EPA issues advisory for substances used to control varroa mites in beehives
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EmailAdvisory from the U.S. Environmental Protection Agency on the applicability of the Federal Insecticide, Fungicide, and Rodenticide Act and Federal Food, Drug and Cosmetic Act for substances used to control varroa mites in beehives.
Language and contents in this article are taken directly from the Advisory on the Applicability of Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and Federal Food, Drug and Cosmetic Act (FFDCA) for Substances Used to Control Varroa Mites in Beehives by the United States Environmental Protection Agency (U.S. EPA).
Advisory on the applicability of FIFRA and FFDCA for substances used to control varroa mites in beehives
The U.S. EPA issued an advisory to clarify what pesticide products and active ingredients are registered under FIFRA to control varroa mites (Varroa destructor) in beehives, what tolerances or exemptions from tolerance under FFDCA are applicable, and how the Agency views use of unregistered products to treat beehives for one’s own personal use. EPA is also affirming that use of registered pesticides must comply with FIFRA labeling requirements, that pesticide residues in honey must comply with any federal tolerances under FFDCA, and that states may have more restrictive requirements that must be followed as well.
It is a violation of FIFRA if a person uses registered pesticides in a manner that is not in accordance with label instructions. Currently, EPA has registered 16 pesticide products, covering about 10 active ingredients, that can be used on beehives to control varroa mites. In registering these pesticides products, EPA has conducted comprehensive evaluations and determined the products will not cause unreasonable adverse effects to human health or the environment when used according to the label. While "one's own personal use" is not defined in federal regulations, using unregistered pesticides could result in a violation of FIFRA. Additional violations could exist if the colony or hive products are distributed and/or sold. Use of unregistered products as a pesticide that do not include label instructions or a designated application rate could also result in residues in the honey or other edible bee products (e.g., honeycomb, pollen). Hive products that are derived from hives where unregistered pesticides are used are not covered by a tolerance or exemption under FFDCA and represent an adulterated product. The sale or distribution of adulterated edible hive products is a violation of FFDCA.
EPA remains committed to supporting the compliance and enforcement efforts by states with primary enforcement authority to ensure compliance with FIFRA requirements.
The advisory addresses the following questions:
- Why is EPA issuing an advisory now?
- What are varroa mites and why are they such a concern for the beekeeping community?
- What does it mean to be a registered pesticide under FIFRA?
- What does it mean to be exempt from the requirements of FIFRA as a “minimum risk pesticide”?
- What does it mean to have a tolerance or tolerance exemption under FFDCA?
- Does an exemption under from the registration requirements under FIFRA automatically mean it is exempted under FFDCA from the requirements for a tolerance, and vice versa?
- Are there pesticides registered under FIFRA that beekeepers can use to control varroa mites in their beehives?
- Are there tolerances or tolerance exemptions set under FFDCA that cover the residues of the pesticide products listed in Table?
- Is it a violation of FIFRA to use a registered pesticide in a manner that is not consistent with its label?
- Is it a violation of FIFRA or FFDCA to sell or distribute food derived from beehives (e.g., honey, comb, wax, propolis, royal jelly, pollen) harvested from beehives treated with unregistered products?
- Is it a violation of FIFRA or FFDCA to sell or distribute the honey or other edible beehive products (e.g., pollen, honeycomb) harvested from beehives treated with unregistered products?
- Are there state pesticide laws that are different from FIFRA that may be applicable?
- What other efforts is EPA engaged in to help beekeepers address the varroa mite issue?
Conclusion
The information in this article is intended to help beekeepers understand the restrictions and requirements regarding pesticide applications in honey bee colonies, such as varroa mite treatments. For the most up-to-date information or for clarification, please refer to the Advisory on the Applicability of FIFRA and FFDCA for Substances used to Control Varroa Mites in Beehives by U.S. EPA.
Resources
- Advisory on the Applicability Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and Federal Food, Drug and Cosmetic Act (FFDCA) for Substances used to Control Varroa Mites in Beehives
- EPA-registered Pesticide Products Approved for Use Against Varroa Mites in Bee Hives
- Honey Bee Health Coalition's Tools for Varroa Management Guide
Acknowledgements
Thank you to the U.S. Environmental Protection Agency (EPA) for providing input on this article. Language and content in this article are taken from the Advisory on the Applicability FIFRA and FFDCA for Substances used to Control Varroa Mites in Beehives by U.S. EPA.
This work is supported by the Crop Protection and Pest Management Program [grant no 2021-70006-35450] from the USDA National Institute of Food and Agriculture. Any opinions, findings, conclusions, or recommendations expressed in this publication are those of the authors and do not necessarily reflect the view of the U.S. Department of Agriculture.
