as mentioned in your statement. Wild bees were not part of the data requirements and there is a lack of approved guidance at EU level. EFSA could not conclude on a low risk for wild bees because of a lack of data, which as applicant we were not allowed to submit. And while the data on wild bees has since been generated to address EFSA latest questions, EFSA did not have an opportunity to review them before the hasty adoption of these restrictions.
  3. Member States role as risk manager has been ignored
    While EFSA carries out the risk assessment, the European Commission and Member States have a joint role as risk managers. Since sulfoxaflor recent approval in 2015, 17 Member States competent authorities have confirmed the safe use of sulfoxaflor in open fields. All existing sulfoxaflor authorisations in EU Member States already include risk mitigation measures and there are no uses during flowering. These mitigations have ensured that there has been no incidence on pollinators despite open field uses over four seasons. Member States are competent to put in place appropriate risk mitigation measures, and their views have been largely ignored as the restriction decision has been taken without the support of a qualified majority of Member States. As they are responsible for authorising Plant Protection Products containing sulfoxaflor, Member States have a significant expertise and are best placed to assess how risk to pollinators can be adequately addressed in their local conditions. However, the misguided political decision driven by the European Commission deprives those Member States that have shown their ability to safely manage the local use of this product of that option.

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.

Yours sincerely,
Igor Teslenko
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: