Dear Assistant Administrator Freedhoff:

The National Association of State Departments of Agriculture (NASDA) wants to share our perspective on the U.S. Environmental Protection Agency’s (EPA) registration review for Enlist One and Enlist Duo for uses on herbicide-tolerant corn, cotton, and soybeans.

I. About NASDA

NASDA represents the Commissioners, Secretaries, and Directors of the state departments of agriculture in all fifty states and four U.S. territories. State departments of agriculture are responsible for a wide range of programs including food safety, combating the spread of disease, and fostering the economic vitality of our rural communities. Conservation and environmental protection are also among our chief responsibilities.

In forty-three states, the state department of agriculture is a co-regulator with EPA and responsible for administering, implementing, and enforcing the production, labeling, distribution, sale, use, and disposal of pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

II. General Comments

Crop protection tools are an important component within many agricultural crop production systems. NASDA is intimately familiar with EPA’s rigorous, scientific evaluation and review process for all crop protection tools under FIFRA. NASDA supports the development, scientific review, and approval of new technologies and uses, such as products for herbicide-tolerant crops, crops that enable growers to combat weed-resistance challenges.

Importance of Crop Protection to Agriculture. Our members work closely with farmers, and we know that Enlist One and Enlist Duo are critical crop protection tools widely used for controlling weeds in integrated weed management strategies. Producers rely on these technologies in their future planning decisions. Given the recent legal actions surrounding other biotechnology tools, farmers are in need of continuity and certainty that their upcoming seed purchases will have corresponding technologies available.

Importance of a Rigorous Registration Process. Notwithstanding the successful use of these products, our members appreciate the rigor and validity of EPA’s FIFRA and science-based registration review process. We appreciate that EPA will have a decision regarding extension ofregistration of these products by late this year. NASDA also appreciates that EPA will continue to coordinate with us to clarify label interpretations and regulatory oversight for future pesticide re-registration.

Our growers face constant pressures from weather conditions, pest stressors, herbicide resistance issues, and a myriad of other challenges. A wide range of crop protection tools must continue to be available in the farmer’s toolbox, following EPA-registration process and a determination of safe when used according to the label. It is essential to American agriculture that EPA execute its authorities and responsibilities in a timely manner consistent with the Agency’s robust science- based registration and review process to ensure farmers have access to a broad range of new technologies and modern crop protection tools.

III. Conclusion

NASDA appreciates the opportunity to comment on this important issue. We support EPA’s registration review of these Enlist One and Enlist Duo formulations, which are used in combination with herbicide-tolerant corn, cotton, and soybeans consistent with the Agency’s well-established registration review process under FIFRA.

As regulatory partners with EPA, we stand ready to assist EPA in ensuring our growers have access to a broad range of technologies and crop protection tools, that are reviewed and approved in a scientifically sound and transparent manner, and needed to continue to produce our nation’s food, fiber, and fuel.

Please contact (zach.gihorski@nasda.org) if you have any questions or would like any additional information.


Barbara P. Glenn, Ph.D.
Chief Executive Officer

Date Sent:

August 25, 2021




EPA Assistant Administrator Michal Freedhoff