ESA Pesticide Label Changes – What You Need to Know for the 2026 Growing Season

Introduction

With the growing season right around the corner, you’ve probably started planning which pesticides you intend to use this year. When selecting the pesticides, carefully review the label since some pesticides now include new language and practices that must be followed to be compliant with the Endangered Species Act (ESA). As of May 2026, there are currently 14 pesticide products (4 active ingredients) registered for use in WI with ESA label requirements (Table 1).

Table 1. Pesticide products registered in WI that include ESA label requirements. List compiled by DATCP. *NOTE: This is not a product endorsement, these products are listed for educational purposes.

Product Name	Active Ingredient	EPA Reg. No.
Liberty Ultra	Glufosinate-P-Ammonium	7969-500
Noventa Ultra Herbicide	Glufosinate-P-Ammonium	7969-500
Autonomy ULTRA Herbicide	Glufosinate-P-Ammonium	7969-500-55467
Legrium ULTRA Herbicide	Glufosinate-P-Ammonium	7969-500-534
Incipio	Isocycloseram	100-1712
Vykenda	Isocycloseram	100-1703
Atexzo	Isocycloseram	100-1703
Zivalgo	Isocycloseram	100-1711
Vertento	Isocycloseram	100-1711
Engenia	Dicamba	7969-507
Stryax Herbicide	Dicamba	264-1241
Tavium Plus VaporGrip Technology	Dicamba	100-1753
Enlist One	2,4-D, choline salt	62719-695
Enlist Duo	2,4-D, choline salt	62719-649

https://datcp.wi.gov/Documents2/WisconsinRegisteredProductswithESALabelRequirements.pdf ↗️

All products registered in compliance with the new ESA requirements include label instructions with three main goals: 

1. To minimize spray drift,
2. Reduce pesticide runoff and erosion, and
3. Protect endangered and threatened species and their critical habitats.

Be aware of these changes and proactive when planning pesticide use on the farm to ensure compliance with these new mitigation measures. All newly registered or reregistered pesticides must be ESA-compliant, leading to label changes implemented for herbicides, insecticides, fungicides, and rodenticides for agricultural use.

What steps should be taken to ensure compliance?

Follow these four steps for compliance:

1. Identify which pesticides(s) you intend to use over the next 6-month period. 
2. Read each label entirely to understand the restrictions established, like spray drift buffers. The changes to the label may not be obvious.  Always read the label thoroughly and remember the label is the law.
3. Evaluate on-farm mitigation measures and calculate the total number of mitigation points earned for each field intended for the pesticide application.
   1. The EPA website provides resources to evaluate runoff and erosion potentials and a calculator to estimate mitigation points achieved per field. EPA Mitigation Menu website: www.epa.gov/pesticides/mitigation-menu ↗️   
4. Check for PULAs in Bulletins Live! Two (BLT) within 6 months of the pesticide application.
   1. Any pesticide with ESA compliant language will indicate you must check for any pesticide use limitation areas (PULAs) based on the pesticide product being used and the intended application location. 
   2. You must check BLT to identify any limitations for every field and planned pesticide application. When checking for PULAs you will need the EPA registration number, the month of the intended application, and the intended field/location of the application. 
   3. If PULAs are present, you must follow the limitations listed in BLT. 

Drift Mitigation

The goal of the mandatory spray drift mitigation is to minimize the off-target movement of the pesticides during application. Practices to reduce spray drift include:

• Altering the characteristics of the spray,
• Changing application techniques to reduce drift,
• Following guidance on weather conditions during time of application, and
• Implementing a buffer area between the spray zone and environmentally sensitive areas. 

Drift mitigation requirements will vary by pesticide product. In the label, you will find mandatory practices to minimize spray drift and guidance on approved spray drift buffers. Use the EPA spray drift calculator ↗️ to evaluate if the spray drift buffer outlined in the label can be reduced for the intended site of application. Buffer reductions are based on environmental conditions and pesticide application factors, like droplet size.

Runoff and Erosion Mitigation

In addition to drift reduction measures, agricultural fields must meet criteria to reduce pesticide movement via runoff or erosion. The pesticide label will require a certain number of mitigation points to be achieved per field for the application of a specific pesticide product. Mitigation points ensures the field characteristics and practices are in favor of reducing the risk of pesticide movement by runoff and erosion. 

The total number of mitigation points required will vary by pesticide product. Points are earned by evaluating current field practices (e.g., application rate, tillage, irrigation, etc.) and inherent field characteristics (e.g., soil type, slope, etc.). Additional points are earned by implementing practices described in the EPA’s Mitigation Menu. 

The EPA mitigation point calculator ↗️ is a helpful tool to determine the number of points earned from current field conditions/practices.  It includes a ‘credit’ based on a county’s environmental characteristics that have relatively less runoff and erosion vulnerability. Based on the EPA’s Runoff Vulnerability Map, all Wisconsin Counties inherently receive between 2 and 3 mitigation points based on the state’s soil characteristics and geography (Figure 1). 

Bulletins Live! Two (BLT)

Bulletins Live! Two ↗️ is a website that provides additional warnings, requirements, and restrictions for pesticide use based on geographic location to protect endangered and threatened species and their critical habitats. These geographic restrictions are called Pesticide Use Limitation Areas (PULAs). In addition to following the pesticide label, PULAs were developed to further mitigate the impacts of pesticides on endangered species and their habitats. Currently, there are only a few products registered for use in Wisconsin that have Endangered Species Protection Bulletins, but moving forward, this will change as new pesticide products are registered or new endangered or threatened species are listed. The ESA language on both the full pesticide label and in the bulletins is specifically intended to reduce the risk of pesticide drift and runoff/erosion. 

Before the pesticide application, read the pesticide label thoroughly. With the ESA compliance changes, information regarding Bulletins Live! Two may be found in different sections of the label on different products. Pay particular attention to the Environmental Hazards, Endangered Species or the Mandatory Runoff Mitigation sections of labels. 

Examples of mandatory statements found within the label that indicate you must access Bulletins Live! Two:

• “When using this product, you must follow the measures contained in the Endangered Species Protection Bulletin for the area in which you are applying the product. To obtain Bulletins, no more than six months before using this product, consult https://www.epa.gov/endangered-species-bulletins-live-two-view-bulletins…” 
• “Applicators must access and search Bulletins Live! Two (BLT) at https://www.epa.gov/pesticides/bulletins within six months of the application…”

If there is a bulletin for the product you wish to use, a link or phone number to access Bulletins Live! Two will be included in the label. To access Bulletins Live! Two online, go to https://www.epa.gov/pesticides/bulletins ↗️.

For detailed information on navigating BLT online, check out the 2025 article on ESA and Bulletins Live! Two (https://fyi.extension.wisc.edu/pat/2025/05/30/the-endangered-species-act-and-bulletins-live-two-website/).

Why should I comply?

The pesticide label is the law. It is a legally binding document, and you must follow all the instructions outlined in the label. If the label requires you to have drift buffers, mitigation points, and access Bulletins Live! Two, you must do it.

Remember, pesticide products are registered and reregistered frequently. Always read the pesticide label carefully and follow the instructions. Failure to follow the pesticide label is illegal.