Letter

Key Points: 

  • Support for Uniform Federal Pesticide Labeling: The letter urges Congress to pass the Agricultural Labeling Uniformity Act to reaffirm that only the EPA can set pesticide labeling and packaging requirements, preventing states from imposing conflicting rules.
  • Concerns Over State-Level Regulations: The authors express concern about recent state actions that contradict EPA-approved pesticide labels, warning this creates regulatory inconsistency, disrupts commerce, and undermines public confidence in federal science-based regulation.
  • The letter calls for any legislation to affirm these changes do not otherwise impede the states’ flexibilities for regulating pesticides under FIFRA Section 24(a) and 24(c).

Dear Speaker Johnson, Leader Thune, Leader Jeffries, and Leader Schumer,

We write to express our great concern with recent misinterpretations of long-standing policy regarding the regulation and labeling of pesticide products, as some states have begun to regulate pesticides in a manner contradicting decades of scientific guidance from the Environmental Protection Agency (EPA). Lack of certainty on EPA-approved, science-based nationwide labels will erode access to current and future pesticides, threatening crops and farmer incomes, conservation practices, public health, vital infrastructure, and ultimately raise food prices for families amidst high inflation. Growers and users need reaffirmation from Congress that while states have authority to regulate the sale and use of pesticides within their jurisdiction, they cannot impose labeling or packaging requirements in addition or different from the scientific conclusions of the EPA. To that end, we support and urge Congress to enact the Agricultural Labeling Uniformity Act, bipartisan legislation which would reaffirm federal pesticide labeling uniformity and prevent states from adopting inconsistent labeling or packaging which would disrupt commerce and access to these vital tools.

The last several years have demonstrated how fragile our food production and infrastructure systems can be. Whether driven by war in Ukraine, extreme weather events, avian influenza disruptions, our economic wellbeing and access to a safe, affordable food supply relies on many factors. Pesticides are an essential tool for many growers and other users whose operations rely on them, and for consumers and our environment which benefit from their use. If left unchecked, some pests can inflict crop yield losses greater than 80 percent, destroy important infrastructure, harm public health through mosquito-borne disease or other outbreaks, among other harms. Additionally, pesticides are essential to maintaining and expanding vital conservation practices, such as cover crops or tillage reductions, which remove the equivalent of millions of cars from roadways annually, reduce soil erosion, and prevent nutrient loss to watersheds. Without access to safe, effective pesticides regulated with the best available science, food prices for American families will rise significantly and our ability to protect public health, infrastructure, and our environment will be greatly diminished.

Disturbingly, we are seeing in states an emerging threat that risks access to these essential tools on which farmers and other users rely. The Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), the primary statute governing pesticides, places EPA in the authority to make foundational, science-based decisions on how pesticides can be labeled and used. States are permitted to regulate the sale and use of pesticides under FIFRA but are preempted from requiring additional or different pesticide labels or packaging. Nevertheless, in recent years we have seen actions from states that directly and unjustifiably contradict EPA’s scientific findings on pesticide safety. These actions risk creating an unworkable, inconsistent patchwork of state pesticide labels that can quickly disrupt commerce and access to these much-needed tools. As concerning, this threatens to jeopardize public confidence in EPA’s authority and science-based regulation under FIFRA, as well as the continued availability of individual tools on which there are contradictory claims.

We urge Congress to seriously consider the far-reaching implications should this uncertainty go unaddressed by federal policymakers. The ability of farmers, land managers, and other users to produce an abundant food, feed, and fiber supply, combat public health threats, implement important conservation practices, and maintain vital transportation and utility infrastructure will be significantly impaired. In turn, food prices will further increase for families; important infrastructure will fall into disrepair; our population will be increasingly vulnerable to vector-borne diseases; and our ability to combat climate change and other environmental challenges will be undermined.

To that end, we strongly urge Congress to enact the Agricultural Labeling Uniformity Act. This important legislation will reaffirm that EPA is the primary, federal authority under FIFRA for making pesticide findings and decisions. While states will continue to regulate and provide registrations for additional uses of federally registered pesticide products, as provided by FIFRA sections 24(a) and 24(c), this legislation will reaffirm that they may not impose additional labeling or packaging requirements. Congressional action on this important matter will ensure our nation’s farmers and other users have reliable access to these vital tools in the years to come.

Sincerely,

African American Farmers of California
Agribusiness Association of Iowa
Agribusiness Association of Kentucky
Agribusiness Council of Indiana
Agricultural Council of Arkansas
Agricultural Retailers Association
Alabama Agribusiness Council
Alabama Farmers Federation
Alabama Soybean and Corn Growers Association
Alaska Farm Bureau
Almond Alliance
American Agri-Women
American Cotton Producers
American Cotton Shippers Association
American Dairy Coalition
American Farm Bureau Federation
American Horse Council
American Mosquito Control Association
American Pistachio Growers
American Pulse Association
American Seed Trade Association
American Soybean Association
American Sugar Alliance
American Sugar Cane League
American Sugarbeet Growers Association
AmericanHort
Aquatic Ecosystem Restoration Foundation
Aquatic Plant Management Society
Arizona Cotton Growers Association
Arizona Crop Protection Association
Arizona Farm Bureau Federation
Arkansas Certified Crop Advisers
Arkansas Crop Protection Association
Arkansas Farm Bureau Federation
Arkansas Rice Federation
Arkansas Rice Growers Association
Arkansas Soybean Association
Associated Oregon Hazelnut Industries
Association of Equipment Manufacturers
Big Horn Basin Beet Growers Association
Big Horn County Sugar Beet Growers Association
Burley and Dark Tobacco Producer Association
California Alfalfa & Forage Association
California Apple Commission
California Association of Wheat Growers
California Association of Winegrape Growers
California Blueberry Commission
California Cattlemen’s Association
California Cherry Growers and Industry Association
California Citrus Mutual
California Cotton Ginners and Growers Association
California Farm Bureau
California Fresh Fruit Association
California Grain and Feed Association
California Pear Growers
California Rice Commission
California Safflower Growers Association
California Seed Association
California Specialty Crops Coalition
California State Floral Association
California Sweetpotato Council
California Tomato Growers Association
California Walnut Commission
California Warehouse Association
California Wild Rice Advisory Board
Carolinas Cotton Growers Cooperative
Cherry Marketing Institute
Colorado Association of Wheat Growers
Colorado Cattlemen’s Association
Colorado Farm Bureau
Colorado Fruit And Vegetable Growers Association
Colorado Livestock Association
Colorado Nursery and Greenhouse Association
Colorado Potato Legislative Association
Colorado Sugarbeet Growers Association
Connecticut Environmental Council
Connecticut Farm Bureau Association
Corn Refiners Association
Council of Producers & Distributors of Agrotechnology
CropLife America
Delaware-Maryland Agribusiness Association
Delta Council
Empire State Council of Agricultural Organizations
Empire State Potato Growers
Far West Agribusiness Association
Florida Citrus Mutual
Florida Cotton Growers Association
Florida Farm Bureau Federation
Florida Fertilizer & Agrichemical Association
Florida Fruit and Vegetable Association
Food Producers of Idaho
Georgia Agribusiness Council
Georgia Cotton Commission
Georgia Farm Bureau
Georgia Fruit and Vegetable Growers Association
Georgia Green Industry Association, Inc.
Georgia Urban Ag Council
Georgia-Florida Soybean Association
Golf Course Superintendents Association of America
Great Plains Canola Growers Association
Grower-Shipper Association of Central California
Hawaii Cattlemen’s Council
Hawaii Crop Improvement Association
Hawaii Farm Bureau
Hop Growers of America
Idaho Alfalfa and Clover Seed Growers Association
Idaho Barley Commission
Idaho Eastern Oregon Seed Association
Idaho Farm Bureau Federation
Idaho Grain Producers Association
Idaho Hay and Forage Association
Idaho Honey Industry Association
Idaho Hop Growers Association
Idaho Mint Growers Association
Idaho Noxious Weed Control Association
Idaho Oilseed Commission
Idaho Onion Growers’ Association
Idaho Oregon Seed Pesticide Council
Idaho Pea & Lentil Commission
Idaho-Oregon Fruit and Vegetable Association
Illinois Corn Growers Association
Illinois Farm Bureau
Illinois Fertilizer and Chemical Association
Illinois Soybean Association
Independent Professional Seed Association
Indiana Corn Growers Association
Indiana Farm Bureau
Indiana Soybean Alliance Membership & Policy Committee
International Fresh Produce Association
Iowa Corn Growers Association
Iowa Farm Bureau
Iowa Seed Association
Iowa Soybean Association
Iowa Sports Field Management Association
Kansas Agribusiness Retailers Association
Kansas Association of Wheat Growers
Kansas Cotton Association
Kansas Farm Bureau
Kansas Grain and Feed Association
Kansas Livestock Association
Kansas Sorghum Producers
Kansas Soybean Association
Kentucky Corn Growers Association
Kentucky Farm Bureau Federation
Kentucky Small Grain Growers Association
Kentucky Soybean Association
Louisiana Agricultural Consultants Association
Louisiana Cotton & Grain Association
Louisiana Farm Bureau Federation
Louisiana Nursery and Landscape Association
Maine Farmers Coalition
Maine Potato Board
Malheur County Onion Growers Association
Maryland Farm Bureau
Maryland Grain Producers Association
Massachusetts Farm Bureau Federation
Michigan Agri-Business Association
Michigan Asparagus Association
Michigan Bean Shippers
Michigan Corn Growers Association
Michigan Farm Bureau
Michigan Nursery & Landscape Association
Michigan Soybean Association
Michigan State Horticultural Society
Michigan Vegetable Council
Mid Atlantic Soybean Association
Midwest Council on Agriculture
Midwest Food Products Association
Midwest Forage Association
Minnesota AgriGrowth
Minnesota Area II Potato Growers Council
Minnesota Association of Wheat Growers
Minnesota Canola Council
Minnesota Corn Growers Association
Minnesota Crop Production Retailers
Minnesota Farm Bureau Federation
Minnesota Soybean Growers Association
Mint Industry Research Council
Mississippi Farm Bureau Federation
Mississippi Soybean Association
Missouri Agribusiness Association
Missouri Corn Growers Association
Missouri Farm Bureau Federation
Missouri Pork Association
Missouri Rice Council
Missouri Soybean Association
Modern Ag Alliance
Montana Agricultural Business Association
Montana Farm Bureau Federation
Montana Grain Growers Association
National Agricultural Aviation Association
National Alfalfa & Forage Alliance
National Alliance of Independent Crop Consultants
National Association of State Departments of Agriculture
National Association of Wheat Growers
National Barley Growers Association
National Black Growers Council
National Cattlemen’s Beef Association
National Christmas Tree Association
National Corn Growers Association
National Cotton Council
National Council of Farmer Cooperatives
National Milk Producers Federation
National Onion Association
National Pecan Federation
National Potato Council
National Sorghum Producers
National Sunflower Association
National Turkey Federation
National Watermelon Association
NEBCO Sugarbeet Growers Association
Nebraska Agri-Business Association
Nebraska Corn Growers Association
Nebraska Farm Bureau Federation
Nebraska Soybean Association
Nebraska Sugarbeet Growers Association
Nevada Farm Bureau Federation
New Hampshire Farm Bureau
New Jersey Farm Bureau
New Jersey Green Industry Council
New Jersey Nursery & Landscape Association
New York Corn & Soybean Growers Association
New York Farm Bureau
New York Green Industry Council
New York State Agribusiness Association
New York State Turfgrass Association, Inc.
Nezperce Prairie Grass Growers Association
Nisei Farmers League
North American Blueberry Council
North Carolina Christmas Tree Association
North Carolina Cotton Producers Association
North Carolina Egg Association
North Carolina Farm Bureau
North Carolina Grange
North Carolina Nursery & Landscape Association
North Carolina Potato Association
North Carolina Soybean Producers Association
North Central Weed Science Society
North Dakota Agricultural Association
North Dakota Corn Growers Association
North Dakota Dry Pea & Lentil Council
North Dakota Farm Bureau
North Dakota Grain Growers Association
North Dakota Soybean Growers Association
Northarvest Bean Growers Association
Northeast Agribusiness & Feed Alliance
Northeast Dairy Producers Association
Northeastern Weed Science Society
Northern Canola Growers Association
Northern Pulse Growers Association
Ohio AgriBusiness Association
Ohio Corn & Wheat Growers Association
Ohio Farm Bureau
Ohio Soybean Association
Oklahoma Agribusiness Retailers Association
Oklahoma Cotton Council
Oklahoma Farm Bureau
Oklahoma Soybean Association
Oklahoma Wheat Growers Association
Olive Grower Council of California
Oregon Association of Nurseries
Oregon Cattlemen’s Association
Oregon Farm Bureau
Oregon Hop Growers Association
Oregon Potato Commission
Oregon Seed Council
Oregon Wheat Growers League
Oregon Women for Agriculture
Oregonians for Food and Shelter
Pacific Egg & Poultry Association
Pacific Northwest Canola Association
Pacific Seed Association
Palmetto AgriBusiness Council
Panhandle Peanut Growers Association
PennAg Industries Association
Pennsylvania Cooperative Potato Growers
Pennsylvania Corn Growers Association
Pennsylvania Farm Bureau
Pennsylvania No-Till Alliance
Plains Cotton Growers, Inc.
Potato Growers of Michigan, Inc
Professional Dairy Managers of Pennsylvania
Public Lands Council
Red River Valley Sugarbeet Growers Association
Rhode Island Farm Bureau Federation
RISE (Responsible Industry for a Sound Environment)
Rolling Plains Cotton Growers
Snake River Sugarbeet Growers Association
South Carolina Corn and Soybean Association
South Carolina Farm Bureau Federation
South Carolina Peach Council
South Dakota Agri-Business Association
South Dakota Association of Cooperatives
South Dakota Corn Growers Association
South Dakota Farm Bureau
South Dakota Soybean Association
South Texas Cotton & Grain Association
Southern Cotton Growers, Inc.
Southern Crop Production Association
Southern Idaho Potato Cooperative
Southern Kansas Cotton Growers Coop
Southern Montana Sugarbeet Growers
Southern Rolling Plains Cotton Growers Assn
Southern Weed Science Society
Southwest Council of Agribusiness
Synergistic Hawaii Agriculture Council
Tennessee Farm Bureau Federation
Tennessee Nursery & Landscape Association
Tennessee Soybean Association
Texas Corn Producers Association
Texas Farm Bureau
Texas Grain Sorghum Association
Texas International Produce Association
Texas Rice Council
Texas Soybean Association
Texas Vegetable Association
Texas Wheat Producers Association
U.S. Apple Association
U.S. Beet Sugar Association
U.S. Canola Association
U.S. Durum Growers Association
U.S. Peanut Federation
United Egg Producers
United Potato Growers of America
US Dry Bean Council
US Pea & Lentil Trade Association
US Rice Producers Association
USA Dry Pea & Lentil Council
USA Rice
Utah Farm Bureau Federation
Venture Dairy Cooperative
Virginia Agribusiness Council
Virginia Cattlemen’s Association
Virginia Farm Bureau
Virginia Grain Producers Association
Virginia Soybean Association
Washington Asparagus Commission
Washington Association of Wheat Growers
Washington Blueberry Commission
Washington Farm Bureau
Washington Friends of Farms and Forests
Washington Grain Commission
Washington Mint Growers Association
Washington Potato & Onion Association
Washington Pulse Crops Commission
Washington State Dairy Federation
Washington State Potato Commission
Weed Science Society of America
Westen Plant Health Association
Western Alfalfa Seed Growers Association
Western Growers
Western Pulse Growers Association
Western Society of Weed Science
Western Sugar Cooperative
Western Tree Nut Association
Wisconsin Agri-Business Association
Wisconsin Corn Growers Association
Wisconsin Dairy Products Association
Wisconsin Farm Bureau
Wisconsin Potato & Vegetable Growers Association
Wisconsin Soybean Association
Wyoming Ag Business Association
Wyoming Crop Improvement Association
Wyoming Farm Bureau Federation
Wyoming Wheat Growers Association

Contact Information

Patrick Wade
Director, Public Policy
patrick.wade@nasda.org

Sender:

Agricultural Coalition

Subject:

Refiling of the Agricultural Labeling Uniformity Act