NPTA Response (2025)

 

The NPTA’s survey evidence, which was collated from surveying 188 pest controllers, provides a clear insight which demonstrates that there is currently no suitable alternative to SGARs. Restricting them would undermine public health, escalate costs, reduce welfare outcomes, and weaken the UK’s resilience against rodent-borne threats.

 

This conclusion is independently supported by the Analysis of Alternatives (2024), submitted during the EU’s anticoagulant renewal process, which found that while alternatives such as cholecalciferol, alphachloralose, phosphine gas, and traps may contribute to integrated pest management, none can match SGARs for consistency, scalability, or reliability in real-world rodent control.

 

1. Necessity of AVKs in Professional Pest Control

Survey results confirm that 96.2% of respondents had to use SGARs because no other management method was effective or lowered the risks.

This demonstrates that SGARs are not a matter of convenience but essential interventions where alternatives fail. Importantly, these decisions are guided by site-specific risk assessments:

• In domestic settings, SGARs may be required to ensure rapid control where infestations pose a risk to families.
• In commercial food premises, SGARs provide the reliability needed to maintain compliance with hygiene and audit standards.
• In public infrastructure (e.g. drains, transport, utilities), SGARs are often the only viable option to prevent escalation of infestations.

Without SGARs, pest controllers would face treatment failures in critical locations, undermining both public health and food safety.

 

2. Resistance Issues

Survey evidence highlights the scale of the resistance challenge:

• 62.2% reported behavioural resistance.
• 47% have encountered rodenticide resistance, while 43.8% reported no resistance. 9.2% were unsure if they have encountered this.

Bait avoidance and behavioral resistance is a real and growing issue, making chemical diversity critical. Restricting the range of SGARs available would increase reliance on actives with limited palatability resulting in a potential increase in bait avoidance, reducing efficacy and raising public health risks.

In practice, current resistance means:

• Bromadiolone and difenacoum are often ineffective in regions with well-documented resistance strains.
• Professionals must therefore have access to single feed SGARs (brodifacoum, flocoumafen, difethialone) to achieve control.
• Equally, accessibility to active ingredients such as bromadiolone and difenacoum are vital when baiting in areas where single feed baits or cholecalciferol may be too hazardous.
• Without this flexibility, infestations would last longer, spread further, and require more site visits — increasing cost, resistance pressure, and environmental impact.

 

3. Why Professionals Choose Specific Actives

Survey data confirms that product choice is risk-based, site-specific, and professional:

• Bromadiolone: palatability (78.5%) and affordability (37.5%).
• Brodifacoum: resistance management (60.6%) and palatability (60%).
• Flocoumafen: chosen where resistance management is present (61.2%).
• Difethialone: palatability (51.4%) and resistance (51.4%).
• Difenacoum: palatability (72.6%) and affordability (42.2%).

This shows that professionals weigh efficacy, resistance, safety, affordability, and non-target risk when selecting actives.

Different actives are matched to different location requirements:

• High-resistance sites demand single feed SGARs.
• Open area use and secondary poisoning risks drives the use of cholecalciferol.
• Cost-sensitive contracts (e.g. local authorities) rely on affordable actives like bromadiolone and difenacoum.

This layered, professional decision-making is precisely what stewardship is designed to achieve — and it depends on the full toolbox of SGARs remaining available.

 

4. Range of Active Use in Professional Practice

Survey results clearly demonstrate that UK pest professionals rely on a wide range of active substances rather than a narrow set of products.

Active Substance	% of Respondents Using
Brodifacoum	89.20%
Cholecalciferol	80.50%
Bromadiolone	77.80%
Difenacoum	73.00%
Difethialone	37.80%
Flocoumafen	36.20%
Coumatetralyl	36.80%
Alphachloralose	41.10%

This spread shows that professionals are drawing on all available actives to match control strategies to site-specific needs such as resistance management, non-target risk, and environmental conditions. Importantly, it evidences that decisions are not being made out of habit or convenience but as part of a conscious, risk-based approach under the stewardship framework.

The data further highlights the depth of this toolbox approach: 80.5% of respondents reported using three or more actives, and nearly three-quarters (72.4%) use four or more. Almost half (49.2%) use five or more actives, while one-third (33.5%) use six or more. Notably, 19.5% of pest controllers reported using seven actives, and 13.0% use all eight.

This breadth of use underscores that professional rodent control in the UK depends on maintaining access to the full range of SGARs and non-anticoagulant alternatives. Restricting SGAR availability would undermine this diversity, reducing practitioners’ ability to tailor solutions and weakening the stewardship-driven balance between efficacy, safety, and sustainability. Crucially, it also demonstrates that pest controllers are making informed, risk-based choices, selecting actives not out of habit, but in response to resistance pressures, site-specific risks, and welfare considerations.

 

5. Formulations in Practice

Survey results show broad reliance on multiple bait formulations:

• Grain – 88.1%
• Wax blocks – 79.5%
• Pasta – 62.7%
• Gel – 43.2%
• Foam – 28.6%
• Liquid – 7.0%

This diversity ensures professionals can adapt to different environments and rodent behaviours.

Different formulations are essential for different locations:

• Grain is often used on rats, where block or solid baits are often avoided.
• Wax blocks are critical in damp or external environments where weatherproofing is required.
• Pasta provides an oily, highly palatable option for locations with strong food competition.
• Foam and gel formulations are particularly useful in cavities, drains, inaccessible areas and areas where bait avoidance is present.

Restricting SGARs would significantly reduce treatment flexibility, making it harder to match formulation to location, and ultimately undermining the effectiveness of rodent control.

 

6. Animal Welfare and Safety

Survey data confirms that welfare and safety considerations are central to professional pest management:

Pest controllers are not making choices out of habit or convenience — they are weighing up the risks of each active and formulation based on site-specific conditions. This includes assessing factors such as the likelihood of non-target exposure, the presence of pets or livestock, and the welfare outcomes of different control methods.

Professionals reported that their choice of products is influenced by factors such as:

• Secondary poisoning risk to non-target species.
• The need for rapid control in sensitive environments.
• Palatability and effectiveness where resistance is present.
• The balance between efficacy, affordability, and animal welfare outcomes.

This evidence shows that stewardship is working as intended. Pest controllers are already applying a risk-based approach, reserving SGARs for when they are necessary, using alternatives when appropriate, and prioritising welfare in their decisions.

• Survey evidence confirms that professionals consider secondary poisoning risk when choosing actives, and that this risk is a recognised and influential factor in product choice. Pest controllers are weighing this alongside resistance management, palatability, and affordability. While the survey data does not map directly onto toxicological rankings, it demonstrates that professionals are actively factoring non-target safety into their decision-making. This supports the conclusion that stewardship is working as intended, with informed, risk-based choices being made rather than convenience-driven or habitual use.

Active	% citing secondary Poisoning*	Dog LD₅₀ (per kg)**
Difenacoum	19.3%	200g
Bromadiolone	15.3%	200g
Flocoumafen	10.4%	1.5g
Brodifacoum	7.3%	5g
Difethialone	7.1%	160g

• * The % citing secondary poisoning risk comes from the NPTA member survey (2025). **Toxicological LD₅₀ values (dogs per kilo) has been provided by BASF        

• Insight: The most toxic SGARs for pets (brodifacoum, flocoumafen) are also those least often selected for secondary poisoning risk (7.3–10.9%). Meanwhile, actives with higher LD₅₀s (difenacoum, bromadiolone) are chosen more often (15–19.3%). This shows professionals are consciously avoiding the most hazardous actives in high-risk, pet-sensitive environments and applying alternatives where a heightened risk through secondary poisoning to non-target animals exist.
• Professionals also weigh non-target safety, with 42.3% citing cholecalciferol, 38.9% bromadiolone, and 28.9% difenacoum as examples of where this risk influenced their choice.

 

7. Economic Implications

Survey evidence and field experience highlight the economic challenges of relying on alternatives to SGARs. While product purchase prices vary, the practical cost of control is driven by efficacy, application rates, and labour:

• Baiting efficiency: SGARs typically achieve control more rapidly and with fewer repeat applications. Thereby potentially having a lower environmental profile due to the shorter practical baiting time. By contrast, alternatives such as cholecalciferol may require longer treatment times, while alphachloralose is limited to mice indoors. This can increase the number of visits needed to achieve effective control in practice.
• Traps: Although reusable, traps become labour-intensive in medium to large infestations. Each unit must be set, checked, and reset, which increases professional time on site. For small populations they may be cost-neutral, but at scale the labour requirements outstrip baiting efficiency.
• Carbon and fuel context: Every additional visit adds travel, fuel use, or vehicle emissions, even where fleets are partly electric. A control programme requiring twice the number of visits has a clear environmental and cost impact compared to one resolved in fewer site attendances.
• Affordability: was cited by only 4% for cholecalciferol, compared with 37.5% for bromadiolone and 42.2% for difenacoum.

In summary, while some alternatives may be cheaper per unit or in very specific scenarios, survey data confirms professionals regard SGARs as the most reliable and cost-effective backbone of rodent control at national scale, with alternatives typically used to complement rather than replace them.

 

Trapping as an alternative:
While trapping is sometimes proposed as a substitute for SGARs, its economic and practical limitations are significant:

• Once a trap is activated, it no longer delivers value until it is reset or replaced.
• Large infestations require multiple traps, regular checking, and frequent re-setting.
• This incurs substantial labour costs, travel costs, and additional carbon emissions compared to the efficiency of well-managed SGAR baiting.

Cost of professional time:
Recent analysis by the NPTA shows that the true cost of a professional pest controller is £50–£65 per hour in reference to rodent treatments before profit margin is added.

• Factoring this in, the cost of deploying and monitoring traps rapidly exceeds the cost of SGARs (NPTA, 2025).
• For businesses, local authorities, and households, this translates to significantly higher service bills and reduced capacity to control rodent outbreaks effectively (NPTA, 2025).

This demonstrates that while traps may have a role in integrated pest management, they cannot replace SGARs as an alternative to a affordable, scalable, and sustainable rodent control.

 

8. Stewardship and Best Practice

Survey data demonstrates that stewardship is embedded in daily practice:

• Bromadiolone: palatability (78.5%) and affordability (37.5%).
• Brodifacoum: resistance management (60.6%) and palatability (60%).
• Cholecalciferol: overwhelmingly selected for reduced secondary poisoning risk (75.2%),

These patterns show that professionals make risk-based, not habitual decisions, weighing risk, resistance, and welfare alongside cost.

The strong weighting towards risk reduction confirms that stewardship is working. Restricting AVKs would undermine this model, removing the ability to match actives and formulations to site-specific conditions.

The UK Rodenticide Stewardship Regime which is coordinated and led by CRRU UK: All professional use of SGARs in the UK is governed by the (CRRU) UK Code of Best Practice: Best Practice and Guidance for Rodent Control and the Safe Use of Rodenticides (July 2024) and the wider UK Rodenticide Stewardship Regime. This framework requires:

• • Mandatory training and certification for professional users.
  • Site-specific risk assessments before treatment.
  • Site-specific environmental risk assessments before baiting
  • Careful consideration of non-target risks and application of integrated pest management (IPM) principles.
  • Limitation of baiting to the minimum necessary duration and quantity, with removal of bait after control is achieved.

Survey evidence confirms that these requirements are not only understood (CRRU, 2024; HSE, 2022) but actively applied by pest professionals in the field. Pest controllers are already choosing actives based on risk profiles, avoiding SGARs where non-target risks are high, and turning to alternatives such as cholecalciferol or alphachloralose when appropriate.

This shows that the stewardship framework is functioning exactly as intended: SGARs are reserved for when they are necessary, alternatives are used and decisions are guided by risk assessment rather than convenience.

 

9. Environmental Balance

All rodent control methods carry risks, but SGARs sit within a robust stewardship framework that manages those risks effectively. Alternatives are not risk-free:

• Cholecalciferol – no antidote is available, and accidental exposures in pets can be difficult to treat, making it a concern in pet-sensitive environments as well as being a endocrine disrupter.
• Traps – often require repeat visits, increasing carbon emissions and labour costs, and raise welfare concerns where instant kill is not achieved.
• Glue boards – widely regarded as carrying high animal welfare impacts.

SGARs, when used under stewardship, represent the best balance (CRRU, 2020) between efficacy, safety, environmental protection, and welfare outcomes.

 

Conclusion

The combined evidence from the NPTA survey and decades of frontline practice demonstrates that SGARs are irreplaceable in safeguarding public health, food security, animal welfare, and infrastructure in the UK. This conclusion is independently supported by the Analysis of Alternatives (2024), which found that no current alternatives can provide the breadth, scalability, or sustainability required at national level.

• Public health: Without SGARs, rodent-borne diseases such as leptospirosis, Salmonella, and hantavirus are likely to rise, alongside food contamination and property damage.

• Animal Welfare
  SGARs provide rapid and predictable control, reducing prolonged suffering in target animals. Alternatives such as traps may raise welfare concerns when death is not instantaneous, and sticky boards are now highly regulated for the same reason.
• Risk & Safety
  SGARs have the safeguard of an antidote (vitamin K1), which makes accidental exposures more manageable in many cases. However, some SGARs remain highly toxic to wildlife through secondary poisoning. Cholecalciferol, by contrast, reduces secondary poisoning risks to wildlife but has no antidote and presents serious risks in pet-sensitive environments, where treatment outcomes are uncertain even at low exposures.

• Economics: Alternatives are up to five times more costly. Survey evidence confirms cholecalciferol is chosen almost exclusively for non-target safety (75.2%) rather than affordability (4%). SGARs remain the backbone of effective, affordable rodent control.
• Resistance: Nearly half of surveyed professionals encounter rodenticide resistance. Maintaining chemical diversity through SGARs is essential to prevent treatment failures.
• Stewardship and environmental balance: The UK Rodenticide Stewardship Regime which is coordinated and led by CRRU UK. Ensures that SGARs are used responsibly and proportionately, with mandatory training, risk assessments, and IPM requirements in place to minimise non-target exposure and environmental impact. Alternatives can have an important role in certain contexts, but they do not yet provide the same breadth, consistency, or scalability. This is why maintaining access to SGARs under stewardship is essential not because they are without risk, but because they remain the only tools capable of delivering reliable control across all environments.
• Balanced outcomes: SGARs, when used under stewardship, remain the only tools that combine efficacy, affordability, and the safeguard of an available antidote. This allows professionals to deliver effective rodent control while still prioritising welfare and non-target safety.
• Availability: Alternatives are few, restricted, and vulnerable to supply disruption. SGARs are available across multiple active substances and formulations, supported by robust supply chains.

• Limits of physical alternatives: Traps, proofing, and habitat management are all important elements of integrated pest management and strengthen long-term prevention. However, the evidence shows they cannot replace SGARs. Traps are labour-intensive, costly, and raise welfare concerns; proofing is often impractical in complex or older buildings; and habitat management reduces risk but cannot eradicate established infestations. These measures are best seen as supporting tools, effective only when combined with SGARs as the backbone of professional rodent control.
• Informed professional practice: Survey data shows pest controllers are using a wide range of actives, with over 80% using three or more to tailor solutions to site-specific conditions. This confirms that decisions are informed, risk-based, and stewardship-led, not habitual. Restricting SGARs would narrow this professional toolbox and undermine the industry’s ability to deliver effective, safe, and sustainable rodent control.

Restricting SGARs could lead directly to longer lasting and more widespread infestations, poorer welfare outcomes, and heightened risks of disease transmission. Costs would rise sharply for households, local authorities, and businesses, with smaller pest control companies most severely affected.

For these reasons the NPTA, representing nearly 1,100 pest control companies and almost 3,000 professional technicians, strongly urges the HSE to retain professional access to the full range of SGARs. Their continued availability, under stewardship, is the only way to balance efficacy, safety, affordability, and sustainability in professional rodent management.  

 

REFERENCES

NPTA & Industry Evidence

• NPTA Response (2025).
• BASF (2023). UK Farmer Rodent Control Survey – reference Link

• Direct Line Group (2025). Councils carry out 291,000 pest control visits in 2024 – 91% were rodent related. Reference Link
• Pest Magazine (2025). Rentokil sees an increase in reported rodent activity in Q4 2024 compared to Q3 2024. Reference Link
• Drain Detectives (2025). UK’s rodent problem: FOI data reveals the biggest hotspots for rat infestations since 2023. Reference Link

— see also national press coverage: The Independent (2025). Reference Link

• Rentokil (2023). PestConnect White Paper– includes “£12 billion” estimate for UK business impact. Reference Link

UK Regulation & Stewardship

• CRRU (2020). Code of Best Practice Reference Link
• CRRU (2024). Rodenticide Stewardship Annual Report. Reference Link
• HSE Guidance on the Use of Rodenticides in the UK. Reference Link

Independent Scientific Evidence

• DEFRA (2022). Understanding & Evaluating On-farm Loss and Waste in the UK. Reference Link

Supplementary documents

• Analysis of Alternatives (2024). Submitted during EU AVK rodenticide approval process.
  Download
• Report CEPA 2023 Survey of Prof.Technicians Final.
  Download
• CEPA IPM Guidelines-EN.
  Download
• EU-BPR Active Substances CEPA Statement.
  Download

 

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