Neonic Label Q&A

Q&A: Getting Ready for Changes to Neonicotinoid Labels with Outdoor Foliar Uses

For quick reference we have put together the below Q&A for new labels and their use directions.

"Do not apply [insert name of product] while bees are foraging. Do not apply [insert name of product] to plants that are flowering. Only apply after all flower petals have fallen off."

In this follow-up article, we attempt to address these changes.

What active Ingredients are affected?

imidacloprid, dinotefuran, clothianidin, thiamethoxam

What uses are affected and what is NPMA doing about it?

EPA has said that the new language only applies to products that have "foliar" uses. Foliar generally refers to pesticide applications made to leaves. NPMA is working through SFIREG and ASPCRO, organizations comprised of state pesticide regulators, to obtain a guidance document from EPA, which will address some common questions and provide greater clarity to PMPs using these products, to include:

  1. Clarification that this language does not prohibit or limit indoor, termite or perimeter treatments
  2. That the new "bee box" is only advisory and not mandatory, enforceable label language
  3. What "bees are foraging" means
  4. That the term "bee" refers to honey bees, bumble bees and carpenter bees, but does not include wasps or Africanized honey bees

When will the new labels appear?

Products released for shipment after February 28th must bear the new labeling.

You should start seeing the first updated labels this spring, however since there is no way to know when the new language to protect pollinators will begin arriving on containers from your distributor, it is important to carefully review the label and any associated labeling material each time a new imidacloprid, dinotefuran, clothianidin, thiamethoxam container is opened for use.

In addition, EPA recently informed us that some manufacturers have removed uses from their labels due to the new restrictions. Thus, it is critical that in addition to looking for the new label restrictions, you also need to ensure the Directions for Use still includes the site to which you will be applying the product.

Are any of the labels I use changing?

If the product has outdoor foliar uses on the label; yes, changes will be made to the directions for use. The directions will now read,

Do not apply [insert name of product] while bees are foraging. Do not apply [insert name of product] to plants that are flowering. Only apply after all flower petals have fallen off.

This language will be accompanied by a bee icon in a red diamond to alert you to the label change. The icon should also remind you to consider any foraging bees before choosing the product if there are flowering plants in the area to be treated.

When do I have to start complying with the new labels?

The label is the law. So, as soon as the product container you are using displays the updated language, you are required to comply with the new directions for use.

Can I use neonics for a perimeter treatment?

Yes, you may apply a perimeter treatment using neonics. Before you treat, however, look for flowering plants that could indicate foraging bees may be present. If bees are present, be sure to take steps to minimize exposure of the product to bees and other insect pollinators.

If bees are on the label, is it permissible to still use the product?

As long are you are not treating plants that are flowering while bees are foraging, then yes, it is still permissible to use the product.

Bees are important to my family and me. Are there actions I can take to protect bees beyond what is on the label?

There are lots of things you can do.

What steps do you recommend for my company?

What does science actually say about neonicotinoids and their impact on bees?

EPA and USDA issued a report in 2012 that suggested factors influencing bee health may include "disease, arthropod pests [parasitic mites], pesticides, poor nutrition and beekeeping practices." They identified the varroa mite as "the single most detrimental pest of honey bees and can magnify the role of viruses." Most scientists agree that declining bee health is a result of multiple factors.

A Pollinator Advisory Box was mentioned in the article. Do you know what this will look like?


Protection of Pollinators

Look for the bee hazard icon in the directions for use for each application site for specific use restrictions and instructions to protect bees and other insect pollinators.

This product can kill bees and other insect pollinators.

Bees and other insect pollinators will forage on plants when they flower, shed pollen, or produce nectar. Bees and other insect pollinators can be exposed to this pesticide from:

Direct contact during foliar applications, or contact with residues on plant surfaces after foliar applications

Ingestion of residues in nectar and pollen when the pesticide is applied as a seed treatment, soil, tree injection, as well as foliar applications.

When Using This Product Take Steps To:

  • Minimize exposure of this product to bees and other insect pollinators when they are foraging on pollinator attractive plants around the application site.
  • Minimize drift of this product on to beehives or to off-site pollinator attractive habitat. Drift of this product onto beehives or off-site to pollinator attractive habitat can result in bee kills.
  • Information on protecting bees and other insect pollinators may be found at the Pesticide Environmental Stewardship website.

Pesticide incidents (for example, bee kills) should immediately be reported to the state/tribal lead agency. For contact information for your state, go to: Pesticide incidents should also be reported to the National Pesticide Information Center.