Modernizing Crop Protection Policy for a New Era of Precision Agriculture

ISSUE:

Federal pesticide frameworks, including the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Pesticide Registration Improvement Act (PRIA), remain essential components of crop protection oversight. These frameworks were developed during an era when field-wide broadcast applications represented the dominant delivery method. Risk assessments naturally reflected those realities.

Today, ultra-high precision agriculture technologies create conditions dramatically different from traditional broadcast systems:

·       Products can be applied to specific plants and plant groups rather than entire fields.

·       Artificial intelligence systems can distinguish plant species, sizes and relative location in the field.

·       Off-target exposure may be reduced substantially or eliminated.

·       Total chemical volume may be significantly lower.

·       Drift and unnecessary application can decline significantly (Drift can even be neglected if a spray is done under a hood).

When application methods fundamentally change, exposure assumptions should be revisited. Regulations should evolve alongside technological capabilities.

Agriculture has improved and changed faster than regulation.

American Agri-Women Request:

Technologies of ultra-high precision application represent a unique opportunity to expand agronomic solution options while responding to the growing societal and regulatory demand for greener and more sustainable agricultural practices. They offer a rare possibility to reconcile productivity, environmental stewardship, public health concerns, and agricultural viability. 

To fully realize this potential, regulatory frameworks should take these technologies into account when evaluating and defining product labels. Precision-targeted applications substantially reduce the total volume of product required, lowering environmental load and reducing the risk of unnecessary residues leaching into soil and water systems. In addition, highly targeted applications can significantly reduce — or in some cases eliminate — residues on harvested products.

Legislation should consider adapted regulatory pathways for precision application technologies, including the possibility of higher permitted application rates within ultra-targeted spraying systems, as well as the reassessment of certain active ingredients for

crops where their use was previously restricted, prohibited, or never registered under conventional broadcast application assumptions due to lack of crop safety.

Congress and regulatory agencies should:

1. Maintain science-based regulatory frameworks under EPA authority.

2. Support timely PRIA and FIFRA reauthorization.

3. Encourage regulatory consideration of precision application technologies during risk assessments.

4. Evaluate how AI-assisted systems alter exposure assumptions and application realities.

5. Revisit historical restrictions where modern technologies create materially different use conditions.

6. Support expanded research into precision agriculture and crop protection outcomes.

7. Preserve broad producer access to crop protection tools while encouraging innovation that reduces overall use.

8. Ensure labels and guidance evolve alongside modern technologies.

Background:

Agriculture is entering a new era where advances in artificial intelligence, machine vision, robotics, and precision application systems are fundamentally changing how crop protection products are used. Historically, agricultural chemical regulations were developed around broad-acre application methods designed decades ago. Regulatory assumptions reflected technologies that treated entire fields uniformly, regardless of if the target was crop, weed, or soil. A chemical molecule was either unselective or selective on certain crops, this inherent selectivity was purely determined by the chemical properties of the molecule and its mode of action in the plants. Today, precision technologies challenge that model.

Modern systems can be trained and programmed to identify and target individual plants or plant groups in real time, distinguishing not only broad botanical classifications (such as narrow-leaf versus broadleaf species), but also specific plant categories and species (e.g., crops versus weeds), plant size, growth stage, spatial location, and other visual characteristics.

Based on these parameters, products can be applied precisely and with a selectivity that goes far beyond the inherent selectivity of a molecule to the intended target. These advances have the potential to dramatically reduce overall chemical use while preserving the effectiveness of crop protection tools and maintaining farmer access to critical production inputs. In addition, they can help reduce environmental pollution by minimizing unnecessary soil residues that may leach into water bodies, contributing to both environmental degradation and potential human and ecosystem health concerns.

Furthermore, the new AI-based selectivity of molecules can do what was only a few years ago impossible, to turn a non-selective molecule into a selective one. This opens complete new potential use cases of formerly non-usable herbicides in crops that are not chemically/metabolically resistant to them. By this for example less toxic non-selective organic herbicides can be used selectively in lettuce or broccoli. Or resistant weeds can be fought with so far non available (due to non-selectivity) modes of actions in cotton.

Modern ultra-high precision application technologies have demonstrated crop protection products reductions approaching 90% or more compared with traditional broadcast applications in certain use cases. For example, targeted applications of glyphosate onto identified weeds rather than blanket field applications can dramatically reduce total chemical use while maintaining weed control effectiveness. That kind of reduction should be viewed as an opportunity.

Predictable and timely regulatory pathways matter. Innovation slows when approvals, amendments, or evaluations cannot keep pace with technological advancement. While regulatory rigor remains essential, review systems should be equipped to evaluate technologies evolving faster than traditional policy assumptions. Artificial intelligence, machine vision, and precision application systems are changing not only what products are used, but how they are used. As agriculture enters an era of AI-assisted crop management, regulatory systems should be prepared to evaluate evolving methods of application in addition to products themselves.

Political pressure, public perception, and social trends should not replace scientific analysis. This principle becomes increasingly important as public debates surrounding agricultural chemistry become more polarized. Precision agriculture technologies create opportunities to generate entirely new datasets around exposure, drift, residue, and application behavior. Data generated under modern conditions can help policymakers make informed decisions that reflect how agriculture operates today in real time.