Information Note - PMRA's conclusion on Notice of Objection 2021-3440 for the imidacloprid re-evaluation decision

Health Canada's Pest Management Regulatory Agency
10 January 2025

Table of contents

• About Notices of Objection
• Notice of Objection (2021-3440) for the imidacloprid re-evaluation decision
• PMRA's decision on this Notice of Objection (2021-3440)
• How to request our decision letter

About Notices of Objection

Anyone in Canada may formally object to a major registration, re-evaluation or special review decision for scientific reasons by filing a Notice of Objection within 60 days of the date the decision is published.

When a Notice of Objection is submitted, scientists at Health Canada's Pest Management Regulatory Agency (PMRA) who were not part of the original decision will conduct a thorough scientific review of the objection(s) and supporting reasons provided. The purpose of the review is to determine whether it is necessary to establish an external review panel to examine the decision.

When determining whether an external expert review panel is needed, the following factors are considered:

1. Whether an objection raises scientific doubt about the evaluations of the health or environmental risks of, or the value of the pesticide product; and
2. Whether the advice from expert scientists would help address the objection.

If an expert review panel is established, the review panel may, as part of its role, recommend whether the decision should be:

• confirmed,
• reversed, or
• modified (varied).

All pesticides registered in Canada are re-evaluated every 15 years to make sure that they continue to meet the requirements for protection of human health and the environment and continue to have value. We use a science-based approach that assesses pesticide toxicity and exposure.

As part of our proposed policy on continuous oversight of pesticides, we will continue to regularly monitor new scientific information on pesticides registered in Canada, including publications from international regulatory authorities.

Learn more about:

• Review Panel Regulations
• Pesticide assessments in Canada: Introduction

Notice of Objection (2021-3440) for the imidacloprid re-evaluation decision

Friends of the Earth Canada, the objector, raised objections related to the health assessment we used to make our re-evaluation decision on imidacloprid. The objector submitted evidence to support their objections, including a reference list of 50 studies. The full objection notice, including a list of reference materials, can be accessed in the Pesticide Product Information Database under Application Number 2021-3440.

Our re-evaluation decision on imidacloprid is outlined in the published document titled Re-evaluation Decision for Imidacloprid (RVD2021-05). Supporting information on the pesticide assessment is available in the published document titled Proposed Re-evaluation Decision for Imidacloprid (PRVD2016-20) that underwent a public consultation.

In RVD2021-05, the PMRA concluded that, with additional risk mitigation measures, many uses of imidacloprid products meet current standards for protection of human health and the environment. However, certain uses of imidacloprid were cancelled to address potential risks of concern to the environment.

Learn more about:

• Proposed Re-evaluation Decision for Imidacloprid (PRVD2016-20)
• Re-evaluation Decision RVD2021-05, Imidacloprid and Its Associated End-use Products

PMRA's decision on this Notice of Objection (2021-3440)

Our scientists reviewed the objections raised by Friends of the Earth Canada, including evidence that was submitted in support of the objections, and concluded that:

1. the information provided in this Notice of Objection does not raise scientifically founded doubt about the health risk assessment for imidacloprid or its maximum residue limits (MRLs); and
2. advice from external expert scientists would not help address the objections raised.

Therefore, the PMRA will not set up a review panel for this objection. There is no change to the health risk assessment of the re-evaluation decision for imidacloprid.

Many of the studies provided by the objector are consistent with conclusions addressed in the original decision (RVD2021-05), while the rest did not present a scientific basis to change the conclusions.

How to request our decision letter

Our decision letter to the objector includes technical details and the science review that forms the basis of this regulatory decision.

To request a copy of our decision letter:

1. Visit Health Canada's Public Registry webpage.
2. Click the link to "Pesticide Product Information Database", review the "Disclaimer" page, then click the "Application search" button.
3. Under Filter, select "Application Number", leave the Operator "equal" and in the Value field, type "2021-3440".
4. Click "Search".
5. Click on the application number in the search results.
6. On the Application Details page, scroll down and click on the tab "Published Documents".
7. Click on "Response letter" and follow the prompts to request a copy of this document.

If you have any questions about our decision, please submit questions to Information Services Inquiry - Public Engagement Portal (PEP) (canada.ca).