The compelling case was prepared by British Sugar, NFU Sugar and the British Beet Research Organisation, seeking a positive recommendation by the Expert Committee on Pesticides and then approval by Defra. It noted the severe impact of Virus Yellows in 2020 and the very real threat to the sugar beet industry. The application made, met the three requirements for emergency authorisation.
- Authorisation necessary because danger cannot be contained by other means:
The neonicotinoid seed treatment provides important protection to the emerging crop against insect pests and the viruses they can transmit. This protection cannot be provided by any other reasonable means. Sugar beet yields were significantly reduced in the 2020 season due to the incidence of virus, and similar conditions in 2021 would be likely to present similar dangers.
- Use of product will be limited and controlled:
The applicant proposed a reduced application rate for the seed treatment to deliver less of the product to the soil. In addition, the applicant proposed use of a virus forecasting model to determine whether treatment is needed, setting a threshold for the level of virus infection above which economic impacts would be incurred. If this threshold is not met the seed will not be treated. Sugar beet cultivation in England is also spatially restricted by proximity to 1 of 4 beet processing factories situated in the east of England. All UK sugar beet is grown under commercial contracting arrangements, and this is considered to provide an effective mechanism for controlling the distribution and use of the treated seed. To address the requirement to control use, the applicant proposed a stewardship scheme which includes several measures to address risks to pollinating insects, underpinned by industry commercial contracting arrangements.
- Special circumstances:
The applicant outlined a plan for developing alternative, sustainable approaches to protect crops without the use of neonicotinoid seed treatments. This includes the development of resistant plant varieties, measures to improve seed germination and new practices for growers. The plan is already being delivered. The plan is considered to provide a good basis to confirm that alternative, permanent solutions to neonicotinoid seed treatments for sugar beet are being sought as a matter of priority. The plan anticipates that applications for emergency authorisations for neonicotinoid seed treatments may be needed for three years (2021 to 2023). Any future applications will be fully assessed against the regulatory framework for emergency authorisations.
The authorisation is for the use of Syngenta’s Cruiser SB on sugar beet only and covers use in 2021 in England only. Conditions are attached to the emergency authorisation to ensure that, if the threshold for virus levels is reached and it becomes necessary to treat seeds, use of the product will be limited and controlled and any potential risks to pollinators will be mitigated to an acceptable level. In particular, the application rate of the product will be below the normal commercial rate; no flowering crop is to be planted within 22 months of the sugar beet crop, and no oilseed rape crop is to be planted within 32 months. Industry-recommended herbicide programmes will be followed to limit flowering weeds in and around sugar beet crops. The applicant will be required to limit the sowing rate of treated seeds to achieve no greater than the normal commercial plant population, and to develop and implement their proposed programme to monitor soils and plants following use of the treated seed.
The use of Cruiser SB neonicotinoid seed treatment is subject to the Rothamsted Virus Yellows forecasting model reaching a pre-determined trigger point in February. This model has been used as an indicator for Virus Yellows for over 30 years, providing a robust assessment and prediction of the risk levels.
Further details of a 5-point plan will be released shortly and throughout the growing season to support UK sugar beet growers.