Dicamba over-the-top in 2026–2027: what the new labels require

What changed and when

Over-the-top dicamba has been through four federal approvals since 2016. The Ninth Circuit vacated the 2018 registration in June 2020, and a federal court in Arizona vacated the 2020 registration in February 2024 on procedural grounds under FIFRA, so there was no over-the-top use in 2024 or 2025. EPA proposed an unconditional registration in August 2025 and then, on February 6, 2026, issued a conditional, two-season registration instead. The Stryax label states that the labeling "expires on February 6, 2028" and that the product may not be used or distributed after that date; EPA will need a new decision for 2028 onward.

Compared with the 2020 labels, the main changes are:

• Half the annual load. A maximum of two applications of 0.5 lb a.e. dicamba per acre, for 1.0 lb a.e. per acre per year from all dicamba products combined, including burndown. The 2020 registration allowed 2.0 lb.
• A mandatory volatility reduction agent (VRA) in every application. EPA's release gives the rate as 40 oz per acre of an approved VRA; the Stryax label requires a "qualified pH buffering" VRA and sends the applicator to its requirements website for the current list and rates.
• Runoff and erosion mitigation points under the Endangered Species Act: 3 points per treated field from EPA's mitigation menu, 6 points inside designated pesticide use limitation areas (PULAs).
• A forecast-temperature rule (below).

What the label now requires

The following apply to all three products under the federal labels, as summarized by EPA and by state extension services in 2026. Check the label registered in your state before every application.

Extension articles differ on whether every product carries a growth-stage limit, which is one more reason to read the label for the product and state you are using rather than a summary.

What growers must do before application

The new labels shift most of the work to before the sprayer leaves the shed.

1. Confirm state registration. Federal approval does not authorize use until the state has registered the product and its state-specific labeling. SDSU notes that only products under the South Dakota-specific label may be used there, and Nebraska requires registration with its Department of Agriculture.
2. Check the product's requirements website no more than 7 days before application. The Stryax label makes this mandatory; it is where approved VRAs, DRAs, nozzles and state additions are posted.
3. Check Bulletins Live! Two for your field, the product's EPA registration number and the month. Nebraska's guidance is to check within six months before application and keep a printed or saved copy even when no restrictions apply, because that copy is part of your record.
4. Earn your mitigation points. Three points per field outside a PULA, six inside one. Practices on EPA's menu include cover crops, contour farming and vegetative buffers, and some counties receive automatic credits; your state extension service has the county map.
5. Survey the neighbourhood. Check FieldWatch (or your state's sensitive-crop registry) and walk the downwind edge for sensitive crops, gardens and residences.
6. Record the forecast. The NWS forecast high for the day of and the day after application drives both the 50% rule and the 95°F stop, and the records must show it.
7. Complete the records the same day. The Stryax label lists 24 required items, among them applicator certification, training proof, product and lot, VRA and DRA used, nozzle and pressure, temperature and wind readings, buffer determination, sensitive-area checks, equipment cleanout and mitigation points. SDSU notes they must be completed by the end of the application day and kept available for inspection.

States can be stricter

A state may add restrictions to the federal label, and in 2026 several did:

• Minnesota. No application south of Interstate 94 after June 12 or north of I-94 after June 30. No application if the field air temperature exceeds 85°F (29°C) or the NWS forecast high for the nearest location exceeds 85°F, and the forecast temperature must be recorded at the start of the application.
• Illinois. Under 8 Ill. Adm. Code 250.230, no dicamba application on soybeans after June 20 of each year, none when the field air temperature is over 85°F or the forecast high exceeds 85°F, mandatory FieldWatch consultation, and no application when the wind blows toward an adjacent Illinois Nature Preserves Commission site or residential area.
• South Dakota. Cut-off of June 30 or R1 soybean for all three products.

Iowa carried a June 12 cut-off on its state-specific labeling under the previous registration (EPA approved that amendment in February 2023), and other states have used similar dates. Whatever state you farm in, the state addendum is the controlling document, and the registrant websites are where it is posted.

Status as of October 2026 and what could still change

As of October 2026, the registration stands for the 2026 and 2027 seasons and expires February 6, 2028. On the legal side, the National Family Farm Coalition, Center for Food Safety, Center for Biological Diversity and Pesticide Action & Agroecology Network petitioned the Ninth Circuit in February 2026 (National Family Farm Coalition v. EPA), alleging violations of FIFRA and the Endangered Species Act; the same plaintiffs won vacatur in 2020 and 2024. The National Agricultural Law Center reported the briefing schedule as an opening brief due May 11 and EPA's response due June 10, 2026. None of the sources verified for this page reported a decision or a stay; check the Law Center's dicamba series for the current status before relying on the label for 2027.

Two further things can move. EPA describes the approval as "subject to further review" and says it will work with state enforcement agencies to monitor compliance, so the 2027 label could carry changes. And states can add to their addenda between seasons, as Minnesota, Illinois and South Dakota have already done. The practical rule for a grower is to treat the label, the state addendum and the product website you checked within the last 7 days as the only three documents that count.