"These 'emergency authorisations' are supposed to be granted only under exceptional circumstances but, at the rate in which they're being dished out, it would seem that for some countries exception has become the rule," Doug Parr, the chief scientist at Greenpeace UK, said.
"On average, permission has been granted for the use of these deadly pesticides somewhere across Europe every other week."
Bayer told Greenpeace that continued use of exemptions was evidence that farmers had no other options. The company has had six authorisations granted in its own name.
The National Farmers Union in the UK has joined with Bayer in a legal challenge to the ban, arguing that the EU did not do a sufficient cost-benefit analysis.
Neonicotinoids have also been linked to declines in migratory songbirds and to the collapse of aquatic ecosystems.
Last year, scientists blamed them for wiping out plankton and fish in a Japanese lake in the 1990s.
Sixteen EU member states have issued at least one authorisation since April 2018, Greenpeace found. Belgium issuing the most, with 14, followed by Romania, with 10 authorisations, and Poland with nine.