In our last issue, I wrote an update about the new label requirements on herbicides, based on the Herbicide Strategy that the Environmental Protection Agency (EPA) released in 2024 to comply with the Endangered Species Act (ESA). Pesticide products going through registration or re-registration will have to comply with the ESA and have requirements on their labels when using that specific product to prevent off-target movement and prevent harm to a species, or a species’ critical habitat, that is listed as threatened or endangered. The recent new label language is a result of several lawsuits from environmental non-governmental organizations (NGOs) who sued the EPA for failing to consult with the U.S. Fish and Wildlife Services (USFWS) and National Marine Fisheries Service (NMFS) on pesticides’ interaction with listed species. Therefore EPA will have specific language on each pesticide label on how to comply with ESA, through runoff/erosion mitigation points and spray drift buffer distance requirements when using the product.
A draft insecticide proposal was released in July 2024. After 26,000 comments were received on the proposal, the EPA made several changes, which were reflected and outlined in the final Insecticide Strategy, which was released in April 2025. The agriculture community made its voice heard and asked the EPA to take a more science-based, practical approach when developing the final strategy. Examples of the changes include reduced spray drift distances, increased mitigation points for sandy soils, and the insecticide strategy options are in effect for herbicides, too. Mitigation points are available for growers participating in conservation programs such as the USDA Natural Resource Conservation Services (NRCS) Environmental Quality Incentives Program (EQIP) or the Conservation Stewardship Program (CSP) Pest Management Conservation System (595) plans.
Thankfully, the EPA made the changes above; however, there are additional opportunities for long term improvements to be made. EPA is working on adding more mitigation practices to the mitigation menu that are economic to implement. Another long-term improvement is the risk assessment evaluation approach EPA takes to determine if a species is at risk and the development of species maps.
To recap, we will see ESA language on insecticide labels come up for re-registration or as new products go through the registration process. In May, the EPA proposed the new active ingredient (AI), isocycloseram, for registration. Isocycloseram manages white grub, wireworm, seed corn maggot and corn rootworm insect pressure in field corn and will manage insect pressure in cotton, vegetables and cereals. The EPA is accepting public comments until June 10 on the proposed registration of isocycloseram. If registration is granted, EPA will finalize its biological evaluation of the new AI, and if a listed species or critical habitat of a listed species could be affected by isocycloseram, the EPA will begin the ESA consultation proves with USFWS.
After the Herbicide Strategy was released, Liberty Ultra was registered, and we saw ESA requirements on the label. Now that the insecticide strategy has been finalized, I anticipate new insecticide products will be going through the registration process to increase.
At Missouri Soybeans, we will continue to provide updates and guidance on how to stay in compliance. We will work with stakeholders to advocate for science-based, common-sense approaches when determining implementation in the field.
