Written evidence submitted by Natural England (INS0037)

UK Parliamentary Science & Technology Select Committee

Call for Evidence on Insect Declines and Food Security

Natural England is the Government’s statutory adviser on the natural environment established under the Natural Environment and Rural Communities Act 2006. Natural England’s purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Executive summary

• The evidence base for insect abundance has changed little since the 2020 review (UK Parliament 2020), although recent evidence confirms declining abundance in well-studied groups.
• The critical ecosystem function role played by insects (and other invertebrates), as pollinators and wildlife food resource, in farming systems, is well recognised. The UK has a comprehensive process for pesticide authorisation. Whilst pesticide direct effects are routinely evaluated in this process, indirect or longer-term sub lethal effect, on a range of non-target species, are less explicitly and consistently covered (Milner and Boyd 2017). The role that pesticides might play in large scale reductions in insect populations is not clear. There remains limited evidence on the current use and non-target, direct, indirect and sub-lethal effects of Plant Protection Products (PPP) e.g., on soil faunas and function, or of anti-parasitic veterinary medicines.
• Widescale biodiversity initiatives, aimed at addressing insect decline (amongst other biodiversity) are insufficient. Protected sites, notably SSSIs, benefit pollinators but they are limited in area and often in unsatisfactory condition. Insect species continue to be lost from protected as well as unprotected sites. The recent ‘LandSpAES’ study of agri-environment options, provisionally shows that while agri-environment schemes have a role to play in halting insect decline, enhancing the quality of uncultivated habitats and plant diversity within farmed landscapes, remains vital.
• There are a range of existing environmental land management options within agri-environment schemes which provide support for pollinators.  Defra’s environmental land management schemes present an opportunity to build on the experiences and lessons learned from these current schemes.  

Response

1. The current evidence base for insect abundance in the UK, and the gaps in scientific understanding that require further research.

The ‘UK Insect decline and extinctions’ POSTnote (UK Parliament, March 2020) summarised the scientific evidence for insect declines in the UK, the drivers of trends, and interventions to support the recovery of insect populations. Overall declines, in abundance and / or distribution were evident in the most well studied insects: bees and hoverflies (Carvalheiro et al., 2013), butterflies (Butterfly Conservation, 2018), moths (Conrad et al, 2006), and ground beetles (Brooks et al., 2012). Only aquatic insects showed a recovery, since the 1990s (Outhwaite et al., 2020). Multiple drivers of insect decline were identified, operating over different temporal and spatial scales, and on different taxa: habitat loss, fragmentation and degradation; urbanisation; land-use intensification; and pesticides, fertilizers and veterinary medicines. Climate change was exerting both positive and negative effects on insect distribution and abundance. Interventions to support insect recovery were aimed at reducing or reversing the impacts of the drivers, such as habitat restoration and creation.

The main sources of direct abundance data, where terrestrial insects are systematically counted, are still largely confined to established, long-term monitoring schemes e.g., aphids and larger moths (Rothamsted Insect Survey), and butterflies (UK Butterfly Monitoring Scheme). More recent schemes are also contributing systematic abundance data e.g., for bumblebees (Bumblebee Conservation Trust) and wider pollinating insects (UK Pollinator Monitoring Scheme).

For evidence appearing after 2020, the long-term decline in overall butterfly abundance (1976-2019) has been confirmed, with habitat specialists declining by 27% compared to 17% for generalists. These declines have moderated slightly, compared to a 2015 assessment, except for habitat specialists (Fox et al. 2023). However, recent 10-year population reductions in the abundance of individual species means that 24 are now assessed as threatened, compared to 19 in 2011 (Fox et al., 2022).

The overall abundance of larger moths has also declined long-term (1968-2017) by 33%, being greater in the south (39%) than the north of Britain (22%), but showing a northern decline for the first time (Fox et al., 2021).

The DRUID project (Natural Environment Research Council funded, 2021 to Dec 2024) is ongoing and should be able to address many of the questions in the current Call for Evidence, for both terrestrial and freshwater insects. It aims to: provide definitive evidence around the scale and extent of UK insect declines; understand the key drivers; and to support the development of policies to reverse them.

Similarly, ‘Insect declines and why they matter’, commissioned by the South West Wildlife Trusts (Goulson, 2019) contains evidence synthesis and recommendations for both terrestrial and freshwater insects.

The ‘Bugs Matter Citizen Science Survey’ (Ball et al, 2021) describes large declines in insect abundance between 2004 and 2021. This innovative, citizen science survey recorded insects squashed on car number plates.

The state of freshwater insects has not been explicitly covered in this submission. However, the current scale of cumulative impacts, caused by river pollution incidents, chronic sources of pollution e.g., pesticide, nutrient and sediment run-off, and pressures on river volumes (both human and climate mediated) suggests that the health of aquatic systems is declining. The citizen science work carried out by anglers and others under the Riverflies.org framework, using standardised riverfly assessments, is a valuable development.

2. The effects of pesticides, such as neonicotinoids or other agricultural control methods on insects including pollinators and their impact on UK food security.

Between 75% and 80% of UK crops are estimated to require pollination by insects. In the UK, pollinated crops are worth over £690 million each year and this service has an estimated value of £1.8 billion (NBDC, 2021). The economic contribution of pollination by wild bees (which pollinate between 85-95% of the UK’s insect pollinated crops) has been assessed as around £1,800 per hectare. While it is difficult to separate the role of pesticides from other factors operating on farmland, the replacement of organophosphorus and carbamate insecticides with pyrethroids and neonicitinoids from the 1990s to the 2010's has reduced toxicity to mammals and birds, while specific toxicity to invertebrates has increased; and the area of land in the UK treated with pesticides nearly doubled from 45 to 80 million hectares (Goulson et al. 2018, 2019, Schulz et al, 2021. For example,  neonicotinoid seed treatment on oilseed rape increased from 37% to 83% between 2002 and 2011. The distributions of wild bees that foraged on oilseed rape were substantially affected by neonicotinoid use, compared to species not foraging on the crop (Woodcock et al., 2016).

Neonicotinoids also accounted for 92% of the increase in invertebrate toxicity loading in agricultural environments (DiBartolomeis et al., 2019). Sixty per cent of neonicotinoid application in 2011 was through seed treatments and soil application; 80% or more of the active ingredients remain in the soil.

Indirect effects are incompletely addressed during the pesticide approval process. Within-year effects on non-target arthropods are assessed and some mitigation (e.g., buffer zones to minimise drift on to non-crop habitats) may be included, but, for example the relevance of pesticide use on food availability to farmland birds is still not fully considered.  The risk assessment process does not always predict all potential impacts or reflect the most up to date science (Kessler at al, 2015). In the case of neonicotinoids, the risk assessment guidance did not fully cover risk of long-term exposure (chronic toxicity), risk at different life stages (adult and larvae) and risk to bumble bees and solitary bees (EFSA 2012). It was new scientific studies outside of the risk assessment process that alerted the EU regulatory community to the environmental risk being posed by these new products and ultimately informed the restriction on use and a review of the guidance to better assess these risks (EFSA 2018).

Specific data on the in-field effects of combinations and multiple applications of pesticides are lacking; as are comprehensive data on the presence and loads of pesticides in the environment.

The hazard posed by agrochemicals (e.g. Plant protection products and veterinary medicines) are understood. There remains, however, limited evidence on the current use and infield direct, indirect and sublethal effects and impact of these substances e.g., on soil faunas and function, or of anti-parasitic veterinary medicines.

Natural England is exploring the efficacy of Integrated Pest Management (IPM) as an agricultural control method, through its IPM and Biodiversity Enhancement study (pending publication; Annex 1). Provisional findings indicate evidence of both positive and negative impacts of IPM practices on insect (arthropod) abundance. However, the evidence is patchy e.g., often just one species in a study. Declines in the abundance of invertebrates preying upon insect pests, in IPM were related to increases in pesticide use (GWCT, 2023).

The role of veterinary medicines as an agricultural control method, both in lowland and upland livestock farming has not been explicitly covered in this submission. However, anti-parasitic products e.g., anti-helmintics, which act in a similar manner as pesticides on non-target organisms e.g., dung beetles, may be having impacts on insect biodiversity and ecosystem services. Just as for pesticides, there is currently a lack of terrestrial and aquatic monitoring to adequately assess the level of impacts of veterinary medicines on insects.

3. The extent that biodiversity initiatives, such as creating reservoir populations, are addressing insect decline and whether there is sufficient co-ordination with the UK food system.

Populations of insects, especially scarce and threatened species, are now mainly concentrated in areas of ecologically intact, semi-natural habitat. Cooke et al. (2023) found that, for a suite of 1238 invertebrates, including pollinators and predators (ants, bees, hoverflies, ladybirds, spiders and wasps), protected areas supported 15% more species than unprotected ones; and nearly double the number of rarer species. However, over the period 1990 to 2018, species were lost from all sites, with losses of rarer species being balanced by gains on protected sites. Over this period, commoner insect species declined more steeply on protected sites than elsewhere, though this was not the case for pollinators which generally fared better within protected sites. The evidence indicates that our most important reservoirs (protected sites) are currently failing to prevent declines of commoner and rare insects.

In agri-environment schemes, the Natural England-funded (and soon to be published) UK-CEH (Centre for Ecology & Hydrology) / British Trust for Ornithology ‘Landscape-scale species monitoring of agri-environment schemes’ (LandSpAES) project (LM0465) explored how mobile insect taxa responded to gradients in the quantity of beneficial scheme options at local (1km2) and landscape scales (9km2). Provisional findings show variable responses by insects to option gradients, when instead factors related to habitat or plant diversity were often also important: butterfly abundance strongly benefited from options at the wider scale; wild bees overall were unaffected by options. However, the abundances of late emerging bumblebees, and of moths, profited from local options, when options in the wider landscape were scarce. Moth species richness benefitted from options locally, in the lowlands. Hoverflies were unaffected by options. These results indicate that while agri-environment schemes have a role to play in halting insect decline, enhancing and conserving the quality of uncultivated habitats and plant diversity within agricultural landscapes remains vital. We have 30 years of evidence regarding the effectiveness of agri-environment schemes; whilst offering many benefits the declining health of insect populations is evident as described above.  It is too early to assess whether new measures under the latest Environmental Land Management Schemes will prove more effective in halting these declines

The Defra / EU funded Game & Wildlife Conservation Trust project LM0471 (Niamh et al., 2021), addressed local insect reservoirs in farmland by looking at beneficial insects in cultivated arable margins (those primarily aimed at scarce arable plants). It found that minimum-till was far better than ploughing, allowing insects to complete their life cycles and attain higher abundances within the margin. Furthermore, non-rotational margins (i.e., location remained the same during the option period) allowed more valuable vegetation to develop for bees. The report recommended that floristically enhanced margins adapt their seed mixes and tolerate the presence of those plants (‘weeds’) that supported the most pollinators. These results show that the benefits of cultivated margins could be maximised by fine-tuning their specifications to insect needs.

4. Whether the threat to UK food security from insect decline receives sufficient cross-government priority

Domestic and global food production is highly dependent on pollinators. The often-quoted statistic is that one out of every three mouthfuls of our food depends upon pollinators, like bees, butterflies and moths, birds and bats, and beetles and other insects. This dependency requires a focus on integrated solutions, which deliver both food and environmental security. 

There are a wide range of existing environmental land management options agri-environment schemes which provide support for pollinators (e.g. Nectar & Flower mix, Flower rich margins and plots, Beetle Banks, etc.).  In particular, the farm wildlife offers within Countryside Stewardship have been designed based on scientific evidence to support the full life-cycle requirements of a range of farmland species, including common pollinating insects.

Defra’s development of environmental land management schemes is bringing together a wider range of measures in this space, most notably as part of the Sustainable Farming Incentive (SFI) which will include an increasing focus on measures to support Integrated Pest Management (IPM) approaches, specifically IPM planning and actions such as companion crops, nil use of insecticides and flower rich margins (see Environmental Land Management (ELM) update: how government will pay for land-based environment and climate goods and services - GOV.UK (www.gov.uk)) .  However, these new measures are available individually, rather than as an evidence-based package, and their effectiveness will depend on both overall patterns of uptake and the balance of uptake across the different measures.

5. Additional policy initiatives and solutions needed in the UK and internationally to reduce and reverse the trends in insect decline

As a general observation, the fact that national agri-environment schemes and protected area networks have failed to substantially halt widescale declines in insects (and other invertebrates) over the past 30 years, points to the need for more far-reaching solutions.

Habitat loss, in the second half of the 20th Century, is widely regarded as one of the principal drivers of biodiversity loss. Therefore careful protection of existing semi-natural habitat, in addition to habitat recreation and/or restoration is needed. There is a substantial area of high quality, semi-natural habitat that receives no legal protection; much of it occurs as the 44,000 regionally significant ‘Local Wildlife Sites’, which cover around 5% of England’s land area. These are designated by local authorities, who frequently lack the resources to properly manage them or protect them (Wildlife Trusts, 2018). While Local Nature Recovery Strategies will likely include Local Wildlife Sites, government should consider policy that adequately oversees and supports this resource, so that it might contribute to 30 x 30 and Nature Recovery targets.  In addition to site-based actions a more relaxed approach to other areas, such as roadside verges or other municipally owned land where less frequent cutting and reduced pesticide use can encourage invertebrates, should be encouraged.

9 May 2023

References

Ball L et al. (2021). The Bugs Matter Citizen Science Survey. Technical Report. Buglife & Kent Wildlife Trust, 26pp.

Brooks, D. R. et al. (2012). Large carabid beetle declines in a United Kingdom monitoring network increases evidence for a widespread loss in insect biodiversity. Journal of Applied Ecology, Vol 49, 1009–1019.

Butterfly Conservation. Population trends of UK butterfly species to 2018: Official Statistics briefing.

Carvalheiro, L. G. et al. (2013). Species richness declines and biotic homogenisation have slowed down for NW-European pollinators and plants. Ecology Letters, Vol 16, 870–878.

Conrad, K. F. et al. (2006). Rapid declines of common, widespread British moths provide evidence of an insect biodiversity crisis. Biological Conservation, Vol 132, 279–291.

Cooke R et al. (2023). Protected areas support more species than unprotected areas in Great Britain, but lose them equally rapidly. Biological Conservation 278, 109884.

DiBartolomeis M, Kegley S,  Mineau P, Radford R, Kendra K. (2019). An assessment of acute insecticide toxicity loading (AITL) of chemical pesticides used on agricultural land in the United States. 2019 Aug 6;14(8):e0220029. doi: 10.1371/journal.pone.0220029.

Dicks, L. V., Baude, M., Roberts, S. P. M., Phillips, J., Green, M., & Carvell, C. (2015). How much flower-rich habitat is enough for wild pollinators? Answering a key policy question with incomplete knowledge. Ecological Entomology, 40(S1), 22-35. doi:10.1111/een.12226

EFSA. (2012). Scientific Opinion on the science behind the development of a risk assessment of Plant Protection Products on bees. EFSA Journal, 10(5), 2668. https://www.efsa.europa.eu/en/efsajournal/pub/2668

EFSA. (2018). Neonicotinoids: risks to bees confirmed

https://www.efsa.europa.eu/en/press/news/180228

Ewald, J. E., Wheatley, C. J., Aebisher, N. J., Moreby, S. J., Duffield, S. J., Crick, H. Q., & Morecroft, M. B. (2015). Influences of extreme weather, climate and pesticide use on invertebrates in cereal fields over 42 years. Global Change Biology, 9931-9950.

Fox R, Dennis EB, Brown AF & Curson, J (2022). A revised Red List of British butterflies. Insect Conservation & Diversity 2022, 1-11.

Fox R, Dennis EB, Harrower CA et al. (2021). The State of Britain’s Larger Moths 2021. Butterfly Conservation, Rothamsted Research and UK Centre for Ecology & Hydrology, Wareham, UK.

Fox R, Dennis EB, Purdy KM, et al. (2023). The State of the UK’s Butterflies 2022. Butterfly Conservation, Wareham, UK.

Game and Wildlife Conservation Trust - GWCT (2023). Pesticide use, climate change and farmland invertebrates - (gwct.org.uk) (ongoing study).

Goulson, D (2019). Insect declines and why they matter. South West Wildlife Trusts, 48pp.

Goulson, D., Thompson, J., & Croombs, A. (2018). Rapid rise in toxic load for bees revealed by analysis of pesticide use in Great Britain. PeerJ, 2018(7). https://doi.org/10.7717/peerj.5255

Kessler, S. C., Tiedeken, E. J., Simcock, K. L., Derveau, S., Mitchell, J., Softley, S., Stout, J. C., & Wright, G. A. (2015). Bees prefer foods containing neonicotinoid pesticides. Nature, 521(7550), 74–76. https://doi.org/10.1038/nature14414

Milner, A. M., & Boyd, I. I. (2017). Towards pesticidovigilance. Science, 357(6357), 1232-1234. Retrieved from http://science.sciencemag.org/content/357/6357/1232

National Biodiversity Data Centre (NBDC) (2021) All-Ireland Pollinator Plan 2021-2025. AIPP 2021-2025 » All-Ireland Pollinator Plan (pollinators.ie)

Niamh M. McHugh NM, McVeigh A et al (2021). Evaluation of cultivated margin option effectiveness and exploration of their natural capital. LM0471 / Defra ITT-3829. GWCT, Fordingbridge.

Outhwaite, C. et al. (2020). Complexity of biodiversity change revealed through long-term trends of invertebrates, bryophytes and lichens. Nature Ecology & Evolution 4 (3). DOI: 10.1038/s41559-020-1111-z

Schulz, R., Bub, S., Petschick, L. L., Stehle, S., & Wolfram, J. (n.d.). Applied pesticide toxicity shifts toward plants and invertebrates, even in GM crops. https://doi.org/10.5281/zenodo.4537036

The Wildlife Trusts (2018). The Status of England’s Local Wildlife Sites 2018, 22pp.

Woodcock BA, Isaac NJB, Bullock JM, Roy DB, Garthwaite DG, CroweA & Pywell RF (2016) Impacts of neonicotinoid use on long-term population changes in wild bees in England. Nature Communications, DOI: 10.1038/ncomms12459

UK Parliament (2020) UK Insect decline and extinctions. POSTnote 619, 12pp.

Annex 1

Integrated Pest Management (IPM) for Biodiversity Enhancement, produced by  ADAS for Natural England. To be published Summer 2023

Natural England commissioned a report investigating the impact of IPM practices on biodiversity. The purpose of this study is to provide an assessment of the evidence to help understand which IPM techniques deliver the most benefits for biodiversity, the opportunities for biodiversity enhancement and circumstances where there is a potential for negative impacts on biodiversity.

There was little published evidence found on the effect of IPM methods on biodiversity in its strict sense. The evidence reviewed was therefore almost exclusively from studies where changes in abundance of species were measured under different management regimes. Although abundance is relevant to biodiversity, it is not a measure of species diversity. Where an IPM method was found to result in increases in species abundance, or more increases in abundance than decreases, the review has categorised the method as being broadly positive for biodiversity. Caution is needed in the interpretation of the findings.

Thirteen IPM techniques were covered in the arable sector, nine in horticulture and ten in grassland. These were identified as priority techniques in the AHDB broadacre crops IPM review  and by Natural England. The biodiversity categories covered were birds, mammals, fish, amphibians, reptiles, arthropods, annelids, molluscs, soil micro, meso and macro fauna, non-target plants and protected species. Some of these categories were poorly represented in the evidence.

A summary is reported of seven IPM projects conducted between 1981 and 2005. The projects looked at the effects of reducing inputs on biodiversity but not all were designed with an IPM remit. These projects were complicated and most tried to look at a whole system approach to improving biodiversity whilst reducing pesticide use in crops. The reporting predominantly covered both the benefits and the negative effects to biodiversity. In general, the projects showed that an integrated approach to crop and pest management led to an increase in species abundance and can lead to an increase in species diversity. However, there are no fixed ‘blueprint’ for integrated systems. Methods need to be site specific, adapted to local circumstances with a diverse range of techniques used to benefit a wide range of species. In IPM there is much crossover between techniques and achieving a balance between positives and negatives for biodiversity groups can be difficult.

An assessment was made of both positive and negative impacts of the potential components of IPM systems. In general, many techniques were positive towards biodiversity with crop rotation, field margins, cover crops and companion crops, stubble management, varietal choice and seed mixtures, and bioprotectants having the most positive references. The techniques that had the most negative impact on biodiversity were cultivations (arable) and mowing and topping (grassland). However, these techniques sometimes have positive benefits as well.

Table 1 shows the summary of the impact of 13 IPM techniques in arable farming on arthropods

This tables shows that in many cases evidence has been found of both positive and negative impacts on species abundance from IPM techniques along with a lack of evidence for some IPM techniques. The finding of substantial evidence gaps for the impact of IPM techniques on biodiversity is pertinent as the SFI (Sustainable Farm Incentive) IPM Standard is being introduce with the aim of paying farmers for delivering a public good. However, this report shows that there is a lack of evidence for what impact these practices will have.

Annex 2

A Proposal for Terrestrial Environmental Monitoring of Plant Protectant Products (PPP), produced by UK Centre for Ecology and Hydrology and Fera for Natural England. To be published May 2023

Natural England commissioned a report into terrestrial monitoring of pesticides with funding from DEFRA. This was due to the identification of the evidence gap of the impact on terrestrial environments of pesticides post authorisation. The report evaluated multiple programs that currently monitor pesticides in a part of the terrestrial environment for their potential to contribute to a terrestrial monitoring scheme. This included desk-based data on usage and loading as well as direct presence of pesticides in different environment and biota samples that could provide a measure of exposure. Schemes evaluated were:

• Pesticide Use Survey (PUS): PPP usage remains an important component of the proposed scheme in order to both identify changes in the prevalence and magnitude of use, and for supporting other components of the proposed scheme.
• Inclusion of monitoring of soil concentrations to identify, for example, unexpected combination of PPPs presents in soil, and to identify potential unexpected persistence, including through the formation of bound residues.
• Emerging methods for potential effect measurement that could potentially be used to investigate and monitor the effects of plant protection product on the soil biota would be through the assessment of soil community diversity, most notably through assessment of bacterial or fungal populations.
• Field-derived information on earthworm communities in agricultural soils is likely to be useful in cases where, in common with other biodiversity assessment, trends of community change can be related to likely PPP exposure.
• Chick Food Index (CFI) values, already included in the Pesticide Forum annual reports, have been identified as fundamental information for the terrestrial invertebrate compartment of the proposed scheme.
• Honeybees: National Honey Monitoring Scheme (NHMS) be expanded in scope to include measurement of PPP concentrations in hive products. Pesticide residues in honey are not exposure measures themselves. In addition to the expansion of the NHMS, it is proposed that the Wildlife Incident Investigation Scheme (WIIS) investigations of bee mortalities should be included as it is already running and provides fundamental information for this compartment.
• The WIIS is the only scheme that examines whether the deaths of vertebrate wildlife may be attributable to plant protection products. The focus is on acute poisoning incidents to wildlife and "beneficial invertebrates" refers to honeybees, bumble bees and earthworms, but it may be argued that such incidents are likely to be rare, outside of deliberate poisonings.
• For the potential monitoring of amenity use, other schemes linked within the Wildlife Disease and Contamination Monitoring & Surveillance Network (WILDCOMS), e.g., The Garden Wildlife Health project, already receives samples of garden birds, amphibians, reptiles, and hedgehogs for disease surveillance and could be used for sample collection from peri-urban areas.

The proposed plant protection product monitoring scheme described contains various component elements. These are likely to be conducted by a range of different governmental and NGOs. While some would be a continuation of existing activities, other activities will require development of new collaborative agreements, protocols, pilot-scale testing, full implementation, and data reporting activities. A management structure or group will be required to manage and oversee the functioning, budgeting accountability, and overall reporting of the proposed monitoring scheme.

The report concluded that while it is possible to build a combined monitoring scheme that includes these components building on existing programs, there remain some notable gaps in the potential for exposure and effect monitoring that cannot be so easily filled. These gaps exist both among the taxa sampled and in the aims of the analysis. This highlight that while currently there are schemes that collect data relevant for monitoring the impact of pesticides on terrestrial environments, there are substantial evidence gaps and the disjointed nature of what is being collected means we currently do not have evidence on the presence of pesticides in the terrestrial environment and so cannot say what their impact is on insects.

Annex 3

Background to the development of genetic technologies as an alternative to chemical pesticides

Genetic technologies can provide very effective alternatives to chemical pesticides, with a much lower risk to the environment. For example RNAi, known to work well against coleopterans (beetles) which could prove very effective against flea beetle damage to oil seed rape, replacing neonicitinoids. The first commercial RNAi-based biopesticide to market is dsDvSnf7 registered by the United States Environmental Protection Agency (EPA 2017) for the agrochemical company Bayer. DvSnf7 has been registered as four products (SmartStax PRO) containing a Plant Incorporated Protectant (PIP), whereby transgenic maize expresses DvSnf7 dsRNA targeting the coleopteran Diabrotica vergifera. This results in growth inhibition and ultimately death of the target beetle (Bachman et al., 2013). More recently in the US a sprayable dsRNA product for the control of Colorado potato beetle Leptinotarsa decemlineata has begun the registration process (Rodrigues et al., 2021). The EPA has released a white paper assessing the potential risks and benefits of RNAi-based biopesticides (Matten, 2014), prior to the approval of RNAi biopesticide release in the USA in 2017. More recently, following a 2019 conference on RNAi biopesticide risk and benefits, the Organisation of Economic Cooperation and Development (OECD) and European Food Safety Agency (EFSA) also produced a white paper of an RNAi biopesticide risk assessment (OECD, 2020). Although transgenic plants expressing dsRNA are unlikely to be approved in the UK or the EU in the near future, topically or systemically applied RNAi biopesticides are certainly a possibility. Experimentally, RNAi has proven to be an effective method of pest control against viruses (Mitter et al., 2017), and insects including lepidopterans (butterflies & moths; Terenius et al., 2011), coleopterans (Baum and Roberts, 2014) and hemipterans (true bugs; Cao, Gatehouse and Fitches, 2018). This gives a clear picture of both the viability and regulatory acceptance of RNAi as a pest control strategy.