
EPA Seeks Feedback On Efficacy Data Requirement For Insecticides
The Environmental Protection Agency (EPA) is currently welcoming public insights on a petition it has received, which calls for a significant change in the regulation of neonicotinoids and other systemic insecticides. This petition, spearheaded by Public Employees for Environmental Responsibility (PEER), the American Bird Conservancy (ABC), and supported by 63 other signatories, urges the EPA to embark on a rulemaking process for these widely used insecticides.
Published in January 2024. Dates, deadlines and stages may have changed since.
2 min readAI-drafted, expert reviewed

The Environmental Protection Agency (EPA) is currently welcoming public insights on a petition it has received, which calls for a significant change in the regulation of neonicotinoids and other systemic insecticides. This petition, spearheaded by Public Employees for Environmental Responsibility (PEER), the American Bird Conservancy (ABC), and supported by 63 other signatories, urges the EPA to embark on a rulemaking process for these widely used insecticides.
Systemic insecticides, known for their application directly to plants, soil, or as seed treatments, are at the centre of a crucial debate. The petitioners argue that there is a pressing need for comprehensive data on the effectiveness of these insecticides. Such data is vital to determine whether their benefits in pest control justify the potential risks they pose to non-target species and overall biodiversity.
The petition specifically requests amendments to the Federal Insecticide, Rodenticide, and Fungicide Act (FIFRA). It proposes that all applicants and current registrants of neonicotinoid and other systemic insecticides should be required to submit detailed efficacy data to the EPA. This includes both new registration applications and those under review. In particular, the petition targets an amendment to 40 CFR 158.400(e)(1), advocating for the mandatory submission of product performance data for these insecticides. This would apply to new registration applications and for existing registrants, who would need to comply within 180 days of the enactment of the proposed rule.
Furthermore, the petition suggests a stringent approach towards insecticides lacking proven benefits that outweigh their environmental and overall costs. It proposes that the EPA should not only refrain from registering such products but also revoke any existing registrations that fail to demonstrate a favourable benefit-cost ratio.
Comments are due by 24 January 2024.
For more detailed analysis and updates on developments in chemicals legislation, visit our blog, Signal. Our commitment is to provide factual explanations and actionable insights for our readers, helping them stay ahead in a rapidly evolving regulatory environment.

Dr Steven Brennan
CEO and co-founder of Foresight, and a co-opted member of ECHA's Committee for Socio-economic Analysis. He holds a PhD in chemical engineering.
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