Below is a letter NAICC received from Sustaining Members Bayer, Syngenta and Valent regarding submitting
comments to EPA on the “neonic” class of products.
Dear Valued Stakeholder:
As you are likely aware, the class of insecticides known as neonicotinoids or “neonics” that include imidacloprid, clothianidin, thiamethoxam and dinotefuran are currently undergoing Registration Review with the EPA. Registration Review is a multiyear process, scheduled for completion for all neonics in 2018/2019. The first public comment period in 2016 was for the imidacloprid preliminary pollinator assessment. Along the review timeline, there will continue to be opportunities for stakeholders to directly affect the review outcome by commenting to official EPA dockets. When these opportunities arise, it is critical that you, as a vested stakeholder, articulate how important these products are:
• Comments on the critical role of neonics and any impacts their loss would have to pest control, IPM programs, input
costs, crop yields and quality, landscapes and nurseries, etc.
• Include real-world use information, including target markets, percentage of acres/area treated, use rates and
number of applications, target pests, impacts of alternative products (if available), resistance-management concerns, etc.
• Ask the EPA to consider the real-world use information provided and other relevant data to make higher-tiered,
science-based assessments — rather than ultra-conservative assessments based on unrealistic use patterns.
• Once completed, please post your comments to each of the four open dockets (imidacloprid, clothianidin, thiamethoxam
and dinotefuran), so that the neonics are represented as a whole.
To assist your efforts, we are outlining the review timelines, product brands and benefits of neonics, along with instructions for submitting your comments to the dockets. You can also find these and other supporting studies at www.GrowingMatters.org.
If you have any questions regarding a specific neonicotinoid, please feel free to contact one of us, depending on the product in question.
Thank you for your sustained effort in ensuring these products remain available in the marketplace.