consumption, and biodiversity losses equalling the slashing and burning of 333,000 hectares of Indonesian rainforest. •  In the EU, additional foliar insecticide applications add Greenhouse Gas (GHG) emissions of estimated 0.03 million tons CO2 equivalents and 1.4 million m3 of additional water use annually FARMERS Farmers who were faced with a ban of one of the most effective tools in their insecticide-toolbox, were forced to switch to other, more costly management solutions. A common approach was to resort to spraying pyrethroids. On average, farmers applied 0.73 additional foliar applications per hectare of cultivated oilseed rape. As highlighted above, such additional foliar insecticide applications lead to an increase of GHG emissions and require significant amounts of additional water. The total increase of production costs at farm level is therefore estimated at € 120 mil- lion. In Aug. 2017, a peer-reviewed article has been published on the impact of the restrictions on neonicotinoid and fipronil insec- ticides on pest management in maize, oilseed rape and sunflower in eight European Union regions. The study found that in certain cases farmers switched to using untreated seeds as no alterna- tive seed treatments were available. Other farmers switched to using unrestricted neonicotinoid- or pyrethroid-treated seeds or increased the use of soil or foliar treatments, with pyrethroids as the principal insecticide class. Other changes in pest manage- ment practices ranged from increased sowing density to more frequent scouting for pests. Many farmers perceived that the time, cost and amount of insecticides required to protect crops increased, along with pest pressure. Alternative seed treatments were mostly perceived as being less effective than the restricted seed treatments. SIMILAR STUDIES Comparison with other studies on the same topic find very similar results. A recent study undertaken by ADAS (UK’s largest independent provider of agricultural and envi- ronmental consultancy) also investigated the impact of the neonicotinoid withdrawal on the EU oil- seed rape (and maize) industries. In contrast to the 2016 HFFA-Study, it only focused on the impact in seven European countries (Austria, Germany, Finland, France, Portugal, Romania, Sweden and the UK), and focused specifically on THE SITUATION IN EUROPE The decision by the European Commission (EC) to restrict the use of three seed-applied neonicotinoids from 2013 onwards triggered different regulatory processes. Now we know that the restricted uses will be re-evaluated in November 2017. Besides that, the European Food Safety Authority (EFSA) pub- lished reports on the foliar use of those three neonicotinoids in July 2015 and confirmatory data reports for the two Bayer neonicotinoids Imidacloprid and Clothianidin in November 2016. The EC is currently reviewing these EFSA reports ready for discussion with the EU Member States. The EC is now proposing a broad ban on these two neonicotinoids by only authorizing their use as insecticides in permanent green- houses where a crop stays there all its life. But these are just proposals. No decision has been taken yet. Why EFSA is wrong Bayer does not agree with the EFSA’s risk assessment for the current uses of Imidacloprid and Clothianidin. Their risk assessment was based on the so-called Bee Guidance Document, which still lacks the legally required approval by EU Member States and has therefore not been adopted. That means it is not applicable for regulatory purposes in the EU! If the Bee Guidance Document would be applied consist- ently, its approach would result in a denial of registration for most pesticides, even those used in organic agriculture! If this came about, the impact on food production for the growing global population would, in my opinion, be really bad. What we say Our position at Bayer is quite clear. Neonicotinoids are safe when used responsibly and in accordance with label instruc- tions. In 20 years of intensive and critical research on neon- icotinoids there hasn’t been a single study that was able to show a negative impact on honey bee colony health when neonicotinoid seed treatment products were tested under realistic field conditions and practical application scenarios. What’s more, the EU’s neonicotinoid restrictions have not led to any measurable improvement in bee health – but have cost European farmers a fortune. A recent study published by HFFA Research, an independent research organization, estimated that the current ban is costing European oilseed rape farmers alone almost €900 million a year! This is just one of the reasons why we at Bayer are arguing against the proposed broad ban on neonicotinoids in Europe!  Martin Gruss, Global Head SeedGrowth at Bayer Division Crop Science EUROPEAN-SEED.COM I EUROPEAN SEED I 19