The garden industry body is broadly supportive of the strategy in that it identifies the need to gather more scientific evidence on the numbers and behaviour of the many types of bees, moths, butterflies and other pollinators, to better understand the roles they play and the threats they face.
HTA horticulture head Raoul Curtis-Machin said: "We have suggested that researching alternatives to neonicotinoids should be a top priority because many gardeners want to plant pollinating flowers.
He added: "However, without neonicotinoids in horticultural production, our gardeners are also treated to pots full of vine weevil grubs and bitten leaves.
In its submission Curtis-Machin said the HTA "also makes the point that protected horticultural production should not be ignored because many glasshouse crops - strawberries for example - use managed hives of bees which they place in the glasshouse."
The HTA says there is a danger that banning neonicotinoids outright might push farmers into using broad-spectrum pyrethroids as the next best thing, which may potentially be far worse for bees and pollinators.
The Defra National Pollinator Strategy for bees and other pollinators in England sets out proposals to safeguard bees, given their role in pollinating many food crops and wild plants, and their contribution to food production and environmental diversity.
In 2013, The EC imposed a two-year moratorium on neonicotinoid use, citing bee health as the reason.
Also commenting on the consultation, Bayer Garden attempted to assuage campaigners' fears over neonicotinoids.
Bayer CropScience communications and government affairs manager Dr Julian Little said: "It is a shame that the debate around bee health has focussed on the impact of pesticide use rather than the real issues of nutrition, and bee pests and diseases.
"Retailers of garden care products need to understand the issues so they can address consumers’ concerns when questioned at the fixture and dispel the myths and mis-information."
Researchers into bee health have identified a complex interaction of factors as the causes for the decline. These include the Varroa mite, diseases including Nosema, a lack of food, low genetic diversity, queen bee failure and changing weather patterns.
Little added: "To address bee health the focus should be on tackling the real challenges they face. At Bayer we have invested in two Bee Care Centres and have been working on research projects to promote the health of bees and other pollinators as well as state-of-the-art product stewardship for nearly 30 years.
"One of our most recent developments is the Varroa gate. An innovative front door inspired by tick collars worn by dogs and cats, the gate releases a treatment that kills the mite on the bee and so stops the hive from becoming infected."
Bayer Garden’s Provado insecticide products contain thiacloprid, a new generation insecticide.