Sumitomo Chemical Agro Europe’s views on draft amendment to European Commission Implementing Regulation as regards the conditions of approval of active substance Clothianidin proposed to SCOPAFF (Standing Committee on Plants, Animals, Food and Feed ) on 22nd-23rd March 2017 (the “Draft Amendment”)

The European Commission (DG Sante) has proposed in the Draft Amendment further limitations on the use of insecticidal active ingredient, Clothianidin. According to the Draft Amendment, only uses in permanent greenhouses and where the crop stays its entire life cycle within the permanent greenhouses or uses as seed treatments of crops staying their entire life in greenhouses can continue to be authorised.

Sumitomo Chemical Agro Europe (SCAE) strongly disagrees with the imposition of the use limitation as proposed in the Draft Amendment, as SCAE is fully confident that its Clothianidin based products can continue being safely used without any substantial risk to the wildlife and the environment, including pollinator health, as long as they are used according to the product label instructions, as evident from numerous scientific studies. Also, a growing number of new publications have shown that causes of the bee decline are largely multifactorial and that a simple ban of all neonicotinoids will not solve the issue.

The European Commission has relied on the results of risk assessment as conducted by EFSA (European Food Safety Authority) in leading to the conclusion thereby making such conclusion unjustifiable. The method of risk assessment that EFSA has utilized per the EFSA-2013b guidance document on bees published on 4th July 2013 has never been adopted by the Member States, as it has been criticized as scientifically disproportionate and unworkable. SCAE believes that the criteria set within the document are so unrealistically stringent that the vast majority of pesticides, including those used in organic agriculture, would not pass the assessment. Thus it is SCAE’s firm view that the European Commission should not rely on the above EFSA’s Guidance document and that it should conduct a risk assessment in a more scientifically proportionate and workable manner, agreeable to the Member States, and review the results of the same, before it leads to its conclusion.

SCAE has rigorously used science as a base for its activities. SCAE has regarded the safety of our products as of paramount importance, and thoroughly reviews any new reports and information relevant to our products. Based on such review, SCAE has concluded that the Draft Amendment should not be imposed, and urges the Member States to disapprove this Draft Amendment.


Sylvia Plak, Development and Registration and Regulatory Affairs Director – E-mail:

Geraldine Riou, Registration Manager – E-mail: