Tighter restrictions for over-the-top dicamba

BLOOMINGTON, Ill. — Federal and Illinois guidelines for over-the-top dicamba applications on soybeans have been set for the 2026 and 2027 growing seasons.

Kevin “KJ” Johnson, Illinois Soybean Association director of government relations and strategy, joined Kelsey Litchfield, ISA agronomic outreach manager, in a recent Field Advisor podcast to discuss the regulations.

The U.S. Environmental Protection Agency called the new registration its “most restrictive label requirements in the agency’s history,” reducing allowable application rates and adding expanded restrictions related to volatility reduction agents, temperature-based application limits, conservation practices and recordkeeping.

Litchfield: The U.S. EPA called this the strongest restrictions in agency history. So, this is not something to be taken lightly.

Johnson: That is correct. They never had anything like forecast high temperatures or anything like that before. This is the first time we’ve ever seen more of a buffer (a downwind spray buffer of 240 feet is required) and where they put on a restriction on how much active ingredient you can use going forward. I would agree with them that this is the most restrictive U.S. EPA has been on dicamba for over-the-top use.

Litchfield: EPA says that’s based on farmer input, scientific review and legal scrutiny. Would you see it the same way?

Johnson: Yes, they are definitely hearing from farmers. I know when EPA got the comments from farmers, there were a lot of unique comments, not just copy-and-paste responses.

There’s a lot of farmers that said, “We want to use it, but we also know there probably should be restrictions.”

Again, it’s the furthest they went on dicamba since we started using it over the top in 2017. Dicamba goes back many years, but over-the-top use started in 2017.

Litchfield: Let’s talk about Illinois specifically. We have the federal guidance and how does all that work along with the state guidance?

Johnson: The federal is the base label. The state cannot do anything less than the base label. The state can do more restrictions than the federal label.

In current Illinois rules, over-the-top dicamba applications on soybeans are prohibited if the air temperature at the field exceeds 85 degrees or if the National Weather Service forecasted high temperature for the nearest available location exceeds 85 degrees on the day of application.

That means if you load your sprayer and it is 78 degrees at 10 a.m. and the forecast high by the National Weather Service is supposed to be 85 or 86, that is a do-not-spray day.

Applications in Illinois cannot be made after June 20. Prior to an application in Illinois, applicators must consult the FieldWatch Sensitive Crop Registry and comply with all related recordkeeping and label requirements.

Dicamba applications are prohibited if the wind is blowing toward an adjacent Illinois Nature Preserves Commission site or toward an adjacent residential area. Information on Nature Preserve and Land and Water Reserve sites is available through the Illinois Nature Preserves Commission directory.

Litchfield: I’ve read some articles about how companies are reacting to the new dicamba label. Have you heard any more company reaction to this?

Johnson: All the big three — Bayer, BASF, Syngenta — have been supportive of some kind of a label. Did they think there was going to be more restrictions? Absolutely. I think there was a lot of conversations with EPA last summer about even getting approval, because we did not have dicamba for over-the-top use last year.

There’s been many conversations. What I’ve gotten from most of the chemical companies is they just wanted to see some kind of over-the-top label, even if there was more restrictions, but at least have the option for over-the-top use.

I am seeing a lot more guys using it as a burndown-type product and then maybe use it as an over the top. With how some of the traits are stacked up with dicamba, plus where you can use Liberty, I think a lot more are using Liberty on the back end.

But there are still a lot using dicamba as a pre. This gives options to still use that, not super late in the season, but still use to get a clean field while the plants are still small.

Litchfield: Looking at this from a practical side, this decision didn’t come out until early February. I know people wanted it sooner, but how will this affect farmers in 2026. Are they going to get in the fields and be using this, or is it too late? What’s your perspective?

Johnson: Guys will still be able to use it. On our own farm, we’ve already kind of laid out a plan by the second week of February. You have a game plan when you start prepaying for a lot of products, either that last couple weeks of December or the first two weeks of January.

There will be a little switch, because I think people thought that there could very well be a dicamba label. What would that dicamba label look like? We may have had an idea, so there are game plans being put forth.

I do think that most guys will use this product as a pre rather than a post, but there definitely will be using post applications. If you have super high weed pressure, guys will use it.

Litchfield: The label also calls for additional documentation with mandatory recordkeeping. The three dicamba products now have requirements to meet mitigations for the Endangered Species Act. These involve checking two websites, the EPA’s “Bulletins Live! Two,” where you can see whether the site where you want to apply the products is in a pesticide use limitation area based on the Endangered Species Bulletin, and the other website, “Mitigation Menu.”

Johnson: I think farmers will get to know the “Bulletins Live! Two” website a lot more. You need to look at that because this does apply to the Endangered Species Act. “Bulletins Live! Two” is a good website, but it’s not real easy to just find one thing and find what you need. We asked EPA to streamline that.

The federal label is asking for more recordkeeping, but here over the last five years with dicamba, the Illinois Department of Ag has had a recordkeeping sheet for dicamba with 22 questions.

If you ever get called in on a complaint, the first thing the state Department of Ag is going to ask for is your recordkeeping. If you do not have all 22 questions filled out, you are going to get a $750 fine, no questions asked.

Farmers and retailers, if I can stress anything, do your recordkeeping. I know we get busy in the season and “I’ll take care of that later.” Do that now. Do that in the cab.

It takes two, three minutes, and I know two or three minutes in the heat of the season — we’ve got to go — but that is going to help you long term. On dicamba, this is mandatory.

Litchfield: If you work with a custom applicator, retailer, whatever it might be, this is something to have a conversation on, as well, to make sure that that communication of recordkeeping is being done, as well.

Johnson: Absolutely, if you have it custom applied by somebody else or a retailer, all the responsibility on that recordkeeping is on whoever is in the cab of that sprayer.

You can ask for that information just for your documentation, but if there is an incident that a customer applicator did, the Department of Ag would look to them, not you.

Litchfield: Anything else on dicamba?

Johnson: Have a game plan going into 2026. On our own farm, we have a game plan, but then we have options B, C and D.

I think, with the newer technologies and just how much recordkeeping there is in everything you do, have a game plan going in, try and stick with that game plan and then if it throws a curveball with weather or stuff like that, we can change. Have an idea long term of what products you’re using.