If you apply pesticides in agricultural settings, you are likely aware of the strategies the EPA has developed to comply with the Endangered Species Act (ESA). The EPA has already finalized strategies for agricultural herbicides and insecticides, and several agricultural pesticides now include the new ESA label requirements. Be sure to read John Schepis's recent blog post Understanding new ESA label requirements for the 2026 Illinois spraying season for more information.
Agricultural fungicides are next on the EPA's list. The EPA recently released its Draft Fungicide Strategy to Reduce Exposure of Federally Listed Endangered and Threatened Species and Designated Critical Habitats from the Use of Conventional Agricultural Fungicides. The draft fungicide strategy and related documents can be accessed through regulations.gov by searching for docket EPA-HQ-OPP-2026-2973
The fungicide strategy uses the same framework as the finalized herbicide and insecticide strategies to assess possible population-level impacts to listed species and identify mitigation measures to reduce the potential impacts from the use of agricultural fungicides. If you are looking for more information on the finalized ESA strategies, check out our articles on the herbicide strategy, insecticide strategy, and online ESA tools, or visit the ESA mitigation menu website.
The EPA is seeking comments related to the draft fungicide strategy. They are especially interested in the following notable differences to the existing herbicide and insecticide strategies:
- The draft fungicide strategy evaluates listed vertebrates (e.g., birds, mammals) that may be on agricultural fields and which consume contaminated dietary items, including treated seeds.
- The herbicide and insecticide strategies did not evaluate on-field vertebrates.
- The herbicide strategy did not assess potential impacts from treated seeds.
- The insecticide strategy only assessed potential impacts from runoff/erosion exposure from treated seeds.
- The draft fungicide strategy proposes to expand spray drift adjuvants as a mitigation option:
- Expand oil emulsion adjuvants for use with insecticides and fungicides as opposed to only with herbicides.
- Add guar gum spray drift adjuvants as an option for fungicides, insecticides, and herbicides at specified minimum rates and spray volumes.
- The draft fungicide strategy incorporates usage data on acres treated with fungicides. Because of the more regional pattern of fungicide usage, the incorporation of usage data served to identify listed species where mitigation may be applicable for fungicides.
You can submit comments via the docket through July 20, 2026. This deadline is not likely to be extended because the EPA has set a goal of finalizing the fungicide strategy by Fall 2026.
Photo credit: JJ Gouin, Adobe Stock
ABOUT THE AUTHOR: Travis Cleveland provides subject matter expertise and training in pesticide safety with an emphasis on plant pathology. He provides diagnostic support the U of I Plant Clinic and he coordinates the Home, Yard and Garden Pest Newsletter.