UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

DEC i 4 20" 

MEMORANDUM 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

SUBJECT: BEAD Chemical Profile for Registration Review: Clothianidin (044309) 

FROM: 

THRU: 

TO: 

David 

Biological 

Brassard, 

Analysis 

Senior 

Branch 

Entomologist Pw ~ 

Rafael 

Science 

Prieto, 

Information 

Environmental 

and Analysis 

Protectio

Branc

n S

h 

pecialist ,IlL 

~ Ltf it ~ 

J I fA. 'p ~ 

Derek Berwald, Economist 

Economic Analysis Branch 

Biological and Economic Analysis Division (7503P) 

Arnet Jones, Chief /.) ~ ~~ Biological Analysis Branch ~U 

Diann Sims, Chief .£J~ Science Information and Analysis Branch 

Timothy Kiely, Chief \ A ~ 

~ ,.. 

Biological and Economic Analy' DiviSiOn~) Economic Analysis Branch V"'--

Russell Wasem, Chemical Review Manager 

Risk Management and Implementation Branch 1 

Pesticide Re-evaluation Division (7508P) 

Product Review Panel date: December 7, 2011 

INTRODUCTION 

The purpose of this document is to convey usage information and a broad overview of the pest 

management roles of pesticides that are beginning to undergo registration review. The 

anticipated audience consists of the team of EP A staff currently evaluating the registration status 

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of clothianidin (044309), and eventually the general public. This document builds upon the data 

already provided in the "Usage and Label Use Data Packages" that are also provided to 

Registration Review teams by BEAD. The document is based on infonnation and data available 

to BEAD as of November 31, 2011. 

Clothianidin is a nicotinoid insecticide which was first registered for use as pesticide in the 

United States in 2003. Nicotinoid insecticides are similar to and modeled after the natural 

nicotine. The nicotinoids act on the central nervous system of insects, causing irreversible 

blockage of the postsynaptic nicotinergic acetylcholine receptors (via a selective agonistic 

mechanism). The primary pests targeted for control with clothianidin include; wirewonn, seed 

maggot, rootwonns (com and western com), cutwonns, grubs, and European com borer. 

USE SITES 

Agricultural Use Sites 

Clothianidin is labeled for use on root and tuber vegetables, bulb vegetables, leafy vegetables 

(brassica and non-brassica), legumes, fruiting vegetables, cucurbits, citrus fruit, pome fruit, stone 

fruit, berries and small fruit, tree nuts, cereal grains, oilseed crops, and other unclassified crops 

(Table 1). 

T a bi e 1 R . t d egis ere U se S·t I es fi or CI 0 tho lam ·d· In b )Y EPA G roup S·t Ie. 

Crop Group Site Crops 

Vegetable, root and tuber, group 01 Ginger, Turmeric, Turnip, Artichoke (Chinese, Jerusalem), Carrot, 

Dasheen, Potato, Sweet potato, Yam, Cassava (bitter, sweet), Arrowroot, 

Tanier, Leren, Chufa, Arracacha, Sugarbeet 

Vegetable, bulb, group 03 Leek, Bulb onion 

Vegetable, leafy, except bras sica, Celery, Radicchio, Com salad, Dandelion, Endive, Fennel, Cress (garden, 

group 04 upland), Parsley, Rhubarb, Spinach, Swiss chard, Lettuce (head, leaf), 

Cardoon, Chinese spinach, Amaranth, New Zealand spinach, Chervil, 

Arugula, Celtuce, Chrysanthemum, Dock, Orach, Purlane (garden, 

winter) 

Vegetable, brassica leafy, group 05 Broccoli, Brussels Sprouts, Cabbage, Cauliflower, Collards, Chinese 

cabbage (celery, napa, bok choy, mizuna), Kale, Kohlrabi, Mustard 

green, Rapeseed greens, Broccoli raab, Chinese broccoli, Chinese 

mustard, Mustard spinach 

Vegetable, legume, group 06 Soybean 

Vegetables, fruiting, group 08 Eggplant, Pepper (sweet, bell, chili, cooking), Tomato, Pepino, 

Tomatillo, Ground cherry 

Vegetable, cucurbit, group 09 Golden pershaw melon, snake melon, pineapple melon, santa claus 

melon, Cantaloupe, Casaba melon, Crenshaw melon, Honey ball melon, 

Honeydew melon, Muskmelon, Watermelon, Chinese waxgourd, Chinese 

cucumber, Cucumber, Pumpkin, Squash (scallop, straight neck, acorn, 

crookneck, summer, hubbard, winter, zucchini, spaghetti, hyotan 

butternut), Citron melon, Bitter melon, Balsam pear, Gourd, Gherkin, 

Mango melon, Chayote 

Fruit, citrus, group 10 Citron, Lemon, Lime 

Fruit, pome, group 11 Apple, Crabapple, Pear, Oriental pear, Quince, Loquat 

Fruit, stone, group 12 Peach 

Berry and small fruit, group 13 Blueberry, Cranberry, Grapes 

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Crop Group Site Crops 

Nut, tree, group 14 Almond, Brazil nut, Cashew, Chestnut, Hazelnut, Filbert, Hickory nut, 

Macadamia nut, Pecan, English Walnut, Butternut, Black walnut, Beech 

nut, Chinquapin 

Grain, cereal, group 15 Com (field, pop, and sweet), Millet (pearl, pro so), Barley, Oat, Rye, 

Wheat, Triticale, Teosinte, Buckwheat, Sorghum 

Oilseed crop, group 20 Canola, Com, Cotton 

No group name, group 99 Strawberry, Fig, Pomegranate, Artichoke (globe), Tobacco 

Non-Agricultural Use Sites 

Clothianidin is used on ornamentals, golf courses, airfields, airports, buildings, domestic 

dwellings, schools, playgrounds, and also on livestock pens and poultry houses. 

COMMON FORMULATIONS AND APPLICATION METHODS 

Clothianidin is formulated as a solid in several forms (granular, dust) and as solution in 

emulsifiable and flowable concentrate, soluble concentrate and as ready-to-use. Clothianidin is 

applied to agricultural crops as a foliar, soil, or seed treatment. 

USAGE 

Agricultural Usage 

Based on private market pesticide usage data from 2004-2010, on average, approximately 

800,000 pounds of clothianidin was applied to 35 million acres per year (Proprietary Data, 2004-

2010). Since clothianidin was registered in 2003 usage has been increasing. Com is the largest 

market for clothianidin, accounting for 99% of the average pounds applied and acres treated 

from 2004-2010. The states with the most agricultural usage in terms of pounds A. I. applied are 

Illinois (16%), Iowa (15%), Nebraska (9%), and Indiana (9%). These states also ranked 

similarly in terms of the total area treated. 

Non-Agricultural Usage 

BEAD reviewed available non-agricultural sources and found information was limited to use of 

clothianidin in golf courses, with 1,000 lbs. AI in 2006. (Kline Studies, Inc., 2006) 

USE TRENDS 

Figure 1 depicts usage trends, in terms of pounds applied, for clothianidin's largest agricultural 

markets. The use of clothianidin increased from 2004 through 2009, with a slight decrease in 

2010 (Fig. 1). There is also a recent but minor increase in sugar beet use and other crops. 

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Figure 1. Usage trends (2004-2010) in tenns of pounds applied for clothianidin main 

agricultural use sites. 

1,400,000 

o 

2004 2005 2006 

2004-2010, Proprietary Data 

2007 2008 

Year 

2009 2010 

o All Other Crops 

. Sugar Beets 

. Corn 

Note: "All other crops" refers to Apples, Cotton, Grapes (Raisin, Table, Wine), Pears, Pecans, 

Potatoes, Sorghum (Milo), Soybeans, Squash, Wheat (Spring, Winter). 

BIOLOGICAL ASPECTS RELEVANT TO CLOTIDANIDIN 

One incident of resistance has been noted for clothianidin in the United States. Mota-Sanchez et 

al (2006) reported resistance and cross resistance to nicotinoid insecticides and spino sad in the 

Colorado potato beetle in Long Island, NY. The lack of additional resistance reports for the 

variety of registered crops indicates that insecticide resistance is not an issue with clothianidin at 

this time 

HISTORY OF BEAD ASSESSMENTS FOR CLOTIDANIDIN 

BEAD has reviewed the use of clothianidin four times in recent years in response to requests for 

a Section 18 emergency exemption. In 2009, BEAD concluded that clothianidin was an effective 

control of the exotic white grub in sweetpotato in North Carolina (Brassard and Ranville, 2009). 

The only other effective chemistry was a soil application of imidacloprid. The 125 day preharvest interval for imidacloprid was longer than the time between sweetpotato planting and 

harvest, making it infeasible. Non-chemical controls have not shown efficacy. Losses to the 

exotic white grub can range from 40 - 95% in the areas where it is a found. 

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In 2008, BEAD reviewed a request for an emergency exemption for use of a clothianidin seed 

treatment against seedcorn maggot, onion maggots, and thrips in· leeks, bulb, and green onions in 

New Jersey (Cook and Faulkner, 2008). These pests had developed resistance against diazinon 

and chlorpyrifos, and resistance was developing in cryomazine. Cultural controls and other 

chemicals have proven to be ineffective against these early season pests. BEAD analysts 

concluded that yield loss in green onions and leeks can be 25 - 30% and yield losses of 10 - 20% 

were likely in bulb onions. For all three crops, BEAD found the situation met the criteria for a 

Section 18 exemption for the use of clothianidin. . 

Also in 2008, California requested use of clothianidin to control seedcorn maggot in onion seed 

in six counties (Kaul and Hill, 2008a). Seedcorn maggot was a relatively recent pest in 

California, causing damage early in the season. For two counties in Northern California, BEAD 

analysts concluded that loss estimates of 28 - 30% were reasonable estimates in the onion 

growing areas of Siskiyou and Modoc counties. On reviewing later evidence submitted by 

California, the conclusion was extended to the Central California counties of Kings, Monterey, 

Santa Clara and Stanislaus, where onion seed may also be grown (Kaul and Hill, 2008b). 

DATA NEEDS RELEVANT TO BEAD'S FUTURE WORK ON CLOTHIANIDIN 

Obtaining additional information on the following items would improve future BEAD 

assessments of the importance of Clothianidin and may be required as part of the registration 

review of this pesticide. 

U sage data associated with clothianidin use on ornamental plants and turf. Requested usage data 

should include use site, application rate, application method, timing of application, acres/area 

treated, and comparative efficacy to registered alternative insecticides. 

REFERENCES 

Brassard, D and M Ranville. 2009. Review of Section 18 Submission from North Carolina for 

an Emergency Exemption for the Use ofClothianidin as a Soil Treatment on Sweetpotato to 

Control the Exotic White Grub, Plectris aliena (09NCOl; DP Number 365058), July 13,2009 

Cook, C and J. Faulkner. 2008. Review of Emergency Exemption Submission to Use 

Clothianidin on Onion and Leeks to Control Seedcorn Maggots, Onion Maggots, and Thrips in 

New Jersey (08NJOl, DP # 350982, Decision # 391 556), September 18,2008. 

Kaul, M. and E. Hill, 2008a. Review of the Emergency Exemption Request of California to 

Use Clothianidin to Control Seed Com Maggot in Onion Seed for Dry Bulb Onion 

Production. DP # 355521, September 10,2008. 

Kaul, M. and E. Hill, 2008b. Supplemental to the Review of the Emergency Exemption 

Request of California to Use Clothianidin to Control Seed Com Maggot in Onion Seed for Dry 

Bulb Onion Production. (08CAI6) (DP # 356636), October 3, 2008. 

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Kline & Co., Inc., 2006. 

Mota-Sanchez, D., Hollingworth, RM, Grafius, EJ, Moyer, DD. (2006). Resistance and crossresistance to neonicotinoid insecticides and spinosad in the Colorado potato beetle, Leptinotarsa 

decemlineata (Say) (Coleoptera: Chrysomelidae). Pest Management Science, 62,30-37. 

Proprietary Data, 1998-2010. 

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