Proposed Transform Label Drops Cotton

Proposed Transform Label Drops Cotton

While cotton growers in Arkansas, Mississippi and Tennessee await the decision on Section 18 emergency use of Transform (sulfoxaflor) for plant bug control this season, the EPA is apparently heading in a different direction for the proposed re-registration of the product.

According to information from the National Cotton Council, EPA’s “Proposed Registration Decision for Sulfoxaflor” focuses on registration for the product only on selected agricultural crops, ornamentals and turf. Indeterminate blooming crops – including cotton, citrus and soybeans – covered under the original label are not included in the newly proposed registration.


EPA has opened a 30-day public comment period, ending June 17, for the new label under consideration. The NCC is preparing comments in response to the proposed registration and encourages others in the cotton industry to participate as well.

Details of the label – as well as a link for comments – can be found online.

Sulfoxaflor, developed by Dow AgroSciences, was originally labeled in May 2013. That registration was legally challenged by the Pollinator Stewardship Council and others in July 2013. In September 2015, the Ninth Circuit Court of Appeals issued an opinion that the registration was not supported by substantial evidence to demonstrate “no unreasonable adverse effect to honey bees resulting from the registration of sulfoxaflor.” The court vacated the registration and remanded the issue back to EPA for further studies and documentation.