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Dow Expects Enlist Duo to be on Market for 2016 Growing Season

Last week, the Environmental Protection Agency (EPA) revoked the registration of Enlist Duo herbicide. This mix that features two key active ingredients — glyphosate and 2,4-D choline — is the herbicide component of Dow AgroSciences’ Enlist Weed Control System. The 2,4-D choline formulation is a new one that addresses concerns regarding off-target movement that exists for current formulations like 2,4-D ester and 2,4-D amine. Only the 2,4-D choline formulation can be used in the Enlist system, which confers tolerance to glyphosate and 2,4-D in corn and soybeans and to “fop” herbicides in corn.

In a prepared statement, EPA cited the combination of 2,4-D choline and glyphosate could result in greater toxicity than expected to non-target plants, including those classified as endangered species. EPA stated Dow had not provided this information to it before issuing the Enlist Duo registration. 

What Dow Says
Dow, though, remains confident of a full-scale 2016 launch for the Enlist system. 

“We believe the questions that have been raised about any potential synergy between 2,4-D choline and glyphosate can be promptly resolved in the next few months, in time for the 2016 crop use season,” said Tim Hassinger, Dow AgroSciences president and CEO, in a prepared statement.  

“It’s possible that we could see some changes to use conditions on the existing Enlist Duo label,” Hassinger added in the statement. “However, based on the ongoing dialogue with EPA, we do not expect these issues to result in the long-term cancellation of the Enlist Duo product registration.”

In the statement, Dow officials say evaluations of potential synergy from herbicidal mixtures are common within the crop protection industry and are not unique to Dow AgroSciences or Enlist Duo. The EPA has not used observations of potential synergy in mixtures as a basis for regulatory action. Technology providers, like Dow AgroSciences, have commonly filed patent applications on mixtures without there being any connection to EPA’s regulatory processes, the statement said. 

“EPA now has all of the data developed by Dow AgroSciences on observed potential synergies between 2,4-D choline and glyphosate in Enlist Duo,” Hassinger added in the statement. “From these data, EPA will readily see – after evaluating all of the efficacy data on the final formulation – why these data support the registration of Enlist Duo.” 

Enlist History 
The Enlist system has had a series of fits and starts on its way to market. Dow initially pegged its Enlist system to debut in corn in 2013 and soybeans in 2015. 

However, developments such as USDA’s Animal and Plant Health Inspection Service (APHIS) May 2013 announcement of two separate environmental impact statements (EIS) for the traits that tolerate 2,4-D and dicamba herbicides surfaced. Monsanto has a dicamba-tolerant trait that includes soybeans as part of its Roundup Ready Xtend Crop System. Monsanto and BASF are developing separate dicamba formulations for this system that address concerns about off-target movement.

In September 2014, USDA approved the Enlist corn and soybean traits following the EIS. Meanwhile, EPA approved the Enlist Duo herbicide component in October 2014. This year, Dow marketed the system to select growers. EPA had granted Enlist Duo registration for use in Illinois, Indiana, Iowa, Ohio, South Dakota, Wisconsin, Arkansas, Kansas, Louisiana, Minnesota, Missouri, Mississippi, Nebraska, Oklahoma, and North Dakota in 2015.

Earlier this year, Dow officials were aiming the Enlist system for a full-scale debut in 2016, pending regulatory approvals such as in countries like China. 

Roundup Ready Xtend Crop System
Monsanto is also aiming its Roundup Ready Xtend Crop System for 2016, pending regulatory approvals. 

“Monsanto does not believe the cautionary actions regarding Enlist have application to Monsanto's separate regulatory submission on our dicamba and glyphosate product for the Xtend platform,” says John Combest, a Monsanto spokesman. “Monsanto’s patent submissions have not made claims of synergistic activity between glyphosate and dicamba. We believe we have submitted a regulatory data package that supports approval of our product.” 

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