Minister Steenhuisen, when can we expect the Registrar to respond?

Today marks a year since we called for a review of the registration of 2,4-D in South Africa, in a letter to the Registrar: Act No. 36 of 1947, Mr Jonathan Mudzunga.

With no substantive response forthcoming, despite substantiation in a further submission, and persistent follow up, we have now sent a letter to the Minister of Agriculture, Mr John Steenhuisen, asking him to urgently intervene. Fair administrative justice demands that a response must be given, which delineates the Registrar’s decision and gives reasons for such decision.

Here is a summary of our engagement with the Registrar on this issue, to date:

  • Dec 2023: ACB wrote to the Registrar requesting a review of the registration of 2,4-D.
  • Jan 2024: After no acknowledgement, ACB followed up with the Registrar’s office. Weeks later we finally received a response requesting more information.
  • March 2024: ACB sent a supplementary submission, responding to questions raised by the Registrar, and also arguing that 2,4-D should be classified as a highly hazardous pesticide (HHP).
  • July 2024: Despite follow-ups, we only received an acknowledgment months later. Continued written follow-ups elicited no response.
  • Dec 2024: Current letter to the Minister of Agriculture calling for an intervention.

2,4-D was first registered for use in South Africa in 2007 and is currently banned in ester form and restricted from use in several parts of South Africa. In 2012, the South African government approved its first 2,4-D herbicide-resistant genetically modified (GM) maize variety for commodity clearance, despite civil society opposition. A similar approval followed in 2013 for a 2,4-D resistant soybean variety.

Following these approvals, 2,4-D resistant GM maize varieties including multiple stacked varieties (combining 2,4-D with other traits) have received approvals between 2015 and 2024 for import and trial releases, commodity clearance, and general release. All general-release maize seed varieties containing the transgenic trait to confer tolerance to 2,4-D have been permitted for import for planting since 2020.

Concerning 2,4-D soybean GM varieties, there have been approvals for stacked varieties for commodity clearance, import and trial release, and import for planting for events approved for general release.

The ACB has opposed applications for the authorisation of the use of several GM events that are engineered to resist herbicides such as 2,4-D in South Africa for the past 10 years In these objections, we have raised concerns surrounding:
• regulatory failures;
• herbicide residue risks;
• environmental and health concerns; and
• entrenchment of corporate control of agriculture in South Africa, all of which are deeply concerning.

Thus, we continue to demand transparent, inclusive, public assessment of the environmental, socio-economic, and food safety impacts of genetically modified organisms and their associated chemicals, based on the precautionary principle, as embedded in international and South African environmental law, taking especially into account that maize is a staple food in SA for tens of millions of people.

In addition, the ACB has continued to urge the government to ban HHPs, including 2,4-D, and transition out of industrial agriculture.

Please click here to read the letter.
Please also see our recent letter of demand to the Minister of Agriculture to ban Terbufos and other HHPs here.