crop-chem-docs/corpus/epa_ppls/524-671.md

# MON 89034 × MIR162 × MON 95275 × MON 88017

- EPA Reg No: **524-671**
- Registrant: BAYER CROPSCIENCE, LLC
- Signal word: Caution
- Active ingredients: Bacillus thuringiensis Cry3Bb1 protein and the genetic material necessary (vector ZMIR39) for its production in corn (0.13%); Bacillus thuringiensis Cry1A.105 protein and genetic material necessary (vector PV-ZMIR245) for its production in corn (0.056%); Bacillus thuringiensis Cry2Ab2 protein and the genetic material necessary (vector PV-ZMIR245) for its production in corn (0.055%); Bacillus thuringiensis Vpb4Da2 protein and the genetic material necessary for its production in corn event MON 95275 (OECD Unique Identifier MON-95275-7) (0.0048%); Brevibacillus laterosporus Mpp75Aa1.1 protein and the genetic material necessary for its production in corn event MON 95275 (OECD Unique Identifier MON-95275-7) (0.025%); DvSnf7.1 RNA in corn event MON 95275 (OECD unique identifier MON-95275-7) (4.2e-05%); Bacillus thuringiensis Vip3Aa20 protein encoded by vector pNOV1300 in event MIR162 corn (SYN-IR162-4), % dw (0.15%)
- Label accepted: 2026-03-09
- Source PDF: https://www3.epa.gov/pesticides/chem_search/ppls/000524-00671-20260309.pdf

---
U.S. ENVIRONMENTAL PROTECTION AGENCY 
Office of Pesticide Programs 
Biopesticides and Pollution Prevention Division (7511M) 
1200 Pennsylvania Ave., N.W. 
Washington, D.C. 20460 
NOTICE OF PESTICIDE: 
܈Registration 
 ܆Reregistration 
(under FIFRA, as amended) 
EPA Reg. Number: 
 
 
524-671 
Date of Issuance: 
 
 
3/9/2026 
Term of Issuance: 
Unconditional 
Name of Pesticide Product: 
MON 89034 × MIR162 × MON 
95275 × MON 88017 
Name and Address of Registrant (include ZIP Code): 
Bayer CropScience LLC 
700 Chesterfield Pkwy West 
Chesterfield, MO 63017 
 
Note: Changes in labeling differing in substance from those accepted in connection with this registration must be submitted to and ac cepted by the 
Biopesticides and Pollution Prevention Division prior to use of the label in commerce. In any correspondence regarding this product, always refer to the 
above EPA Registration Number. 
On the basis of information furnished by the registrant, the above named pesticide is hereby registered 
under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA or the Act). 
 
Registration is in no way to be construed as an endorsement or recommendation of this product by the 
U.S. Environmental Protection Agency (EPA). In order to protect health and the environment, the 
Administrator, on his or her motion, may at any time suspend or cancel the registration of a pesticide in 
accordance with the Act. The acceptance of any name in connection with the registration of a product 
under the Act is not to be construed as giving the registrant a right to exclusive use of the name or to its 
use if it has been covered by others. 
 
This product is unconditionally registered in accordance with FIFRA section 3(c)(5) provided that you: 
 
1. Submit/cite all data required for registration of your product under FIFRA section 3(c)(5) when 
the Environmental Protection Agency (EPA) requires registrants of similar products to submit 
such data. 
 
Signature of Approving Official: 
 
 
 
Alan Reynolds, Product Manager 94 
Emerging Technologies Branch 
Biopesticides and Pollution Prevention Division (7511M) 
Office of Pesticide Programs
 
Date: 
 
 
 
3/9/2026 
EPA Form 8570-6 
 
Digitally signed by 
ALAN REYNOLDS 
Date: 2026.03.09 
13:41:53 -04'00'

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EPA Reg. No. 524-671 
OPP Case No. 00659693
 
 
 
2. The subject registration is limited to Bacillus thuringiensis Cry1A.105 and Cry2Ab2 proteins, Bacillus 
thuringiensis Vip3Aa20 protein, Brevibacillus laterosporus Mpp75Aa1.1 protein, Bacillus thuringiensis 
Vpb4Da2 protein, DvSnf7.1 dsRNA [double-stranded RNA transcript comprising a DvSnf7 inverted 
repeat sequence derived from western corn rootworm (Diabrotica virgifera virgifera)], Bacillus 
thuringiensis Cry3Bb1 protein, and the genetic material necessary for their production (vectors PV-
ZMIR245, pNOV1300, PV-ZMIR525664, and PV-ZMIR39) in MON 89034 × MIR162 × MON 95275 × 
MON 88017 (OECD Unique Identifier: MON-89Ø34-3 × SYN-IR162-4 × MON-95275-7 × MON 88Ø17-3) 
for use in field corn. 
 
3. The subject registration may be combined through conventional breeding with other registered 
plant-incorporated protectants that are similarly approved for use in combination, through 
conventional breeding, with other registered plant-incorporated protectants to produce inbred corn 
lines and hybrid corn varieties with combined pesticidal traits. 
 
4. Bayer CropScience LLC (Bayer) must develop and submit a resistance monitoring plan for 
Mpp75Aa1.1 and Vpb4Da2. This plan must include a resistance detection assay that meets EPA's 
criteria (see Section 5)(e)(b) below) and baseline susceptibility data. This plan must be submitted 
within six (6) months of registration. 
 
5. Bayer must commit to do the following Insect Resistance Management (IRM) Program, consisting of 
the following elements: 
 
x Requirements for Bayer to implement an IPM-based stewardship program designed to reduce 
selection pressure for corn rootworm (CRW) resistance. 
x Requirements relating to creation of a non-Bacillus thuringiensis (Bt) lepidopteran-protected 
hybrid corn refuge in conjunction with the planting of any acreage of MON 89034 × MIR162 × 
MON 95275 × MON 88017 corn. 
x Requirements for Bayer to prepare and require MON 89034 × MIR162 × MON 95275 × MON 
88017 corn users to sign grower agreements that impose binding contractual obligations on 
growers to comply with the growing requirements. 
 
x Requirements for Bayer to develop, implement, and report to EPA on programs to educate 
growers about IRM. 
x Requirements for Bayer to develop, implement, and report to EPA on programs to evaluate and 
promote growers’ compliance with IRM requirements. 
x Requirements for Bayer to develop, implement, and report to EPA on monitoring programs to 
evaluate whether there are statistically significant and biologically relevant changes in 
susceptibility to the Cry1A.105, Cry2Ab2, and Vip3Aa20 proteins in the target insects. 
x Requirements for Bayer to develop, and if triggered, to implement a remedial action plan that 
would contain measures Bayer would take in the event that any field-relevant insect resistance 
Cry1A.105, Cry2Ab2, and/or Vip3Aa20 was detected, as well as to report on activity under the

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EPA Reg. No. 524-671 
OPP Case No. 00659693
 
 
 
plan to EPA. 
 
x Requirements for Bayer to investigate reports of unexpected CRW damage to MON 89034 × 
MIR162 × MON 95275 × MON 88017 from growers (“performance inquiries”) and sample CRW to 
determine if the insects are resistant to Cry3Bb1, Mpp75Aa1.1, Vpb4Da2, and/or DvSnf7.1. 
 
x Requirements for Bayer to recommend CRW management options to growers in response to 
cases of unexpected CRW damage to MON 89034 × MIR162 × MON 95275 × MON 88017 corn. 
 
x Requirements regarding mitigation and notification actions that Bayer would take in the event 
that CRW resistance was detected. 
 
x Requirements for Bayer to submit reports on resistance monitoring within the time frames 
specified in this registration notice. 
 
x Requirements for Bayer to make available to the Agency upon request records of the number of 
units of MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend sold or shipped and not 
returned, and the number of such units that were sold to persons who have signed grower 
agreements for the previous growing season, within three months of the request. 
x Bag Tag Requirements for MON 89034 × MIR162 × MON 95275 × MON 88017 corn: Seed bags 
and/or bag tags for corn hybrids that contain plant-incorporated protectants produced in MON 
89034 × MIR162 × MON 95275 × MON 88017 corn must display the registration number and 
active ingredients, and stipulate that growers read the Bayer Stewardship Guide (or equivalent 
guidance) prior to planting these hybrids. The refuge size requirement must be displayed on the 
bag or bag tag in both text and graphic format. 
 
a. Integrated Pest Management Stewardship Program (IPM) 
1) Bayer must implement an IPM-based stewardship program for MON 89034 × MIR162 × MON 95275 
× MON 88017 corn. This program must be designed to reduce selection pressure for CRW resistance 
by encouraging growers to engage in a multi-year crop rotation strategy involving the use of one or 
more of the following: a non-CRW host crop (e.g., soybean), pyramided Bt corn Plant Incorporated 
Protectants (PIPs), other PIP corn products with different modes of action, and/or non-Bt or non-
CRW protected Bt corn. As part of the stewardship program, Bayer must update the technology use 
guide/grower guide and other grower educational materials to indicate that application of an 
insecticide to the soil surface, in furrows, and/or incorporated into the soil (referred to as “soil 
applied insecticide”, “soil insecticide” or “SAI”) with MON 89034 × MIR162 × MON 95275 × MON 
88017 corn is not recommended for control of CRW except under limited circumstances and in 
consultation with extension, crop consultants or other local experts. Grower education materials 
should also state that SAIs should not be necessary for CRW control with pyramided CRW trait Bt 
corn product(s). As part of the stewardship program, Bayer must promote the ABSTC/NCGA Best 
Management Practices (BMPs) for CRW control. Implementation of the IPM strategy can include: 
 
x Grower education initiatives or incentives; 
x Outreach to extension and consultant groups.

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EPA Reg. No. 524-671 
OPP Case No. 00659693
 
 
 
 
b. Refuge Requirements for MON 89034 × MIR162 × MON 95275 × MON 88017 
 
The following information must be included on the product bag or bag tag as sold per respective region 
and in the Grower Guide. 
 
These refuge requirements do not apply to planting of inbred and hybrid corn seed productions, 
breeding, and small-scale research trials on up to a total of 20,000 acres per county and up to a 
combined United States (U.S.) total of 250,000 acres per plant-incorporated protectant (PIP) active 
ingredient per registrant per year. Grower agreements (also known as stewardship agreements) will 
specify that growers must adhere to the refuge requirements as described in the grower guide/product 
use guide and/or in supplements to the grower guide/product use guide. 
 
Common Refuge 
 
A common refuge must be planted for both corn borers and corn rootworm and address the following: 
 
x The common refuge must be planted with corn hybrids that do not contain PIP technologies for the 
control of corn rootworm or corn borers. 
 
x MON 89034 × MIR162 × MON 95275 × MON 88017 corn and the non-PIP refuge must be sown on the 
same day, or with the shortest window possible between planting dates to ensure that corn root 
development is similar among varieties. 
 
x If the refuge is planted on rotated ground, then the MON 89034 × MIR162 × MON 95275 × MON 
88017 corn field must also be planted on rotated ground. 
 
x If the combined refuge is planted on continuous corn, the MON 89034 × MIR162 × MON 95275 × 
MON 88017 corn field may also be planted on either continuous or rotated land (option encouraged 
where WCRW rotation resistant biotype may be present). 
 
x Refuge options are based on the planting of MON 89034 × MIR162 × MON 95275 × MON 88017 corn 
in cotton or non-cotton growing regions and the insect pressure present in those locations. The 
refuge sizes for these regions are detailed in Table 1 below. 
 
x In regions where corn rootworm is a significant pest, the common refuge must be planted as an in-
field or adjacent refuge using corn hybrids that do not contain PIP technologies for the control of corn 
borers or corn rootworms. 
 
x The common refuge can be planted as: 
o A block within or adjacent (e.g., across the road) to the MON 89034 × MIR162 × MON 95275 × 
MON 88017 corn field; 
o Perimeter strips (i.e., along the edges or headlands); or 
o In-field strips.

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EPA Reg. No. 524-671 
OPP Case No. 00659693
 
 
 
x When planting the refuge in strips across the field, refuges must be at least four (4) rows wide. 
 
x The common refuge can be protected from lepidopteran damage by use of non-PIP insecticides if the 
population of one or more target lepidopteran pests of MON 89034 × MIR162 × MON 95275 × MON 
88017 if economic thresholds are exceeded in the refuge. In addition, the refuge can be protected 
from CRW damage by an appropriate seed treatment or soil insecticide; however, insecticides labeled 
for adult CRW control must be avoided in the refuge during the period of CRW adult emergence. If 
insecticides are applied to the refuge for control of CRW adults, the same treatment must also be 
applied in the same timeframe to MON 89034 x MIR162 x MON 87411 corn fields. Economic 
thresholds will be determined using methods recommended by local or regional professionals (e.g., 
Extension Service agents, crop consultants). 
 
x In regions where corn rootworm is not a significant pest, the common refuge may be planted as an 
in-field or adjacent refuge or as a separate block that is within ½ mile of the MON 89034 × MIR162 × 
MON 95275 × MON 88017 corn field. The common refuge must be planted with corn hybrids that do 
not contain PIP technologies for the control of corn borers or corn rootworms must be used for the 
refuge. Economic thresholds will be determined using methods recommended by local or regional 
professionals (e.g., Extension Service agents, crop consultants). 
 
Table 1: Refuge Requirements for MON 89034 × MIR162 × MON 95275 × MON 88017 
 
Region Refuge 
Size 
In-field or 
Adjacent 
Refuge is 
Allowed 
Refuge Seperated 
by up to ½ Mile is 
Allowed 
Cotton growing where CEW is a significant pest 
and WCRW, NCRW and MCRW are not significant: 
AR, NC, SC, GA, FL, TN (only the counties of 
Carroll, Chester, Crockett, Dyer, Fayette, Franklin, 
Gibson, Hardeman, Hardin, Haywood, Lake, 
Lauderdale, Lincoln, Madison, Obion, Rutherford, 
Shelby, and Tipton), AL, MS, LA, VA (only the 
counties of Dinwiddie, Franklin City, Greensville, 
Isle of Wight, Northampton, Southampton, Suffolk 
City, Surrey, and Sussex) 
20% 
non-
PIP 
corn 
Yes Yes 
Cotton growing where CEW is a significant pest 
and WCRW, NCRW, and/or MCRW are significant: 
TX (except the counties of Carson, Dallam, 
Hansford, Hartley, Hutchinson, Lipscomb, Moore, 
Ochiltree, Roberts, and Sherman), OK (only the 
counties of Beckham, Caddo, Comanche, Custer, 
Greer, Harmon, Jackson, Kay, Kiowa, Tillman, and 
Washita), MO (only the counties of Dunkin, New 
Madrid, Pemiscot, Scott, and Stoddard) 
20% 
non-
PIP 
corn 
Yes No

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EPA Reg. No. 524-671 
OPP Case No. 00659693
 
 
 
Region Refuge 
Size 
In-field or 
Adjacent 
Refuge is 
Allowed 
Refuge Seperated 
by up to ½ Mile is 
Allowed 
Cotton growing where CEW is not a significant 
pest and WCRW, NCRW, and MCRW are not 
significant: NM, AZ, CA, NV 
5% 
non-
PIP 
corn 
Yes Yes 
Non-cotton growing where WCRW, NCRW and 
MCRW are not significant: OR, WA, ID, MT, WY, 
UT, VA (except the counties of Dinwiddie, Franklin 
City, Greensville, Isle of Wight, Northampton, 
Southampton, 
Suffolk City, Surrey, and Sussex), WV, PA, MD, 
DE,CT, RI, NJ, NY, ME, MA, NH, VT, HI, AK, TN 
(except the counties of Carroll, Chester, Crockett, 
Dyer, Fayette, Franklin, Gibson, Hardeman, 
Hardin, Haywood, Lake, Lauderdale, Lincoln, 
Madison, Obion, Rutherford, Shelby, and Tipton) 
5% 
non-
PIP 
corn 
Yes Yes 
Non-cotton growing where WCRW, NCRW and/or 
MCRW are significant: KS, NE, SD, ND, MN, IA, MO 
(except the counties of Dunkin, New Madrid, 
Pemiscot, Scott, and Stoddard), IL, WI, MI, IN, OH, 
KY, CO, OK (except the counties of Beckham, 
Caddo, Comanche, Custer, Greer, Harmon, 
Jackson, Kay, Kiowa, Tillman, and Washita), TX 
(only the counties of Carson, Dallam, Hansford, 
Hartley, Hutchinson, Lipscomb, Moore, Ochiltree, 
Roberts, and Sherman) 
5% 
non-
PIP 
corn 
Yes No 
 
 
c. Grower Agreements for MON 89034 × MIR162 × MON 95275 × MON 88017 
 
1) Persons purchasing MON 89034 × MIR162 × MON 95275 × MON 88017 corn must sign a grower 
agreement. The term grower agreement refers to any grower purchase contract, license agreement, 
or similar legal document. 
 
2) The grower agreement and/or specific stewardship documents referenced in the grower agreement 
must clearly set forth the terms of the current IRM program. By signing the grower agreement, a 
grower must be contractually bound to comply with the requirements of the IRM program. 
 
3) Bayer must integrate this registration into the current system used for its other Bt corn plant 
incorporated protectants, which is reasonably likely to assure that persons purchasing MON 89034 × 
MIR162 × MON 95275 × MON 88017
 corn will affirm annually that they are contractually bound to 
comply with the requirements of the IRM program.

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EPA Reg. No. 524-671 
OPP Case No. 00659693
 
 
 
4) If Bayer wishes to change any part of the grower agreement or any specific stewardship documents 
referenced in the grower agreement that would affect either the content of the IRM program or the 
legal enforceability of the provisions of the agreement relating to the IRM program, 30 days prior to 
implementing a proposed change, Bayer must submit to EPA the text of such changes to ensure it is 
consistent with the terms and conditions of this registration. 
 
5) Bayer shall maintain records of all MON 89034 × MIR162 × MON 95275 × MON 88017 corn
 grower 
agreements for a period of three (3) years from December 31st of the year in which the agreement 
was signed. 
 
6) Bayer shall make available to the Agency upon request records of the number of units of MON 89034 
× MIR162 × MON 95275 × MON 88017
 corn seed sold or shipped and not returned, and the number 
of such units that were sold to persons who have signed grower agreements for the previous growing 
season. Bayer is required to submit reports within three (3) months of the Agency’s request. 
 
7) Bayer must allow a review of the grower agreements and grower agreement records by EPA or by a 
State pesticide regulatory agency if the State agency can demonstrate that confidential business 
information, including names, personal information, and grower license numbers of the growers, will 
be protected. 
 
d. IRM Education and Compliance Monitoring Programs for MON 89034 × MIR162 × MON 95275 × 
MON 88017 
 
1) Bayer must implement and enhance (as set forth in paragraph 17 of this section) a comprehensive, 
ongoing IRM education program designed to convey to MON 89034 × MIR162 × MON 95275 × MON 
88017
 corn users the importance of complying with the IRM program, as well as product performance 
expectations and guidance to growers on actions to take when unexpected damage occurs. The 
program shall include information encouraging MON 89034 × MIR162 × MON 95275 × MON 88017
 
corn users to pursue optional elements of the IRM program relating to refuge configuration and 
proximity to MON 89034 × MIR162 × MON 95275 × MON 88017 corn fields. The education program 
shall involve the use of multiple media (e.g., face-to-face meetings, mailing written materials, EPA-
reviewed language on IRM requirements on the bag or bag tag, and electronic communications such 
as by Internet, radio, or television commercials). Copies of the materials will be provided to EPA for 
its records. The program shall involve at least one (1) written communication annually to each MON 
89034 × MIR162 × MON 95275 × MON 88017 corn
 user separate from the grower technical guide. 
The communication shall inform the user of the current IRM requirements. Bayer shall coordinate its 
education programs with educational efforts of other registrants and organizations, such as the 
National Corn Growers Association and state extension programs. 
 
2) Bayer shall revise, and expand as necessary, its education program to take into account the 
information collected through the compliance survey, required under paragraphs 6–9 of this section, 
and from other sources. The changes shall address aspects of grower compliance that are not 
sufficiently high. 
 
3) Upon EPA request, Bayer shall provide copies of grower education materials and information on 
grower education activities including any substantive changes to these materials and activities

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EPA Reg. No. 524-671 
OPP Case No. 00659693
 
 
 
conducted either individually or as part of the industry working group, Agricultural Biotechnology 
Stewardship Technical Committee (ABSTC). Bayer is required to submit reports within three (3) 
months of the Agency’s request. The required features of the compliance assurance program are 
described in paragraphs 4–22 of this section. 
 
4) Bayer must implement and improve an ongoing IRM compliance assurance program designed to 
evaluate the extent to which growers purchasing MON 89034 × MIR162 × MON 95275 × MON 88017 
corn
 are complying with the IRM program and that takes such actions as are reasonably needed to 
assure that growers who have not complied with the program either do so in the future or lose their 
access to Bayer’s Bt corn products. Bayer shall coordinate with other Bt corn registrants in improving 
its compliance assurance program and integrate this registration into the current compliance 
assurance program used for its other Bt corn plant-incorporated protectants. Other required features 
of the program are described in paragraphs 5–22 of this section. 
 
5) Bayer must maintain and publicize a phased compliance approach (i.e., a guidance document that 
indicates how it will address instances of non-compliance with the terms of the IRM program and 
general criteria for choosing among options for responding to any non-compliant growers after the 
first year of non-compliance). While recognizing that for reasons of difference in business practices 
there are needs for flexibility between different companies, Bayer must use a consistent set of 
standards for responding to non-compliance. An individual grower found to be significantly out of 
compliance two (2) years in a row would be denied access the next year to Bayer’s Bt corn products 
for which the grower is required to plant a separate structured refuge. Similarly, seed dealers who 
are not fulfilling their obligations to inform/educate growers of their IRM obligations will lose their 
opportunity to sell Bt corn. 
 
6) The IRM compliance assurance program shall include an annual survey, conducted by an independent 
third party of a statistically representative sample of growers of MON 89034 × MIR162 × MON 95275 
× MON 88017 corn. The survey shall be conducted in odd-numbered years beginning in 2027 and 
shall include growers who plant 100 or more acres of corn in the Southern U.S. corn-cotton areas. 
Bayer may collaborate with other registrants of Bt corn [for example, through the industry working 
group the Agricultural Biotechnology Stewardship Technical Committee (ABSTC)] to conduct the 
survey. 
 
In the U.S. Corn Belt, no anonymous grower survey is required for MON 89034 × MIR162 × MON 
95275 × MON 88017 if Bayer can demonstrate that the industry-wide adoption of integrated refuge 
products (i.e., refuge seed blends) is equal to or greater than 70% of Bt corn acres in the Corn Belt. If 
industry-wide adoption of integrated refuge products (i.e., refuge seed blends) falls below 70% of Bt 
corn acres in the Corn Belt, an anonymous grower survey shall also be conducted in this region 
during the next growing season using a statistically representative sample of growers who plant 200 
or more acres of corn, and grower surveys shall be continued every odd-numbered year until the 
industry-wide adoption of integrated refuge products (i.e., refuge seed blends) is again equal to or 
greater than 70% of Bt corn acres in this region. Bayer may collaborate with other registrants of Bt 
corn (for example, through the industry working group the ABSTC) to compile the integrated refuge 
adoption data and to conduct the surveys. 
 
Alternatively, if Bayer is not a participant of an industry working group (e.g., the ABSTC) and Bayer’s

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EPA Reg. No. 524-671 
OPP Case No. 00659693
 
 
 
sales of integrated refuge products are equal to or greater than 70% of the Bayer’s total Bt corn sales 
in the prior year, then no anonymous grower survey is required in the U.S. Corn Belt. If the Bayer’s 
sales of integrated refuge products fall below 70% of the Bayer’s total Bt corn sales, an anonymous 
grower survey shall also be conducted in this region during the next growing season using a 
statistically representative sample of growers who plant 200 or more acres of corn, and grower 
surveys shall be continued every odd-numbered year until sales of integrated refuge products (i.e., 
refuge seed blends) are again equal to or greater than 70% of Bayer’s total Bt corn sales in this 
region. 
 
x A third party is classified as a party other than the registrant, the grower, or anyone else 
with a direct interest in IRM compliance for Bt corn. 
 
7) The survey shall be designed to provide an understanding of any difficulties growers encounter in 
implementing IRM requirements. An analysis of survey results must include the reasons, extent, and 
potential biological significance of any implementation deviations. 
 
8) The survey shall be designed to obtain grower feedback on the usefulness of specific educational 
tools and initiatives. 
 
9) In years in which the survey is conducted, Bayer shall provide a final written summary of the results 
of the prior year’s survey (together with a description of the regions, the methodology used, and the 
supporting data) to EPA on or before January 31st of each year. Bayer shall confer with other 
registrants and EPA on the design and content of the survey prior to its implementation. 
 
10) Bayer shall revise, and expand as necessary, its compliance assurance program to take into account 
the information collected through the compliance survey, required under paragraphs 6–9 of this 
section, and from other sources. The changes shall address aspects of grower compliance that are 
not sufficiently high. Bayer must confer with EPA prior to adopting any changes. 
 
11) Bayer shall conduct an annual on-farm assessment program. Bayer shall train its representatives who 
make on-farm visits with MON 89034 × MIR162 × MON 95275 × MON 88017 corn growers to 
perform assessments of compliance with IRM requirements. There is no minimum corn acreage size 
for this program. Therefore, growers will be selected for this program from across all farm sizes. In 
the event that any of these visits result in the identification of a grower who is not in compliance with 
the IRM program, Bayer shall take appropriate action, consistent with its phased compliance 
approach, to promote compliance. 
 
12) Bayer shall carry out a program for investigating legitimate tips and complaints that MON 89034 × 
MIR162 × MON 95275 × MON 88017 growers are not in compliance with the IRM program. 
Whenever an investigation results in the identification of a grower who is not in compliance with the 
IRM program, Bayer shall take appropriate action, consistent with its phased compliance approach. 
 
13) If a grower, who purchases MON 89034 × MIR162 × MON 95275 × MON 88017 corn for planting, was 
specifically identified as not being in compliance during the previous year, Bayer shall visit with the 
grower and evaluate whether the grower is in compliance with the IRM program for the current year.

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EPA Reg. No. 524-671 
OPP Case No. 00659693
 
 
 
14) Annually by January 31st each year, Bayer shall provide a report to EPA summarizing the MON 89034 
× MIR162 × MON 95275 × MON 88017 compliance assurance program activities and the results for 
the prior year and the plans for the MON 89034 × MIR162 × MON 95275 × MON 88017 compliance 
assurance program during the current year. Within one (1) month of submitting this report to EPA, 
the registrant shall meet with EPA to discuss its findings. The report will include information 
regarding grower interactions (including, but not limited to, on-farm visits, verified tips and 
complaints, grower meetings and letters), the extent of non-compliance, corrective measures to 
address the non- compliance, and any follow-up actions taken. The report must inform EPA of the 
number of growers deemed ineligible to purchase Bt corn seed on the basis of continued non-
compliance with the insect resistance management refuge requirements. Bayer may elect to 
coordinate information with other registrants and report collectively the results of compliance 
assurance programs. 
 
15) Bayer and the seed corn dealers for Bayer must allow a review of the compliance records by EPA or 
by a State pesticide regulatory agency if the State agency can demonstrate that confidential business 
information, including the names, personal information, and grower license numbers of the growers, 
will be protected. 
 
16) Bayer shall revise and expand its existing compliance assurance program to include the following 
elements. The registrant may coordinate with other registrants in designing and implementing its 
Compliance Assurance Program. 
 
17) Bayer will enhance the refuge education program throughout the seed delivery channel to: 
 
x Ensure sales representatives, licensees, seed dealers, and growers recognize the importance of 
correct refuge implementation and potential consequences of failure to plant the required refuge. 
 
x Implement a “bag tag” that will be attached to all bags of MON 89034 × MIR162 × MON 95275 × 
MON 88017 Corn seed sold and delivered. The refuge size requirement must be included on all 
PIP corn seed bags or bag tags. The PIP product label accepted by EPA must include how this 
information will be conveyed to growers via text and graphics. 
 
18) Bayer will focus the majority of on-farm assessments on regions with the greatest risk for resistance: 
 
x Use Bt corn adoption, pest pressure information, and other available information to identify 
regions where the risk of resistance is greatest. 
 
x Focus approximately two-thirds of on-farm assessments on these regions, with the remaining 
assessments conducted across other regions where MON 89034 × MIR162 × MON 95275 × MON 
88017 is used. 
 
19) Bayer will use its available MON 89034 × MIR162 × MON 95275 × MON 88017 sales records and 
other information to refine grower lists for on-farm assessments of their compliance with refuge 
requirements to: 
 
x Identify for potential on-farm assessment growers whose sales information indicates they have

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EPA Reg. No. 524-671 
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purchased MON 89034 × MIR162 × MON 95275 × MON 88017 corn products but may have 
purchased little or no refuge seed from Bayer, licensees, or affiliated companies. 
 
20) Bayer will contract with third parties to perform on-farm assessments of compliance with 
refuge requirements: 
 
x The third-party assessors will conduct all first-time on-farm assessments, as well as second- year 
on farm assessments, of those growers found out of compliance in a first-time assessment. 
 
21) Annually, Bayer will refine the on-farm assessment program for MON 89034 × MIR162 × MON 95275 
× MON 88017 crn product to reflect the adoption rate and level of refuge compliance for the product. 
 
22) Bayer will follow up with growers who have been found significantly out of compliance under the on-
farm assessment program and are found to be back in compliance the following year: 
 
x All growers found to be significantly out of compliance in a prior year will annually be sent 
additional refuge assistance information for a minimum of two (2) years by Bayer, a seed supplier, 
or a third party assessor, after completing the assessment process. 
 
x Bayer will conduct follow-up checks on growers found to be significantly out of compliance within 
three (3) years after they are found to be back in compliance. 
 
x A grower found with a second incident of significant non-compliance with refuge requirements 
for the Bt corn product within a five-year period will be denied access to Bayer’s Bt corn products 
the next year. Similarly, seed dealers who are not fulfilling their obligations to inform/educate 
growers of their IRM obligations will lose their opportunity to sell Bt corn. 
 
e. Insect Resistance Monitoring and Remedial Action Plans for MON 89034 × MIR162 × MON 95275 × 
MON 88017 
 
1) EPA is imposing the following conditions for the Cry1A.105, Cry2Ab2, and Vip3Aa20 toxins expressed 
in MON 89034 × MIR162 × MON 95275 × MON 88017: 
 
Bayer will monitor for resistance to expressed in Cry1A.105, Cry2Ab2, and Vip3Aa20 toxins MON 89034 
× MIR162 × MON 95275 × MON 88017. The monitoring program European corn borer (Ostrinia nubilalis; 
ECB) and southwestern corn borer (Diatraea grandiosella; SWCB)shall consist of two approaches: (1) 
focused population sampling and laboratory testing; and (2) investigation of reports of less-than 
expected control of labeled insects. Should field-relevant resistance be confirmed, an appropriate 
remedial action plan will be implemented. Corn earworm (Helicoverpa zea; CEW) will be monitored using 
sentinel plots and reports of unexpected injury to MON 89034 × MIR162 × MON 95275 × MON 88017 
corn. 
 
Focused Population Sampling 
 
Bayer shall annually sample and bioassay populations of the key target pests: Ostrinia nubilalis

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EPA Reg. No. 524-671 
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(European corn borer; ECB) and Diatraea grandiosella (southwestern corn borer; SWCB). Sampling for 
the target pests will be focused in areas identified as those with the highest risk of resistance 
development (e.g., where lepidopteran-active Bt hybrids are planted on a high proportion of the corn 
acres, and where the insect species are regarded as key pests of corn). Bioassay methods must be 
appropriate for the goal of detecting field-relevant shifts in population response to MON 89034 × 
MIR162 × MON 95275 × MON 88017 and/or changes in resistance allele frequency in response to the 
use MON 89034 × MIR162 × MON 95275 × MON 88017 corn and, as far as possible, should be 
consistent across sampling years to enable comparisons with historical data. 
 
The number of populations to be collected shall reflect the regional importance of the insect species as 
a pest, and specific collection regions will be identified for each pest. For ECB, a minimum of twelve (12) 
populations across the sampling region will be targeted for collection at each annual sampling. For 
SWCB, the target will be a minimum of six (6) populations. Pest populations should be collected from 
multiple corn-growing states reflective of different geographies and agronomic conditions. To obtain 
sufficient sensitivity to detect resistance alleles before they become common enough to cause 
measurable field damage, each population collection shall attempt to target 400 insect genomes (egg 
masses, larvae, mated females, and/or mixed-sex adults), but a successful population collection will 
contain a minimum of 100 genomes. It is recognized that it may not be possible to collect the target 
number of insect populations or genomes due to factors such as natural fluctuations in pest density, 
environmental conditions, and area-wide pest suppression. The sampling program and geographic 
range of collections may be modified as appropriate based on changes in pest importance and for the 
adoption levels of MON 89034 × MIR162 × MON 95275 × MON 88017. EPA shall be consulted prior to 
the implementation of such modifications. 
 
Bayer will report to EPA, on or before August 31st of each year, the results of the population sampling 
and bioassay monitoring program. 
 
Any incidence of unusually low sensitivity to the Cry1A.105, Cry2Ab2, and Vip3Aa20 proteins in 
bioassays shall be investigated as soon as possible to understand any field relevance of such a finding. 
Such investigations shall proceed in a stepwise manner until the field relevance can be either confirmed 
or refuted, and results of these shall be reported to EPA annually on or before August 31st. The 
investigative steps will include the following: 
 
1. Re-test progeny of the collected population to determine whether the unusual bioassay response is 
reproducible and heritable. If it is not reproducible and heritable, no further action is required. 
 
2. If the unusual response is reproducible and heritable, progeny of insects that survive the diagnostic 
concentration will be tested using methods that are representative of exposure to MON 89034 × 
MIR162 × MON 95275 × MON 88017 corn under field conditions. If progeny do not survive to 
adulthood, any suspected resistance is not field relevant and no further action is required. 
 
3. If insects survive steps 1 and 2, resistance is confirmed, and further steps will be taken to evaluate 
the resistance. These steps may include the following: 
 
x Determining the nature of the resistance (i.e., recessive or dominant, and the level of functional

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EPA Reg. No. 524-671 
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dominance); 
 
x Estimating the resistance allele frequency in the original population; 
 
x Determining whether the resistance-allele frequency is increasing by analyzing field collections 
in subsequent years sampled from the same site where the resistance allele(s) was originally 
collected; 
 
x Determining the geographic distribution of the resistance allele by analyzing field collections in 
subsequent years from sites surrounding the site where the resistance allele(s) was originally 
collected. 
 
Should field-relevant resistance be confirmed, and the resistance appears to be increasing or 
spreading, Bayer will consult with EPA to develop and implement a case-specific remedial action plan. 
 
Investigation of Reports of Unexpected Levels of Damage by the Target Pests (ECB and SWCB) 
 
Bayer will follow up on grower, extension specialist, or consultant reports of unexpected levels of 
damage by the lepidopteran pests listed on the pesticide label. Bayer will instruct its customers to 
contact them if such incidents occur and provide guidance to growers on seed blend product 
performance expectations and actions to take when unexpected damage occurs. Bayer will investigate 
all legitimate reports submitted to the company or the company's representatives. 
 
If reports of unexpected levels of damage lead to the suspicion of resistance in any of the key target pests 
(ECB and SWCB), Bayer will implement the actions described below, based on the following definitions of 
suspected resistance and confirmed resistance. 
 
Suspected Resistance (ECB and SWCB) 
 
EPA defines suspected resistance to mean field reports of unexpected levels of insect-feeding damage 
for which: 
 
x The corn in question has been confirmed to be lepidopteran-active Bt corn; 
 
x The seed used had the proper percentage of corn expressing Bt protein; 
 
x The relevant plant tissues are expressing the expected level of Bt protein; 
 
x It has been ruled out that species not susceptible to the protein could be responsible for the 
damage, that no climatic or cultural reasons could be responsible for the damage; and 
 
x That that there could be no other reasonable causes for the damage. 
 
EPA does not interpret suspected resistance to mean grower reports of possible control failures or

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EPA Reg. No. 524-671 
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suspicious results from annual insect monitoring assays, nor does EPA intend that extensive field 
studies and testing be undertaken to confirm scientifically the presence of insects resistant to 
MON 89034 × MIR162 × MON 95275 × MON 88017 corn in commercial production fields before 
responsive measures are undertaken. 
 
If resistance is suspected, Bayer will instruct growers to do the following: 
 
x Use alternative control measures in MON 89034 × MIR162 × MON 95275 × MON 88017 corn 
fields in the affected region to control the target pest during the immediate growing season. 
 
x Destroy MON 89034 × MIR162 × MON 95275 × MON 88017 corn crop residues in the affected 
region within one (1) month after harvest with a technique appropriate for local production 
practices to minimize the possibility of resistant insects over-wintering and contributing to the 
next season's target pest population. 
 
Additionally, if possible, and prior to the application of alternative control measures or destruction 
of crop residues, Bayer will collect samples of the insect population in the affected fields for 
laboratory rearing and testing. Such rearing and testing shall be conducted as expeditiously as 
practical. 
 
Confirmed Resistance (ECB and SWCB) 
 
EPA defines confirmed resistance to mean, in the case of field reports of unexpected levels of damage 
from the key target pests, that all of the following criteria are met: 
 
x There is >30% insect survival and commensurate insect feeding in a bioassay, initiated with 
neonate larvae, that uses methods that are representative of exposure to Bt corn hybrids under 
field conditions. 
 
x In standardized laboratory bioassays using diagnostic concentrations of the Bt protein suited to 
the target pest in question, the pest exhibits resistance that has a genetic basis and the level of 
survivorship indicates that there may be a resistance allele frequency of ш 0.1 in the sampled 
population. 
 
x In standardized laboratory bioassays, the LC
50 exceeds the upper limit of the 95% confidence 
interval of the LC50 for susceptible populations surveyed both in the original baselines developed 
for this pest species and in previous years of field monitoring. 
 
Response to Confirmed Resistance in a Key Target Pest as the Cause of Unexpected Levels of Damage 
in the Field (ECB and SWCB) 
 
When field resistance is confirmed for ECB or SWCB (as defined above), the following steps will be taken 
by Bayer:

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EPA Reg. No. 524-671 
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x EPA will receive notification within 30 days of resistance confirmation; 
 
x Affected customers and extension agents will be notified about confirmed resistance within 30 
days; 
 
x Monitoring will be increased in the affected area and local target pest populations will be 
sampled annually to determine the extent and impact of resistance; 
 
x If appropriate (depending on the resistant pest species, the extent of resistance, the timing of 
resistance, and the nature of resistance, and the availability of suitable alternative control 
measures), alternate control measures will be employed to reduce or control target pest 
populations in the affected area. Alternative control measures may include advising customers 
and extension agents in the affected area to incorporate crop residues into the soil following 
harvest to minimize the possibility of over-wintering insects, and/or applications of chemical 
insecticides; 
 
x Unless otherwise agreed with EPA, stop sale and distribution of the relevant lepidopteran-active 
Bt corn hybrids in the affected area immediately until an effective local mitigation plan, 
approved by EPA, has been implemented; 
 
x Bayer will develop a case-specific remedial action plan within 90 days according to the 
characteristics of the resistance event and local agronomic needs. Bayer will consult with 
appropriate stakeholders in the development of the action plan, and the details of such a plan 
shall be approved by EPA prior to implementation; 
 
x Bayer will notify affected parties (e.g., growers, consultants, extension agents, seed distributors, 
university cooperators, and state/federal authorities as appropriate) in the region of the 
resistance situation and approved action plan; and 
 
x In subsequent growing seasons, maintain sales suspension and alternative resistance 
management strategies in the affected region(s) for the Bt corn hybrids that are affected by the 
resistant population until an EPA- approved local resistance management plan is in place to 
mitigate the resistance. 
 
Corn Earworm (CEW) Resistance Monitoring 
 
x No annual CEW insect collections and subsequent bioassays are required for the Cry1A.105, 
Cry2Ab2, and/or Vip3Aa20 proteins; 
 
x A network of sentinel plots must be established in cotton growing states to monitor CEW 
resistance in PIP corn products containing the Vip3Aa20 protein, including MON 89034 × 
MIR162 × MON 95275 × MON 88017, that follows EPA approved methods defined in the

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protocol for the establishment of sentinel plots, evaluation of CEW against the Vip3Aa20 
protein only, and calculation of a phenotypic a resistance ratio (MRID 52144201); 
 
x Bayer must follow up on grower, extension specialist, or consultant reports of unexpected 
injury (UXI) by CEW to MON 89034 × MIR162 × MON 95275 × MON 88017 that meet the 
criteria below. Bayer will instruct its customers to contact them if such incidents occur. Bayer 
will investigate all legitimate reports submitted to the company or the company's 
representatives. 
 
o To investigate potential UXI to products containing Vip3Aa20, a minimum of a 100-ear 
sample collected from the affected area of the field will be taken. UXI is confirmed if at least 
10% of individual ears sampled meet both of the following criteria: (1) one or more CEW 
larvae (ш 3rd instar) or exit holes are present; and (2) there is at least 2 cm
2 of CEW feeding 
injury. 
 
x If UXI triggers for CEW above are exceeded, Bayer must implement the mitigation actions 
below: 
 
o Report the results of any investigations confirming the UXI and the affected county where 
the report occurred in an annual resistance monitoring report to EPA; 
 
o Inform affected customer(s) and state extension agents of the UXI within 30 days within 30 
days of the UXI confirmation; and 
 
o Where in-season management tactics are possible, the recommended management options 
include, but are not limited to the following: 
 
ƒ Apply an appropriate foliar chemical insecticide (only if economically viable in corn); 
ƒ If additional pest management is needed, additional control tactics as appropriate (e.g., 
additional foliar insecticide applications, tillage practices). 
ƒ If in-season management tactics are not possible, the recommended management 
options for the next growing seasons include, but are not limited to the following: 
 
x Switching to a different Bt mode of action or planting non-Bt corn; 
x Encourage timely planting to avoid primary risk window for primary pests; 
x Encourage growers to monitor for adults and intensify field scouting for 
injury in corn fields; 
x Use appropriately timed foliar insecticide application based on field scouting 
for insect injury; 
x If additional pest management is needed, additional control tactics as 
appropriate (e.g., additional foliar insecticide applications, tillage practices). 
 
A report on results of resistance monitoring and investigations of damage reports must be submitted to

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EPA Reg. No. 524-671 
OPP Case No. 00659693
 
 
 
EPA, on or before August 31st of each year, for the duration of the registration. 
 
2) EPA is imposing the following conditions for the Cry3Bb1, Mpp75Aa1.1, Vpb4Da2, and DvSnf7.1 toxins 
expressed in MON 89034 × MIR162 × MON 95275 × MON 88017: 
 
a) Investigation of Reports of Unexpected Levels of Damage (UXD) by Corn Rootworm (CRW): 
Performance Inquiries 
 
1) Bayer is required to investigate "performance inquiries" (i.e., reports of unexpected CRW 
damage to MON 89034 × MIR162 × MON 95275 × MON 88017) from growers. Fields (defined 
as a tract separated by permanent boundaries such as fences, permanent waterways, 
woodlands, crop lines not subject to change because of farming practices, or other similar 
features) with unexpected damage that meet both of the criteria below must be subjected to 
the follow-up actions in part 2) below: 
 
a. The affected plants are confirmed to be MON 89034 × MIR162 × MON 95275 × MON 
88017 corn plants (take leaf samples to determine the presence of the CRW- active Bt 
protein); and 
 
b. Corn rootworm feeding caused root damage with a Node Injury Score (NIS) > 0.5 on at 
least 50% of plants surveyed in a transect sampling of the damaged site(s) within the field. 
 
2) Follow-up actions (performance inquiries). For MON 89034 × MIR162 × MON 95275 × MON 
88017 corn fields meeting the criteria in part 1) above, Bayer must take the following actions: 
 
a. Collect at least 250 (ideally 500 or more) CRW adult individuals from the damaged site 
within the field in question. Collections may be extended to the whole field, if necessary 
to obtain sufficient CRW adult individuals. Collected populations must be subjected to 
the steps described for "investigation of populations of concern" in section e(2)(b)(3)(c) 
below. 
 
o If collections are unsuccessful, visit affected farm or field the following year 
(assuming the grower continues to be a customer and repurchases seed and does 
not rotate the field to a non-host crop) and attempt to collect CRW adults. If beetles 
are not present the subsequent year, see section e(2)(b)(3) below. 
 
b. Review with the grower their CRW management practices and provide CRW management 
recommendations including an assessment of corn fields with similar trait(s) adjacent to 
the affected corn field that are managed by the same grower. 
 
c. Use of single trait products containing the CRW traits in MON 89034 × MIR162 × MON 
95275 × MON 88017 in fields with unexpected damage in previous years should be 
discouraged. Recommended management options include, but are not limited to, the 
following:

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OPP Case No. 00659693
 
 
 
o Primary option: Rotation to non-host crop (e.g., soybean) 
 
o Secondary options: 
 
ƒ Use of pyramided Bt corn products one or more different CRW PIP trait(s); 
ƒ Use of different CRW PIP traits (i.e., an alternative CRW-active PIP); 
ƒ Use of non-Bt or non-CRW protected corn. 
 
o Tertiary options: 
 
ƒ If additional pest management need is determined beyond the secondary options 
listed above, use of the same pyramided Bt corn product is acceptable if it is very 
unlikely that both of the traits are affected (e.g., the affected field experienced 
UXD to one of the traits in the product in the previous year, the NIS is less than 
1.0, there has been no continuous use of the second trait in the product in the 
affected field, and Bayer has not been informed of resistance to the second trait 
in the county); 
 
ƒ Additional corn rootworm control tools (e.g., soil applied insecticides, 
chemigation) should be considered. 
 
d. If field(s) with UXD is/are planted to a non-host crop (e.g., soybean) the following year, 
then the area will be considered “mitigated” (as discussed in section e(2)(b)(3)(d) below) 
even if subsequent bioassay results show that the population was resistant. No further 
action will be required by Bayer for the UXD case. 
 
3) Bayer must submit an annual report to EPA detailing activities related to investigations of 
unexpected damage (UXD). This report will include the information from the most recent and 
previous corn growing seasons: 
 
a. Information from the most recent season: 
 
o The number of UXD reports investigated; 
 
o Location (by county and state); 
 
o CRW sampling (number and location of populations collected). 
 
b. Information from the previous season: 
 
o The final disposition of UXD fields from the previous season (i.e., the management 
practices; employed in response to UXD if the grower continues to be a customer; 
 
o Results from bioassays conducted on CRW populations from UXD fields where the

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EPA Reg. No. 524-671 
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primary management option, rotation to non-host crop, was not used. 
 
c. Grower information, such as farm addresses or other personally identifiable information, 
or other sensitive business/customer information must not be included in this report. 
This report must be submitted by November 30th each year. 
 
b) Investigation of Populations of Concern 
 
1) Bayer must conduct investigations of all CRW populations collected as part of the 
performance inquiry process in section e(2)(a) above. These investigations must include the 
use of an EPA-approved bioassay to determine if sampled CRW populations are resistant to 
any of the CRW PIP toxins in MON 89034 × MIR162 × MON 95275 × MON 88017. Acceptable 
assays must be able to function as diagnostic tools capable of distinguishing resistant 
populations from susceptible ones. Unless previously approved, Bayer must consult with EPA 
on their bioassay prior to its use. 
 
2) A CRW population will be considered by EPA to be resistant to a CRW PIP toxin if the 
following criteria are met and additional collections and testing are not deemed to be 
necessary (based on part 3 below
): 
 
a. An initial performance inquiry investigation results in a finding of Unexpected Damage; and 
 
b. Where green tissues are available and if plants are unusually stressed due to agronomic 
and/or environmental factors, Bt protein levels in affected plants are found to be within 
the documented range for that hybrid (if data are available); and 
 
Either (A): On-plant bioassays of insect collections from the UXD fields result in the following 
two statistically relevant comparisons: 
 
i. A statistically significant difference in measures of either mortality or sublethal effects 
(growth/development) between the field population and a relevant susceptible control 
population (i.e., one that responds as a typical susceptible field population) on Bt corn 
containing the single PIP and/or lack of a statistically significant difference in measures of 
mortality or sublethal effect between the field population and a resistant positive control 
population
1; and 
 
ii. A lack of a statistically significant difference in the same measures of the field population 
raised on Bt corn containing the single PIP and non-Bt corn plants. 
 
Or (B): Sublethal seedling bioassay of insect collections from the UXD fields result in two 
statistically relevant comparisons: 
 
 
1 If a resistant positive control population is not available or accessible, Bayer must consult with EPA prior to initiating bioassays 
and work to develop an appropriate resistant positive control population.

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i. A statistically significant difference in measures of sublethal effects 
(growth/development) for populations on Bt corn containing the single PIP (normalized 
using non-Bt) seedlings between the field population and a relevant susceptible control 
population where available or historical field populations and/or lack of a statistically 
significant difference in measures between the field population and a resistant positive 
control population
1; and 
 
ii. A lack of a statistically significant difference in the same measures of the field population 
raised on Bt corn seedlings containing the single PIP and non-Bt corn seedlings. 
 
Or (C): Diet-based bioassays of insect collections from the UXD fields result in two statistically 
relevant comparisons: 
 
i. A statistically significant difference in measures of lethal or sublethal effects 
(growth/development) on diet containing the Bt protein (diagnostic concentration or 
concentration-response measures) between the field population and a relevant 
susceptible control population where available or historical field populations and/or lack 
of a statistically significant difference in measures between field population and a 
resistant positive control population;
1 and 
 
ii. Either a lack of a statistically significant difference in the same measures of the field 
population exposed to diet containing the Bt protein (diagnostic concentration) and diet 
not containing the Bt protein and/or lack of a statistically significant difference in 
measures between the field population and a resistant positive control population, or 
lack of a statistically significant concentration and/or lack of a statistically significant 
difference in concentration response between the field and a resistant positive control 
population.
1 
 
3) Mitigation, as detailed in section e(2)(c) below, is required for any CRW population that 
meets EPA’s resistance criteria above for any of the CRW traits in MON 89034 × MIR162 × 
MON 95275 × MON 88017, unless the circumstances described below are applicable. 
 
a. To minimize the potential for incorrectly reaching a conclusion of resistance, another year 
of CRW adult collections and additional testing is needed to determine resistance if: 
 
i. The results of the bioassays are inconclusive (e.g., the results of the statistical 
analysis are unclear because of low sample sizes); or 
 
ii. Another reasonable explanation for the unexpected damage exists (e.g., high pest 
pressure and/or high plant stress). 
 
b. In these cases, Bayer and EPA will discuss and align on next steps before reaching any 
resistance conclusion. 
 
c. If CRW collections are not possible in the current year or subsequent year due to

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successful management practices, then no further investigation is needed. The population 
would be considered "mitigated" meaning, in this case, that the population is suppressed 
or extirpated for the UXD field. However, EPA recommends that Bayer continue to be 
vigilant in areas where CRW populations were successfully mitigated. 
 
d. If a UXD field receives non-host crop (e.g., soybean) rotation the following year as 
described in Section e(2)(a)(2) above, no additional mitigation is subsequently required. 
 
c) Mitigation of CRW Populations Meeting EPA’s Resistance Criteria 
 
1) For any CRW population found to be resistant to one or more of the CRW traits in MON 89034 × 
MIR162 × MON 95275 × MON 88017 under EPA’s criteria described in section e(2)(b) above, 
Bayer must take the following steps: 
 
a. Bayer must inform EPA of the results of the bioassays as soon as possible, but at least within 
30 days if measures are triggered. 
 
b. The mitigation action area (MAA) is defined as the growers’ farming operation up to a ½ mile 
radius from the damaged site that produced the resistant population. 
 
c. Within 30 days of informing EPA of the results of the bioassays, Bayer must notify state 
extension agents and crop consultants who operate within the county resistance was 
identified. Information shared must include identification of the county in which resistance 
was detected and trait(s) affected. 
 
d. Within the MAA, Bayer must do the following: 
 
i. Prior to finalizing the grower’s seed order for the following season, inform the affected 
grower and other registrants that hold registrations containing the compromised trait(s). 
Bayer must also inform neighboring growers if those growers are customers of Bayer. 
Information shared must include identification of the county in which resistance was 
detected and trait(s) affected; 
 
ii. Discontinue sales/planting of products containing the compromised trait(s) without 
additional/alternative (i.e. non-compromised) CRW traits until resistance has been 
demonstrated to have been mitigated. Other Bt registrants selling such products in the 
MAA are encouraged, but cannot be required, to follow suit; 
 
iii. Bayer must monitor the resistant population in the MAA, as long as grower remains a 
customer of the company, until mitigation has been demonstrated as described in part e. 
below unless otherwise agreed with EPA; 
 
iv. Require any pyramids sold by Bayer containing the compromised trait(s) be planted with 
a 20% refuge until resistance has been demonstrated to have been mitigated. Other Bt 
corn registrants selling such pyramided products in the MAA are encouraged, but cannot

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be required by this term of registration, to follow suit; 
 
v. For Bayer’s affected customer’s field(s), the mitigation goal is to control the resistant 
CRW population. Within the MAA Bayer shall encourage the use of “Mitigation Practices” 
including: 
 
1. Primary option: Rotation to a non-host crop (e.g., soybean); 
 
2. Secondary options: 
 
a. Use of pyramided Bt corn products with different CRW PIP traits; 
 
b. Only in the case that the resistance definition for one of the CRW traits in the MON 
89034 × MIR162 × MON 95275 × MON 88017 is not met, continued use of the 
product with a 20% refuge; 
 
c. Use of different CRW PIP traits (i.e., an alternative CRW- active PIP); 
 
d. Use of non-Bt corn or non-CRW protected corn (with/without soil- applied 
insecticide); 
 
3. Tertiary options: 
 
a. If additional pest management need is determined beyond the secondary options 
listed above, additional CRW control tools (e.g., soil insecticides, seed-applied 
insecticides, chemigation) should be used. 
 
b. Use of foliar applications to control adults (when appropriate economic thresholds 
have been met) may be used in conjunction with one or more of the above; 
 
e. A resistant CRW population in the MAA will be considered mitigated if one of the following 
criteria are met: 
 
i. Corn fields within the MAA are rotated to a non-host crop (e.g. soybean) for one growing 
season. 
 
ii. After implementation of mitigation practices (part d.v. above), resistance monitoring 
(sampling) is conducted but few CRW are found (i.e., <0.1 adults per plant) and 
environmental conditions (e.g., weather) are unlikely to be responsible for the lack of 
adult CRW presence. If environmental conditions are a factor, then monitoring should 
continue for another season. 
 
iii. After implementation practices (part d.v. above), resistance monitoring (sampling) is 
conducted, CRW are found and collected, and bioassays (section e(2)(b)(2) above) show 
that the population susceptibility to the compromised trait(s) has returned to baseline

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OPP Case No. 00659693
 
 
 
levels. 
 
f. The mitigation actions in part d above can be lifted, and growers can resume the use MON 
89034 × MIR162 × MON 95275 × MON 88017 as a primary tool for CRW management in the 
MAA, only when Bayer demonstrates that successful mitigation as described in part e above 
has been achieved. 
 
2) Based on further research to understand CRW resistance to Bt PIPs, EPA will consider 
refinements to the resistance mitigation program. Such research may include characterizing the 
genetics of resistance (e.g., number of genes, functional dominance, mechanism of resistance, 
and cross-resistance) and the biology of resistant insects (e.g., fitness in the presence and 
absence of the product), and other control tactics. 
 
f. Annual Reporting Requirements for MON 89034 × MIR162 × MON 95275 × MON 88017 
 
The following annual reports must be submitted: 
 
1) Compliance Assurance Plan: Compliance Assurance Program activities, including IRM Grower Survey 
results (only for years in which the survey was conducted) and on-farm assessment results for the 
prior year and plans for the compliance assurance program for the current year, on or before January 
31st each year. 
 
2) Insect Resistance Monitoring Results (Cry1A.105, Cry2Ab2, and Vip3Aa20 only): Results of monitoring 
and investigations of damage reports, on or before August 31st of each year. 
 
3) Unexpected Damage Investigations (Cry3Bb1, Mpp75Aa1.1, Vpb4Da2, and DvSnf7.1 only): Activities 
related to investigations of unexpected damage (UXD), including number and location of UXD cases, 
insect sampling, bioassays, and final disposition of UXD fields from the most recent and previous corn 
growing seasons, on or before November 30th of each year. 
 
Should you wish to add/retain a reference to your company’s website on your label, then please be aware 
that the website becomes labeling under FIFRA and is subject to review by the EPA. If the website is false or 
misleading, the product will be considered to be misbranded and sale or distribution of the product is 
unlawful under FIFRA section 12(a)(1)(E). 40 CFR § 156.10(a)(5) lists examples of statements the EPA may 
consider false or misleading. In addition, regardless of whether a website is referenced on your product’s 
label, claims made on the website may not substantially differ from those claims approved through the 
registration process. Therefore, should the EPA find or if it is brought to our attention that a website 
contains false or misleading statements or claims substantially differing from the EPA-approved registration, 
the website will be referred to the EPA’s Office of Enforcement and Compliance Assurance. 
 
Your release for shipment of this product constitutes acceptance of these terms. If these terms are not 
complied with, this registration will be subject to cancellation in accordance with FIFRA section 6. 
 
A stamped copy of the labeling is enclosed for your records. Please also note that the record for this 
product currently contains the following acceptable Confidential Statement of Formula (CSF):

Page 24 of 25 
EPA Reg. No. 524-671 
OPP Case No. 00659693
 
 
 
 
x Basic CSF dated May 15, 2025 
If you have any questions, please contact Stephanie Kelly of my team by phone at (202) 566-0890 or via 
email at kelly.stephanie@epa,gov. 
 
Sincerely, 
 
 
 
 
Alan Reynolds, Product Manager 94 
Emerging Technologies Branch 
Biopesticides and Pollution 
 Prevention Division (7511M) 
Office of Pesticide Programs 
 
 
Enclosure: MON 89034 × MIR162 × MON 95275 × MON 88017 Stamped Label 
Digitally signed by 
ALAN REYNOLDS 
Date: 2026.03.09 
13:42:45 -04'00'

Plant-Incorporated Protectant Label
MON 89034 × MIR162 × MON 95275 × MON 88017 
(OECD Unique Identifier: MON-89Ø34-3 × SYN-IR162-4 × MON-95275-7 × MON-
88Ø17-3) 
Active Ingredients: 
Bacillus thuringiensis Cry1A.105 protein and the geneti c material necessary for its 
production (vector PV-ZMIR245) in corn event MON 89034 (OECD Unique Identifier 
021‘  ” 
Bacillus thuringiensis Cry2Ab2 protein and the geneti c material necessary for its 
production (vector PV-ZMIR245) in corn event MON 89304 (OECD Unique Identifier 
021‘  ” 
Bacillus thuringiensis Vip3Aa20 insecticidal protein and the genetic material necessary for 
its production (via elements of vector pNOV1300) in corn event MIR162 (OECD Unique 
,GHQWLILHU 6<1,5 ” 
Brevibacillus laterosporus Mpp75Aa1.1 protein and the genetic material necessary for its 
production (vector PV-ZMIR525664) in corn event MON 95275 (OECD Unique Identifier 
021 ««««««««««««««««««««««««”
Bacillus thuringiensis Vpb4Da2 protein and the geneti c material necessary for its 
production (vector PV-ZMIR525664) in corn event MON 95275 (OECD Unique Identifier 
021 «««««««««««««««««««««««”
dsRNA transcript comprising a DvSnf7.1 in verted repeat sequence derived from 
Diabrotica virgifera , and the genetic material nece ssary for its production (vector 
PV-ZMIR525664) in corn event MON 95275 (OECD Unique Identifier MON-95275-7)
 ”
Bacillus thuringiensis Cry3Bb1 protein and the geneti c material necessary for its 
production (vector PV-ZMIR39) in corn event MON 88017 (OECD Unique Identifier 
021‘ «««««««««««««««««««««««««” 
Other Ingredients: 
CP4 EPSPS protein (5-enolpyruvylshikimate- 3-phosphate synthase) and the genetic 
material necessary for its production (vec tor PV-ZMIR39) in corn event MON 88017 
2(&' 8QLTXH ,GHQWLILHU 021‘ ««««««««««««««”
03/09/2026
524-671

PMI protein (phosphomannose isomerase) and the genetic material necessary for its 
production (via elements of vector pNOV 1300) in corn event MIR162 (OECD Unique 
,GHQWLILHU6<1,5«««««««««««««««««««««”

*Percentage (wt/wt) on a dry weight ba sis for whole plant (forage) of MON 89034 × 
MIR162 × MON 95275 × MON 88017 plants 
KEEP OUT OF REACH OF CHILDREN 
Caution 
EPA Registration No. 524-ATR 
EPA Establishment No. 524-MO-002 
Bayer CropScience LLC 
700 Chesterfield Pkwy W 
Chesterfield, MO 63017 
U.S.A. 
NET CONTENTS__________ 
DIRECTIONS FOR USE 
It is a violation of Federal law to use this product in any manner inconsistent with its 
labeling. Information regarding commercial production reflected here and in the terms and 
conditions of this registration must be included in the Technology Use Guide. 
This plant-incorporated protectant (PIP) may be combined through conventional breeding 
with other registered PIPs that are simila rly approved for use in combination, through 
conventional breeding, with other registered PIPs. 
MON 89034 × MIR162 × MON 95275 × MON 88017 protects corn crops from leaf, stalk, 
and ear damage caused by lepidopteran corn pests listed on this la bel and root damage 
caused by corn rootworm larvae listed on this label. In order to minimize the risk of these 
pests developing resistance to MON 89034 × MIR162 × MON 95275 × MON 88017 corn, 
an insect resistance management (IRM) plan must be implemented which includes planting 
of a structured refuge.

INSECT RESISTANCE MANAGEMENT 
These refuge requirements do not apply to planting of inbred/hybrid corn seed productions, 
breeding, and small scale research trials on up to a total of 20,000 acres per county and up 
to a combined United States (U.S.) total of 250,000 acres per PIP active ingredient per 
registrant per year. 
Growers are instructed to read information on IRM on the bag and/or bag-tag. 
Several options for deployment of the refuge for MON 89034 × MIR162 × MON 95275 × 
MON 88017 are available to growers. These options are based on the planting of 
MON 89034 × MIR162 × MON 95275 × MON 88017 in cotton or non-cotton growing 
regions and the insect pressure present in those locations. The refuge sizes for these regions 
are either 5% (i.e. 5 acres of non-PIP corn for every 95 acres MON 89034 × MIR162 × 
MON 95275 × MON 88017 corn planted) or 20 % (20 acres of non-PIP corn for every 80 
acres of MON 89034 × MIR162 × MON 95275 × MON 88017 corn planted), and are 
presented in the table below: 
Region Refuge size 
In-field or 
adjacent 
refuge 
Refuge 
separated 
by up to ½ 
mile 
Cotton growing states where CEW is a 
significant pest a nd WCRW, NCRW and 
MCRW are not significant: AR, NC, SC, 
GA, FL, TN (only the counties of Carroll, 
Chester, Crockett, Dyer, Fayette, Franklin, 
Gibson, Hardeman, Hardin, Haywood, 
Lake, Lauderdale, Lincoln, Madison, 
Obion, Rutherford, Shelby, and Tipton), 
AL, MS, LA, and VA (only the counties of 
Dinwiddie, Franklin City, Greensville, Isle 
of Wight, Northampton, Southampton, 
Suffolk City, Surrey, and Sussex) 
20% non-PIP 
corn Yes Yes 
Cotton growing states where CEW is a 
significant pest and WCRW, NCRW 
and/or MCRW are significant: TX (except 
the counties of Carson, Dallam, Hansford, 
Hartley, Hutchinson, Lipscomb, Moore, 
Ochiltree 
Roberts, and Sherman), OK (only the 
counties of Beckha m, Caddo, Comanche, 
Custer, Greer, Harmon, Jackson, Kay, 
Kiowa, Tillman, and Washita), and MO 
20% non-PIP
corn Yes No

(only the counties of Dunklin, New 
Madrid, Pemiscot, Scott, and Stoddard) 
Cotton growing states where CEW is not a 
significant pest a nd WCRW, NCRW and 
MCRW are not significant: NM, AZ, CA, 
NV 
5% non-PIP
corn Yes Yes 
Non-cotton growing states where WCRW, 
NCRW and MCRW ar e not significant: 
OR, WA, ID, MT, WY, UT, VA (except 
the counties of Dinwiddie, Franklin City, 
Greensville, Isle of Wight, Northampton, 
Southampton, Suffolk City, Surrey, and 
Sussex) , WV, PA, MD, DE, CT, RI, NJ, 
NY, ME, MA, NH, VT, HI, AK and TN 
(except the counties of Carroll, Chester, 
Crockett, Dyer, Fayette, Franklin, Gibson, 
Hardeman, Hardin, Haywood, Lake, 
Lauderdale, Lincoln, Madison, Obion, 
Rutherford, Shelby, and Tipton) 
5% non-PIP
corn Yes Yes 
Non-cotton growing states where WCRW, 
NCRW and/or MCRW are significant: KS, 
NE, SD, ND, MN, IA, MO (except the 
counties of Dunklin, New Madrid, 
Pemiscot, Scott, and Stoddard), IL, WI, 
MI, IN, OH, KY, CO, OK (except the 
counties of Beckha m, Caddo, Comanche, 
Custer, Greer, Harmon, Jackson, Kay, 
Kiowa, Tillman, and Washita), and TX 
(only the counties of Carson, Dallam, 
Hansford, Hartley, Hutchinson, Lipscomb, 
Moore, Ochiltree, Roberts, and Sherman) 
5% non-PIP
corn Yes No 
If corn rootworms (CRW) are si gnificant within a region, the structured refuge must be 
planted as an in-field or adjacent refuge using corn hybrids that do not contain PIP 
technologies for the control of corn borers or CRW. The structured refuge can be planted 
as a block within or adjacent (e.g., acro ss the road) to the MON 89034 × MIR162 × 
MON 95275 × MON 88017 field, perimeter strips (i.e., strips around the field), or in-field 
strips. If perimeter or in-field strips ar e implemented, the strips must be at least 4 
consecutive rows wide. The refuge can be pr otected from lepidopteran damage by use of 
non-B.t. insecticides if the population of one or more target lepidopteran pests of 
MON 89034 × MIR162 × MON 95275 × MON 88017 in the refuge exceeds economic 
threshold. In addition, the re fuge can be protected from CRW damage by an appropriate 
seed treatment or soil insecticide; however , insecticides labeled for adult CRW control

should be avoided in the refuge during the period of CRW adult emergence . Economic 
thresholds will be determined using methods recommended by local or regional 
professionals (e.g., Extension Service agents , crop consultants). A schematic of one 
common refuge deployment option is shown below: 
Structured Refuge 
If CRW are not significant within a region, the structured refuge may be planted as an in-
field or adjacent refuge, or as a separate block that is within ½ mile of the MON 89034 × 
MIR162 × MON 95275 × MON 88017 field. The struct ured refuge must be planted with 
corn hybrids that do not contain PIP technologies for the control of corn borers or CRW. 
Economic thresholds will be determined using methods recommended by local or regional 
professionals (e.g., Extension Service agents, crop consultants). A schematic of one refuge 
option with the refuge planted within a ½ mile of the MON 89034 × MIR162 × 
MON 95275 × MON 88017 field is shown below: 
Separated Structured Refuge
MON 89034 × 
MIR162 × 
MON 95275 × 
MON 88017 
Refuge 
Non-PIP corn 
MON 89034 × 
MIR162 × 
MON 95275 × 
MON 88017 
ч ½ mile
Refuge 
Non-PIP corn

Corn Insects Controlled or Suppressed 
European corn borer (ECB) Ostrinia nubilalis
Southwestern corn borer (SWCB) Diatraea grandiosella
Southern cornstalk borer (SCSB) Diatraea crambidoides
Corn earworm (CEW) Helicoverpa zea
Fall armyworm (FAW) Spodoptera frugiperda
Stalk borer Papaipema nebris 
Sugarcane borer (SCB) Diatraea saccharalis 
Beet armyworm Spodoptera exigua
True armyworm Pseudelatia unipuncta
Black cutworm Agrotis ipsilon
Western bean cutworm (WBC) Striacosta albicosta
Lesser cornstalk borer Elasmopalpus lignosellus
Dingy Cutworm Feltia jaculifera
Western corn rootworm (WCRW) Diabrotica virgifera virgifera
Mexican corn rootworm (MCRW) Diabrotica virgifera zeae
Northern corn rootworm (NCRW) Diabrotica barberi 
Sales of corn hybrids that c ontain Bayer’s PIPs must be accompanied by either a grower 
guide or bag tag which includes informat ion on planting, production, and IRM and notes 
that routine applications of insecticides to control these insects are usually unnecessary 
when corn containing the PIPs are planted. 
__________________________ 
MON 89034 × MIR162 × MON 95275 × MON 88017 is a product of Bayer’s research program offering 
unique genetic characteristics for specific grower needs and may be protected by one or more of the following 
U.S. patents that can be found at http://cs.bayerpatents.bayer.com