2 of 12

Clothianidin Preliminary Work Plan. Valent also commented on trade irritants and conditionally 

required magnitude of residue studies.

On March 20, 2012, the EPA received an emergency citizen petition (referred to hereafter as 

“emergency petition”) seeking suspension of registration for clothianidin. The emergency petition 

requested action within 90 days. The agency is reviewing the emergency petition and will be 

responding to the petitioners' allegation that clothianidin poses an imminent hazard to pollinators. 

Many of the comments received in the March 20, 2012 petition were also received during the 60 day

comment period. Many of the matters raised in the emergency petition were also received as 

comments during the 60 day comment period on the Preliminary Work Plan (PWP) for the 

Registration Review of Clothianidin. Comments received on the PWP that are duplicated in the 

emergency petition will be posted in the Clothianidin Petition for Emergency Suspension Docket 

(EPA-HQ-OPP-2012-0334) at www.regulations.gov. The responses in this document should not be 

interpreted as the Agency’s final/formal response to the emergency citizen petition.

Below are PRD’s responses to those comments pertaining to policy, process, and benefits. Comments 

regarding the environmental fate or effects of clothianidin have been addressed by the Environmental 

Fate and Effects Division’s (EFED) document, EFED Response to Comments Submitted to the 

Clothianidin Registration Review Docket (dated June 11, 2012). There were no comments pertinent to 

the health effects scoping document on the planned human health risk assessments.

BP & PANNA Campaign Comments:

More than 120,000 commenters requested the agency ban the use of or “cancel the approval” of 

clothianidin. Approximately 120,000 of these ban requests were the result of a letter writing campaign 

organized by Beyond Pesticides. Commenters requesting clothianidin be banned, generally cited 

concern for pollinators as the reason why this compound should be banned, though many several noted 

additional points support their claim that clothianidin should be banned. Specifically mentioned were:

• Clothianidin was registered on the basis of an incomplete data set and should be banned until a 

data set that verifies it does not pose unreasonable risk to human health or the environment is 

produced. 

• EPA has failed to consider all of the available data showing clothianidin is highly toxic to 

honey bees and EPA should suspend the use of clothianidin until this exhaustive review is 

complete.

• Clothianidin is highly toxic to honey bee and the lack of an acceptable field test for pollinators 

study for clothianidin, which was a condition of the original registration, means the registrant 

has not satisfied the conditions that their clothianidin registration was granted on. 

• The existing data set provides enough evidence that clothiainidin cannot be used without 

causing unreasonable adverse effects to pollinators. 

• The risk clothianidin poses to pollinators outweighs the benefits of clothianidin use. 

Agency Response:

The Agency has initiated the registration review of clothianidin pursuant to Section 3(g) of the Federal 

Insecticide, Fungicide, and Rodenticide Act (FIFRA) to determine whether clothianidin continues to 

meet the FIFRA standard for registration. The preliminary work plan (PWP) for clothianidin and the 

supporting Ecological Problem Formulation and Human Health Scoping Document provide a 
3 of 12

background on what the Agency knows and does not know about clothianidin’s effects to human 

health and the environment when it is used as labeled. These documents also provide the Agency’s 

anticipated path towards re-evaluating clothianidin. To further evaluate risks to pollinators and other 

beneficial insects, EPA intends to require data to assess honey bee toxicity. In the development of a 

quantitative risk assessment for pollinators, EPA will consider the recommendations of the Society of 

Environmental Toxicology and Chemistry (SETAC) Workshop on Pesticide Risk Assessment for 

Pollinators, and EPA is working with its federal and state partners, industry, and academia to 

determine appropriate assessment methodology. 

• Clothianidin was registered on the basis of an incomplete data set and should be banned until a 

data set that verifies it does not pose unreasonable risk to human health or the environment is 

produced. 

The regulatory standards for taking currently registrered products off the market are set forth in section 

6 of FIFRA. In connection with our response to the emergency petition, we are evaluating whether 

those standards have been met, including the assertion that EPA should suspend or cancel clothianidin 

based on missing data.

• EPA has failed to consider all of the available data showing clothianidin is highly toxic to 

honey bees and EPA should suspend the use of clothianidin until this exhaustive review is 

complete.

The Agency agrees that clothianidin is highly toxic to honey bees via acute oral and acute contact 

routes of exposure. It is not uncommon that insecticides that are utilized to control or kill insects will 

be toxic to beneficial insects, such as honey bees, and to account for this the Agency has required 

mitigation measures for all clothianidin products that aim to reduce the exposure to beneficial insects. 

The purpose of registration review is to review the current state of the science, use knowledge, and 

effects knowledge and make a determination if the current risk mitigation measures for clothianidin 

continue to meet the FIFRA registration standard. If at any point the Agency concludes that the 

existing mitigation measures required for clothianidin are not sufficient to prevent unreasonable 

adverse affects to human health or the environment, then the Agency will examine all available means 

of mitigating unacceptable risks.

• The existing data set provides enough evidence that clothiainidin cannot be used without 

causing unreasonable adverse effects to pollinators. 

The Agency is assessing these issues in connection with both its review of the March 20, 2012 petition

and registration review. If following these reviews, or if at any other time additional information is 

made available that leads the Agency to conclude that clothianidin use cannot be used without causing 

unreasonable adverse effects to human health or the environment, the Agency will respond 

accordingly. 

• The risk clothianidin poses to pollinators outweighs the benefits of clothianidin use. 
4 of 12

This comment was also raised in the March 20, 2012 petition and response to it will be posted in the 

Clothianidin Petition for Emergency Suspension Docket (EPA-HQ-OPP-2012-0334) at 

www.regulations.gov. 

Comment:

Several commenters noted that use of clothianidin has been banned in several European countries 

noting: “France, Italy, Slovenia, and Germany -- the home of Bayer -- have already banned 

clothianidin. The U.S.A. needs to ban it, too.” (EPA-HQ-OPP-2011-0865-0041 & EPA-HQ-OPP2011-0865-0058)

Response:

The Agency is aware that several European countries have suspended specific uses of clothianidin and 

other neonicotinoid insecticides such as imidacloprid and thiamethoxam. The Agency understands that 

these suspensions are only on the use of neonicotinoid insecticides as seed treatments on crops such as 

corn (maize) and sunflower and that these suspensions are temporary.

The Agency is in regular contact with many of the countries cited by the commenter on the topic of 

pollinator protection and assessing the risks of pesticides to pollinators. The Agency regularly shares 

information on the topic of protecting non-target organisms from exposure to pesticides and always 

welcomes information on other state’s experiences with mitigation measures to better inform 

mitigation measures the Agency considers.

Several European countries have suspended the use of certain neonicotinoid insecticides, including 

clothianidin, in response to incidents involving acute poisoning of honey bees. To EPA's knowledge, 

none of the incidents that led to suspensions have been associated with Colony Collapse Disorder. The 

following are the countries in which pesticides have been suspended, the pesticides in question, and the 

current registration status for the pesticide:

France - Sunflower and corn seed treatments of the active ingredient imidacloprid are suspended in 

France; other imidacloprid seed treatments, such as for sugar beets and cereals, are allowed, as are 

foliar uses.

Germany - The use of a number of seed treatment pesticides was temporarily suspended following 

an incident in May 2008 in which many bees were inadvertently poisoned. However, after 

investigating the factors contributing to the situation, Germany lifted the suspensions with the 

exception of the neonicotinoid clothianidin, which remains suspended as a seed treatment for corn.

Italy - Clothianidin seed treatment uses on corn were suspended temporarily, and this temporary 

suspension is scheduled to expire on June 30, 2012. The Agency is not aware of foliar uses of 

clothianidin being suspended in Italy. This action was taken based on preliminary monitoring studies 

in northern and southern regions of Italy showing that bee losses were correlated with the application 

of seeds treated with these neonicotinoid compounds; Italy also based its decision on the known acute 

toxicity of neonicotinoid compounds to pollinators.

Slovenia - Neonicotinoid seed treatments for maize and oil seed rape (canola) were temporarily

suspended. The suspension was based on poor seed treatment methods resulting in release of dust 
5 of 12

during the seed sowing process. In August 2008, the suspension for oil seed rape seed treatments was 

lifted due to improved seed treatment methods and seed sowing equipment.

Comment:

“No major independent study has verified the safety of Clothianidin. However independent studies 

have shown that neonicotinoid pesticides like clothianidin are highly toxic to honey bees, providing 

compelling evidence that they should be immediately taken off the market until the E.P.A. can conduct 

a full and valid scientific review.” (EPA-HQ-OPP-2011-0865-0080, EPA-HQ-OPP-2011-0865-0041, 

and EPA-HQ-OPP-2011-0865-0143)

Response:

The Agency agrees that clothianidin is highly toxic to honey bees. It is common for insecticides, such 

as clothianidin, to be highly toxic to beneficial insects such as honey bees. The Agency has imposed

mitigation measures on the labels of registered clothianidin products and other insecticides to address

the risk clothianidin poses to humans and the environment, including risks to bees. In connection with 

both its review of the emergency petition and registration review, EPA will determine whether there is 

a need to impose further limitations on use to ensure that clothianidin meets the requirements of 

FIFRA. 

Comment:

“Shockingly, no major independent study has verified the safety of this pesticide. While clothianidin 

has been used on corn — the largest crop in the U.S. — since 2003, it was officially approved by the 

Environmental Protection Agency in 2010 on the basis of a single study, conducted by Bayer. 

However, leaked documents show that the study was actually debunked by the agency's own scientists, 

so the pesticide was effectively approved with no scientific backing.” EPA-HQ-OPP-2011-0865-0143 

and EPA-HQ-OPP-2011-0865-0041

Response:

The Agency disagrees that the registration of clothianidin relied on a single study. The Agency’s 

decision to grant or deny a registration is not based on the results of any single study, but instead the 

collection of data presented in the studies combined with other information. The other information can 

cover a variety of topics including but not limited to economic information (such as the economic 

benefit use of said pesticide can provide specific crops) and information on alternatives (such as is this 

pesticide an environmentally preferable substitute to pesticides used on the same pests). 

BP Comment: 

Beyond Pesticides and others pointed out to the agency in December 2010 that at the time of 

conditional registration, the agency was aware that clothianidin posed a threat to honey bees and other 

pollinators, yet went forward with authorizing its use in the wider environment, without the “required” 

honey bee data to support registration. The agency in response argued that “the uses met the Federal 

Insecticide, Rodenticide and Fungicide Act (FIFRA) risk/benefit standard for registration.” In this 

letter the agency stated, “the 2003 conditional registration of clothianidin was granted based on.... the 

submission of a field test for pollinators.” The letter goes on to state that this study was reclassified as 

a supplemental study, i.e. “a study that provides scientifically sound information, but did not follow all 

protocols set forth in EPA test guideline.” At the point of this reclassification, the study was no longer 

acceptable to support registration. The reclassification is troubling given that clothianidin was already 
6 of 12

granted conditional registration by this time, after the agency acknowledged that clothianidin posed a 

threat to bees and took no action. (EPA-HQ-OPP-2011-0865-0104)

Response:

The Agency will respond to requests to suspend clothianidin in its response to Emergency Citizen 

Petition to the United States Environmental Protection Agency Seeking Suspension of Registration for 

Clothianidin, dated March 20, 2012, in docket number EPA-HQ-OPP-2012-0334 at 

www.regulations.gov for a response to this comment.

National Honey Bee Advisory Board (NHBAB) Comment:

“The National Honey Bee Advisory Board (NHBAB) has reviewed EPA’s risk assessment documents 

for clothianidin. The “conditional registration” for clothianidin recognized this product as a potential 

problem for pollinators. An important component of that conditional approval was a requirement for a 

pollinator field study. We can find no documentation that an “acceptable” field test for pollinators has 

been listed by EPA risk assessors. We are unclear how a product can transition from conditional 

registration to full registration if all requirements are not met. FIFRA mandates EPA to “prevent 

unreasonable risk to the environment”. EPA must reconsider all registrations of clothianidin until an 

acceptable field study for pollinators has been approved. We are particularly concerned about foliar 

applications of clothianidin on blooming crops. California recently enacted restrictions on this use on 

blooming cotton. We request EPA to suspend this method of application until further studies confirm

safety for pollinators.” EPA-HQ-OPP-2011-0865-0074

Response:

The Agency will respond to requests to suspend clothianidin in its response to Emergency Citizen 

Petition to the United States Environmental Protection Agency Seeking Suspension of Registration for 

Clothianidin, dated March 20, 2012, in docket number EPA-HQ-OPP-2012-0334 at 

www.regulations.gov for a response to this comment.

Steve Ellis, Old Mill Honey Co. Comment:

“Another subject of great concern to beekeepers is the allowed higher rate use for homeowners, and 

landscaping and nursery businesses. This rate is sometimes as high as 40 times the allowable rate of 

agriculture. At this high rate, and with NO BEE CAUTION on their labels, these products are used on 

lawns, flowers and fruit trees. These areas may be smaller patches, but it is creating lethal dose 

exposure to pollinators. This practice must be halted immediately.” (EPA-HQ-OPP-2011-0865-0123)

Response:

This comment was also raised in the March 20, 2012 petition and response to it will be posted in the 

Clothianidin Petition for Emergency Suspension Docket (EPA-HQ-OPP-2012-0334) at 

www.regulations.gov. 

Rachel Carson Council Comment:

“The continuing adverse impact of Colony Collapse Disorder and the association of neonicotinoids 

with honey bee population declines worldwide require the Agency to curtail availability of this 

neonicotinoid insecticide which also has been flagged for lacking adequate data to support its 

registration.” (EPA-HQ-OPP-2011-0865-0051)
7 of 12

Response:

The regulatory standards for taking currently registrered products off the market are set forth in section 

6 of FIFRA. In connection with our response to the emergency petition, we are evaluating whether 

those standards have been met, including the assertion that EPA should suspend or cancel clothianidin 

based on missing data.

Valent Comment: 

“We respectfully request and encourage the EPA to harmonize data requirements with California 

Department of Pesticide Regulation (CDPR) and Health Canada’s Pest Management Regulatory 

Agency (PMRA). Valent has received requests for data addressing risk to honeybees from DPR, 

PMRA and EPA. In order to avoid duplicative or contradictory testing requirements which could 

further cloud rather than illuminate the factors affecting pollinator health, we urge further cooperation 

and harmonization based on the best principles of risk assessment.” (EPA-HQ-OPP-2011-0865-0070)

Response:

The Agency is working with the CDPR and Health Canada’s PMRA to ensure that the necessary data 

will be available for assessing risk to insect pollinators by the time of registration review. It is the 

Agency’s intention to avoid requesting data that is duplicative, contradictory, or otherwise unduly 

burdensome.

Valent Comment: 

Valent alerted the Agency to several discrepancies on the tolerances listed for several commodities in 

Canada and one commodity in the US listed in the Clothianidin Human Health Assessment Scoping 

Document in Support of Registration Review, dated December 8, 2011. Valent also highlighted several 

of the tolerance disparities noted by the Agency in this document. (EPA-HQ-OPP-2011-0865-0070)

Response:

The Agency appreciates Valent bringing these discrepancies to its attention and as stated in the PWP 

the Agency will modify tolerance levels as needed, and work to harmonize tolerances/maximum 

residue limits (MRL), where possible, in key export markets during registration review.

Valent Comment: 

Valent noted that since the publication of the PWP in December, it had submitted side-by-side residue 

trials for leaf lettuce, non-bell peppers, and cabbage. In the PWP these studies were listed as data gaps 

that were to be required through data call-in to support the registration review of clothianidin. 

Valent also requested the Agency consider waiving the side-by-side residue trials for mustard greens 

due to there being adequate comparison data. (EPA-HQ-OPP-2011-0865-0070)

Response:

This data will be reviewed and incorporated into future risk assessments as appropriate. Review of this 

data will also allow the Agency to determine whether an additional comparison study on mustard 

greens is needed.

Bayer CropScience (BCS) and Valent Comment:
8 of 12

Both Valent and BCS submitted edits regarding Appendix A, Maximum Labeled Application Rates for 

Clothianidin. (EPA-HQ-OPP-2011-0865-0070 and EPA-HQ-OPP-2011-0865-0069)

Response: 

The Agency acknowledges the receipt of this information. 

FESTF Comment: 

The FIFRA Endangered Species Task Force (FESTF) submitted a comment requesting that any 

technical registrant for clothianidin who is not a member of the FESTF (or a company having met its 

data compensation obligations) be asked to provide a formal offer-to-pay to FESTF for reliance on 

their data. (EPA-HQ-OPP-2011-0865-0066)

Response: 

The Agency thanks FESTF for its comment and will consider it as it conducts the registration review 

of clothianidin.

Comments on the agricultural benefits of clothianidin: 

Various individuals from research universities (Mississippi State Agricultural Extension and 

University of Tennessee Agricultural Extension), and the pesticide industry (Florida Fruit & Vegetable 

Association) commented in support of the continued registration of clothianidin. They state that 

clothianidin is an effective and safe insecticide for managing yield-robbing insects in many crops. 

Clothianidin use is beneficial for a number of reasons: a) clothianidin seed treatments results in less 

exposure to birds and other wildlife because clothianidin is buried with the seed under the soil surface, 

b) clothianidin’s toxicity profile and low application rates minimize impact on human health and the 

environment, c) clothianidin use reduces the environmental load of other organophosphate, carbamate, 

and pyrethroid pesticides, d) application of clothianidin on the seed allows for direct targeting of pests, 

e) clothianidin use increases agricultural yields, and f) the benefits of seed treatments, with pesticides 

such as clothianidin, offer time savings and convenience to growers. Neonicotinoid alternatives to 

clothianidin include imidacloprid and thiamethoxam (of which clothianidin is a major degradate of). 

Imidacloprid requires higher application rates and does not provide the same level of control as 

clothianidin for some pests; similarly, thiamethoxam does not control the same broad range of pests. 

Response: 

The Agency acknowledges the receipt of this information and will consider all the benefits of 

clothianidin use for growers when it conducts its risk benefits analysis for registration review. 

Comments on the general benefits of clothianidin as a seed treatment: 

Various growers and other stakeholders (including Burros Bros Seed Company and Auburn 

University’s Horticulture Extension Program) commented in support of the continued registration of 

clothianidin seed treatments, stating that using clothianidin seed treatments in place of other pesticide 

formulations was preferable for several reasons: a) the convenience —of using a systemic insecticide 

seed treatment, b) reduced occupational exposure since there is less dust and human contact with 

treated seeds, eliminating the need for handling bags of dry or liquid insecticide, c) some planters are 

not equipped to apply dry or liquid insecticide and using seed treatments eliminate this issue, d) the 

low use rate per acre associated with seed treatments, which results in more cost savings, e) its high 

efficacy against a broad range of insects, f) reduced environmental exposure compared to other 
9 of 12

pesticide formulations--the total amount of clothianidin seed treatment applied to one acre of field corn 

can be up to 50 times less than for an organophosphate granular insecticide, and g) the reduced need 

for use of more harmful granular and foliar pesticides by using seed treatments—before the availability 

of seed treatments, growers had to broadcast granular insecticides like terbufos and chlorpyrifos 

(Lorsban®) onto crops; these compounds were more dangerous and were known for killing most 

insects in the field and disrupting the ecosystem. 

 

Response: 

The Agency acknowledges the receipt of this information and will consider all the benefits of 

clothianidin use for growers when it conducts its risk benefits analysis for registration review. 

Comments on clothianidin use on sugar beets: 

Growers and other representatives of the sugar beet industry (The Beet Sugar Development 

Foundation, The American Society of Sugar Beet Technologists, Wyoming Sugar Growers, The 

American Crystal Sugar Company, and The Western Sugar Cooperative) commented in support of the 

continued registration of clothianidin and highlighted clothianidin’s importance to the sugar beet 

industry in the United States. Clothianidin is a valuable tool in the sugar beet industry for treating 

pests like leaf miners, springtail insects, loopers, sugar beet leafhoppers, and other below ground 

insects such as root maggots and wireworms. The sugar beet leafhopper in particular is a vector for 

curly top virus, which often afflicts many growers and has reduced crop yields in the past, even when 

the sugar beet varieties grown were engineered to be resistant to the disease. Clothianidin, in 

comparison with other pesticides, allows for better control of the leafhopper and has replaced more 

harmful planting-time organophosphate and carbamate pesticides, which have been known to kill 

wildlife. Moreover, clothianidin is particularly important because some of the pesticide alternatives

used in the past have been taken off the market and are no longer available. Without the ability to treat 

curly top virus, sugar beet growers may see a 60-70% crop loss. Clothianidin has had a positive effect 

on the sugar beet industry in Idaho, Washington, and Oregon, where curly top disease is prevalent but 

use of clothianidin has resulted in consistently increased crop yields. Moreover, sugar beets grown for 

sugar production do not flower and so do not provide foraging for bees. Losing the ability to use 

clothianidin would result in a large financial loss to the sugar beet industry. Growers raised concerns 

that without the use of clothianidin it might not be profitable to grow sugar beets anymore, which 

would close factories and force farmers out of business. 

USDA reinforced earlier points made by other growers, commenting that research conducted at 

different levels of host resistance and disease pressure indicate that clothianidin use could lead to a 

20% increase in sugar beet root yield when applied as a seed treatment. Recent research indicates that 

even under strong curly top disease pressure, seed treatment with clothianidin can provide excellent 

protection and lead to 55-95% increased sugar beet root yield. Clothianidin has been shown to control 

other pests such as leaf miner, black bean aphid, and root aphid. Because of this wide range of pest 

control, clothianidin can increase yields by 3-8% even without curly top disease pressure. 

Response: 

The Agency acknowledges the receipt of this information and will consider all the benefits of 

clothianidin use for growers when it conducts its risk benefits analysis for registration review. 

Comment on the success of clothianidin use against the annual bluegrass weevil: 
10 of 12

One researcher (EPA-HQ-OPP-2011-0865-0021) commented on the instrumental use of clothianidin in 

controlling pests on golf courses. The annual bluegrass weevil is a serious pest on East Coast golf 

courses; both the adult and larvae feed on the annual bluegrass, which is a major component of turf 

grass. A combination of clothianidin and bifenthrin is widely and effectively used to control this pest. 

Two applications of clothianidin coformulated with bifenthrin are sufficient for season-long control, 

even on golf courses with bifenthrin resistance, whereas alternative pesticides require 4-6 applications 

to achieve control. The control achieved with clothianidin is better than with any other product on the 

market. Clothianidin is also effective against a broad spectrum of other golf course pests such as 

cutworms, grubs, billbugs, sod web worms, mole crickets, and army worms. 

Response: 

The Agency acknowledges the receipt of this information and will consider all the benefits of 

clothianidin use for growers when it conducts its risk benefits analysis for registration review. 

Comments on clothianidin use on field corn: 

Stakeholders from the corn industry, including Iowa Corn, The National Corn Growers Association 

(NCGA), Minnesota Corn Growers, and Illinois Corn Growers commented in support of the continued 

registration of clothianidin. In addition, state extension programs at Auburn University, Mississippi 

State University, and University of Tennessee provided similar comment. They stated that clothianidin 

is an integral component of early-season pest control (for pests like billbugs, stinkbugs, and sugarcane 

beetles) and soil insect management (for pests such as wireworms, black cutworms, and white grubs)

in field corn, citing various benefits like reduced handling, reduced occupational exposure, lower 

environmental risks, convenience to growers, high efficacy, precise application, and increased yields in 

comparison with alternate pesticides on the market. 

Illinois Corn Growers stated that clothianidin is used on approximately 60% of the corn in Illinois and 

produces a 6 bushel per acre average yield increase which at current corn prices could result in an 

increased profit of $280 million dollars for the state of Illinois. Discontinuing clothianidin’s 

registration would result in a negative economic impact.

In general, commenters were concerned about colony collapse disorder and its potential impact on the 

larger agricultural economy, but stated that corn growers can use best management practices to 

minimize exposure to bees. Although clothianidin has been implicated with the recent decline in bee 

populations in the US, studies suggest that there are multiple and complex causes of colony collapse 

disorder. Corn farmers believe that the current science does not support discontinuing clothianidin’s 

registration. 

Response: 

The Agency acknowledges the receipt of this information and will consider all the benefits of 

clothianidin use for growers when it conducts its risk benefits analysis for registration review. 

Comments on clothianidin use on cotton: 

Various stakeholders from the cotton industry (the Cotton Council, Plains Cotton Growers, the Georgia 

Cotton Commission, Southern Cotton Growers, the Plains Cotton Cooperative, the California Cotton 

Ginner and Growers Association, the South Texas Cotton and Grain Association, and Florida Fruit & 

Vegetables) commented in support of the continued registration of clothianidin. They state that 
11 of 12

clothianidin is an important component of cotton production because it helps control several 

piercing/sucking insect pests such as thrips, aphids, plant bugs, and the pesky Lygus bug (the most 

destructive cotton pest in California). Alternatives to the neonicotinoids are limited to pesticides like 

aldicarb, which has limited availability, and dicrotophos, which has annual rate restrictions. Growers 

have observed increased insect resistance with alternative pesticides and prefer neonicotinoid 

pesticides like clothianidin because they are able to move into the sap of plant parts and provide 

enhanced protection from cotton pests. In addition to its effectiveness against a broad range of pests, 

clothianidin use is convenient for growers because it allows precise and targeted application to crops. 

Response: 

The Agency acknowledges the receipt of this information and will consider all the benefits of 

clothianidin use for growers when it conducts its risk benefits analysis for registration review. 

Comments on clothianidin use on rice: 

The California Rice Commission submitted comments in support of the continued registration of 

clothianidin, stating that although clothianidin is not currently registered for use on rice, rice farmers 

could benefit from use of a systemic seed treatment insecticide like clothianidin to control pests like 

aster leafhoppers, army worms, rice seed midges, rice water weevils, and other pests. The rice water 

weevil in particular feeds on the leaf tissue and the roots of rice, inflicting heavy damage that result in 

grain losses of up to 44%. Pesticides currently used to control the rice water weevil include 

dinotefuran, lambda cyhalothrin, and s-cypermethrin, but these only target the adult weevils and can’t 

control the larvae. Clothianidin, as a systemic pesticide, is able to control both adult and larvae stages 

of pests. 

Response: 

The Agency acknowledges the receipt of this information. The Agency is currently reviewing an 

application for clothianidin use on rice (seed and foliar uses) and if this use is registered, the Agency 

will consider clothianidin use on rice during registration review.

Comments on clothianidin use on canola:

Stakeholders from the canola industry (the US Canola Association, the Northern Canola Growers 

Association, the Minnesota Canola Council, and the Great Plains Canola Association) commented in 

support of the continued registration of clothianidin, citing its various benefits to canola producers. US 

canola producers have turned to seed treatments like clothianidin to control insects and disease because 

of their effective control of pests, lower environmental and occupational exposure, lower application 

costs, and added convenience. Loss of clothianidin use on canola would require producers to increase 

use of foliar applications of other more harmful pesticides to control insects such as flea beetles, 

aphids, and wireworms, thereby increasing the risk to other beneficial insects, reducing efficiency, 

lowering profits, and impairing an already well-established pest management program in canola 

producing areas. Clothianidin is a very important tool for canola growers in North Dakota, which 

produces about 90% of the canola in the US. Canola producers in North Dakota are beleaguered by 

the crucifer flea beetle, which can devastate seedlings and destroy a crop if not controlled. Seed 

treatments like clothianidin are the best option for controlling the crucifer flea beetle due to their high 

efficacy and affordability. 

Response: 
12 of 12

The Agency acknowledges the receipt of this information and will consider all the benefits of 

clothianidin use for growers when it conducts its risk benefits analysis for registration review. 

Comments on clothianidin use on soybeans:

Various stakeholders from the soybean industry (Nebraska Soybean Association, Illinois Soybean 

Association, and Minnesota Soybean Growers Association) commented in support of the continued 

registration of clothianidin, citing the convenience of its seed treatment use, high efficacy against a 

broad range of pests (including nematodes), precision, reduced environmental and occupational 

exposure, higher yields, and the reduced need for early-season sprays and other in-furrow and foliar 

sprays. 

Response:

The Agency acknowledges the receipt of this information and will consider all the benefits of 

clothianidin use for growers when it conducts its risk benefits analysis for registration review. 

Comments on clothianidin and wheat:

The Washington Grain Alliance and other wheat growers submitted comments in support of the 

continued registration of clothianidin. With the loss of lindane, wheat farmers in Washington have 

seen a rise in wireworms, which cause lots of damage to wheat. Research shows that Poncho 

(clothianidin) is superior to Gaucho (imidacloprid) or Cruiser (thiamethoxam) for control of 

wireworms. If clothianidin registrations are cancelled there will be no replacement for it in the market

and farmers will be forced to use higher rates of less effective chemicals to control wireworms. 

Response:

The Agency acknowledges the receipt of this information and will consider all the benefits of 

clothianidin use for growers when it conducts its risk benefits analysis for registration review.