OTT dicamba has returned.
On February 6, 2026, the EPA approved labels for over-the-top (OTT) dicamba herbicides to be used with dicamba-tolerant cotton and soybean varieties. These labels pave the way for OTT dicamba to be used for the first time since the District Court of Arizona issued an order to vacate the EPA’s labels in February 2024.
New Labels
In addition to retaining legacy restrictions from the older OTT dicamba labels, the EPA added four new restrictions in the latest 2026 labels.
The first restriction pertains to the maximum application rate, which has been cut in half. Under the new labels, a maximum of two applications of 0.5 lbs. of dicamba can be made annually. The purpose of this restriction is to reduce total dicamba in the environment and minimize potential exposure to endangered species.
The second restriction requires applicators to add 40 ounces/acre of approved volatility Reduction Agents (VRA) to every application. This amount is double that from prior labels.
The third restriction involves mandatory conservation practices, a relatively new concept that arose from the EPA’s incorporation of the Endangered Species Act (ESA) into the pesticide regulatory structure created under the Federal Insecticide Fungicide and Rodenticide Act (FIFRA). Under this restriction, growers must achieve 3 runoff/erosion mitigation points at a minimum, and 6 points in certain Pesticide Use Limitation Areas (PULAs) where especially vulnerable species maintain habitat.
The fourth restriction creates temperature-based limits on applications, as opposed to the previously used date-based restrictions. Specifically, an applicator may apply OTT dicamba to no more than 50% of their untreated DT cotton and soybean acres in a given county on days when the forecasted temperature is between 85°F and 95°F, either on the day of application or the following day. If the forecasted temperature reaches or exceeds 95°F on the day of application or the following day, OTT dicamba applications are prohibited.
New Lawsuit
As expected, the EPA’s decision to register OTT dicamba has created some controversy. The National Family Farm Coalition, the same organization that previously sued the EPA to de-register dicamba in 2020 and again in 2024, has filed a lawsuit against the EPA to remove OTT dicamba from the market once again. In this lawsuit, the National Family Farm Coalition alleges that the EPA violated its duties under FIFRA and the ESA by re-registering OTT dicamba. Of note, these claims are very similar to the claims successfully made in 2020 and 2024.
Brown, Nicholas. “OTT Dicamba Returns, Prompting Lawsuits.” Southern Ag Today 6(11.5). March 13, 2026. Permalink
