As seed sales for the 2017 planting season begin in earnest, we wanted to share the third part of our series on Year 2 of the Ontario Neonicotinoid regulations. Specifically, in this post, we cover how this second phase of the regulations affects Sales Representatives and Direct-to-Farm Sales of Class 12 Pesticides or treated seed.

First, to recap a couple of definitions we shared in our last post:

  • A treated seed Sales Representative is an individual who:
    • Represents a person (or company) that is required to hold a treated seed vendor’s licence.
    • Has direct contact with the buyers of neonicotinoid-treated seed and facilitates the sales transaction for a vendor.
    • Note that a treated seed Sales Representative has special responsibilities under the regulation, but does not require a licence.
  • If eligibility criteria are met, direct-to-farm vendors do not require a licence but they have some regulatory responsibilities similar to those that apply to treated seed Sales Representatives.

The Requirements

As of August 31, 2016, Sales Representatives will be able to sell a Class 12 pesticide for the 2017 planting season – such as Neonic-treated corn or soybean seed – on behalf of a licenced vendor if the buyer provides the necessary paperwork. Treated seed Sales Representative and direct-to-farm vendors will need to forward these documents to the licensed vendor on a timely basis (in addition to retaining their own copies).


Any person facilitating the sale of Class 12 pesticides on a vendor’s behalf must carry identification provided by the vendor. Licenced seed vendors are required to provide each Sales Representative with this identification.

Seed Sales Representative- gettyimages-600158950

Image credit: Jevtic /Getty Images 600158950

Training for pesticide Sales Representatives

Since a Sales Representative has direct contact with the buyer to facilitate the sale of a Class 12 pesticide on behalf of a licenced vendor, the Sales Rep will need to understand the new regulatory requirements. They will also need to be aware of the necessary documentation that must be reviewed and retained before facilitating the sale.

It is up to the licenced vendor to determine the appropriate training for their Sales Representatives, but they must ensure that each of their treated seed Sales Representative receives training on the relevant requirements set out in the regulations. Vendors must also keep a record of the name of the treated seed Sales Representative and the date of training.

Documents required by the Sales Rep from the buyer

Several documents must be collected by the Sales Rep from the grower (or other person/organization) buying treated seed for the 2017 growing season. The required documents include the following:

  • A completed and signed pest assessment report that confirms the presence of pests in soil, or crop damage, at or beyond the thresholds set out in the Pest Assessment Guideline.
  • If the buyer is another vendor, a treated seed vendor’s licence number.

Sales representatives must submit a copy of these collected documents to the vendor they represent within 30 days of obtaining the information from the buyer.

Note that Sales Representatives may be asked by officials to provide this information upon request, so it is important for Reps to keep a copy of all documents for at least two years. Also note that Sales Representatives should keep any Seed Amount Declarations that were obtained last year (for the 2016 growing season) for at least two years as well.


Feature image credit: Bryan Eastham /Getty Images 91250376


For more informationcontact your PROSeeds representative, or refer to the following links or the Government of Ontario website for guidelines and forms:


Info for Sales Representatives:

Neonic regulations for Treated Seed Sales Representatives:

IPM Written Declaration Form (required from buyer):


See also our other related blog posts:

Neonic Regs Year 2 – What Vendors Need to Know for Treated Seed:

Neonic Regs Year 2 – What Growers Need to Know:

New Ontario Neonic Regs – What You Need to Know (the 1st Year):

Canadian bees in crisis? Latest data says no:

Neonic Reg Compliance – Two Methods of Pest Assessment:

Neonic Reg Compliance – When is a Professional Pest Advisor Required?: