New Regulatory Requirements for Neonicotinoid Seed Treatments in Quebec

The DEKALB® brand team has been tracking the regulations and supporting information published by the Quebec government. The regulations create a new class of pesticides – Class 3A – for corn and soybean seeds treated with neonicotinoid insecticides (imidacloprid, thiamethoxam and/or clothianidin). The DEKALB brand uses these insecticides on our treated corn and soybean seed.

It is important to know that these new regulations come into force in the period between March 8, 2018 and September 8, 2018 for Class 3A pesticides. We wanted to share with you today is our understanding of the regulations and the impact it has on our business.

To purchase and use neonicotinoid treated corn and soybean seed, an Agronomic Justification and a Prescription prepared and signed by an agronomist are required. The customer is also required to store treated seed appropriately.

Agronomic Justification1, 2

The regulations require the development of an agronomic justification, intended for the farmer, for a field application of the higher‐risk pesticides or for an in‐ground incorporation of Class 3A pesticides. The work on the farm must be carried out in compliance with the conditions listed in the agronomic justification. Without agronomic justification, it is prohibited for the farmer to apply or have these pesticides applied.

It is important to note that an agronomic justification covers one crop per parcel or per group of parcels and must contain the following information:

  • the number of the document;
  • the name, address, telephone number and, where applicable, email address of the farmer who intends to apply the pesticide;
  • where applicable, the name, address and telephone number of the owner of the parcel;
  • the name, address of the professional domicile and, where applicable, email address of the mandated agronomist and the agronomist’s member number in the Ordre des agronomes du Québec;
  • the identification of the parcel in which the work is to be performed;
  • the identification of the phytosanitary problem;
  • an evaluation of the phytosanitary problem;
  • an analysis of the various possible phytosanitary interventions, including alternative pest control methods available;
  • the treatment required;
  • the reasons justifying the choice of the treatment;
  • the name of the active ingredient involved in the treatment and:
  • in the case of Class 3A pesticides, the quantity of seeds required and the plant species concerned;
  • the expiry date of the justification (the validity period of the justification may not exceed one year);
  • the signature of the agronomist and the date.

Agronomic Prescription1, 2

Additionally, for the pesticides covered by the agronomic justification, the agronomist must develop a prescription. Retail sellers may only sell the concerned products if a person authorized for their application provides them with a prescription.

The prescription must be dated and must contain:

  • the number of the agronomic justification;
  • the name, address and telephone number of the farmer;
  • the name and address of the professional domicile of the agronomist who signed it and the agronomist’s member number in the Ordre des agronomes du Québec;
  • the name of the active ingredient involved in the treatment and:
  • in the case of Class 3A pesticides, the quantity of seeds required and the plant species concerned;
  • the expiry date of the prescription. The validity period of the prescription may not exceed the expiry date provided for in the justification.

This means that as of September 8, 2018, you are not permitted to purchase DEKALB Corn or Soybean seed that is treated with neonicotinoid insecticides in Quebec without an agronomic prescription that contains all the information listed above. Customers are required to hold a Subclass E1 (farm producer) or E2 (farmer) certificate or C8 permit. Customers are required to keep an up‐to‐date register of the use of Class 3A pesticides for a period of 5 years.

We know that the regulatory changes are creating some confusion in the marketplace, and we expect that you have many questions. Because we cannot provide legal advice, we encourage you to review the regulations on your own in respect of your own business and all questions should be directed to the Government of Quebec at 1‐800‐561‐1616.

To find your local DEKALB agronomist /_uploads/images/agronomic-info/click-here.jpg

 

Additional Resources:

Overview of Permit and Certificate Regulations (English)
http://www.mddep.gouv.qc.ca/pesticides/permis‐en/

The Pesticides Management Code (English)
http://www.mddelcc.gouv.qc.ca/pesticides/permis‐en/code‐gestion‐en/index.htm

New requirements for pesticide use (in French)
http://www.mddelcc.gouv.qc.ca/pesticides/permis/modif‐reglements2017/index.htm

 

1 http://www.mddelcc.gouv.qc.ca/pesticides/permis/modif‐reglements2017/avis_circulaire_modif_agriculteur.pdf

2 http://www.mddelcc.gouv.qc.ca/pesticides/permis/modif‐reglements2017/justification‐liste‐verification.docx

 

Last updated on: September 27, 2018.

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