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Lord de Mauley

 

 

 

 

Parliamentary Under?Secretary Your ref'

Defra Our ref:

Nobel House Email:

17  Square Direct line:

London

SW1 3JR Date: 25 October 2012



Dear Maw-Key,-

Neonicotinoids and bees

You will be aware of the concerns being expressed by some organisations regarding the
regulatory assessments relating to neonicotinoid pesticides and in particular the effects of these
insecticides on bees and other pollinating insects.

This issue is very important to our industry in terms of agricultural pollination and the availability
of crop protection products, both of which are important elements of sustainable food
production.

The NFU echoes comments made by Defra in welcoming the EFSA Scientific Opinion published
earlier this year, which identi?ed gaps in knowledge and made recommendations to improve the
current risk assessment. As the science moves on our understanding improves, and this
enables us to identify gaps in current regulatory processes and develop ways to improve them
accordingly.

The assessments of recently published research in the EFSA statement and recent Defra report
(the state of the science and the regulatory response) are also welcome. These balanced
reviews have found these studies to be inconclusive in terms of the sub-lethal effects that are
likely to arise-from current uses of neonicotinoids.

The NFU fully supports a risk-based approach to regulation. In the absence of a weight of
evidence to support a change to approvals for neonicotinoid products, changes would be on the
basis of a precautionary hazard-based approach, which we do not support. The NFU believes
that taking 'a hazard-based approach would undermine the EU regulatory process that is
anchored in a science-based approach.

 

 

NFU, Agriculture House, Stoneleigh Park, Stoneleigh, Warwickshire CV8 2TZ 
Tel: 024 7685 8500 Fax: 024 7685 8501 Web:  

 

 

 

 

Registered in England 'No. 245E NFU mutuat



LETTER FROM NFU HQ

 

The EFSA Scientific Opinion highlighted that consideration needs to be given to the trade-off
between plant protection and the protection of bees. Neonicotinoids are a diverse group of
chemicals used in very different ways. In many cases they are the most effective pesticides
available. Having to rely on the currently available alternatives could result in a significant
reduction in yields and the use of a much higher volume of less effective active ingredients that
we believe could result in an increased risk to the environment, bees and other beneficial
insects.

The NFU fully supports the evidence and risk-based approach that has been taken by Defra on
this issue, and we look forward to seeing the outcome of EFSA's work to review the risk
assessments for neonicotinoids, due to be published in December 2012.

Yours sincerely

 

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