On April 29, 2025, the Environmental Protection Agency (EPA) released the final version of its Insecticide Strategy, marking a significant step in the agency’s ongoing effort to balance pesticide regulation with endangered species protection. This strategy is the latest component of EPA’s broader initiative to revise how it meets its Endangered Species Act (ESA) responsibilities while managing pesticide use under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
The final Insecticide Strategy aims to reduce pesticide exposure to protected wildlife by implementing mitigation measures to curb spray drift and runoff. This approach mirrors the final Herbicide Strategy released last September, which also focused on minimizing pesticide impacts on listed species. However, the Insecticide Strategy is not self-implementing. Instead, the mitigation measures identified will gradually appear on pesticide labels as new products are approved and existing ones come up for registration review. Farmers and pesticide applicators can expect to see these changes on insecticide labels in the near future, although full implementation will take years.
The EPA’s new policy to address pesticide exposure to ESA-protected species was first announced in April 2022. The agency published a work plan outlining its intentions to create strategy documents for herbicides, insecticides, fungicides, and rodenticides. This initiative was driven by a “decades-old challenge” to satisfy both ESA and FIFRA obligations, as well as to reduce legal challenges from environmental groups.
The ESA, enacted in 1973, requires all federal agencies to consult with the U.S. Fish and Wildlife Service to ensure their actions do not jeopardize protected species. The EPA, which takes numerous actions under FIFRA each year, has historically struggled to fully satisfy these consultation responsibilities. This has led to numerous lawsuits and settlement agreements, with the EPA currently working to complete consultations into the 2030s.
To better protect endangered wildlife and create more robust pesticide labels, the EPA has adopted a new approach. It has sorted all registered pesticides into broad groups and developed mitigation measures for each to reduce pesticide exposure via spray drift and runoff or erosion. The final Insecticide Strategy outlines these measures, focusing on protecting invertebrate species listed under the ESA.
The strategy employs a three-step framework to determine additional mitigation measures for insecticide labels. First, the EPA establishes the likelihood of population-level impacts on protected species. If impacts are deemed low, medium, or high, additional mitigation measures are assigned accordingly. Second, the EPA determines which mitigation measures to apply, relying on buffer zones and specific application equipment to reduce spray drift. The largest buffer zone identified is 300 feet for aerial applications, with others being 100 feet or less. To reduce runoff and erosion, the strategy offers a menu of mitigation options, each assigned a point value based on efficacy. The number of points required depends on the degree of population-level impacts identified.
The EPA has also assigned counties different mitigation points based on their runoff potential, with counties having very low runoff potential receiving the most points. This approach ensures that mitigation measures are tailored to specific geographic areas, enhancing their effectiveness.
While the final Insecticide Strategy represents a significant step forward, its full impact will be seen over the coming years as mitigation measures are incorporated into pesticide labels. Farmers and pesticide applicators will need to stay informed and adapt to these changes to ensure compliance and protect endangered species. The strategy is a testament to the EPA’s commitment to balancing agricultural needs with environmental conservation, paving the way for more sustainable and responsible pesticide use.