Dicamba Cutoff Date & Options After June 25

2.  July 31 USEPA Cancellation Date:  The USEPA order states that Engenia, Xtendimax and FeXapan cannot be used or distributed, even by commercial and private applicators, after July 31, 2020.   Sale and/or distribution by the registrants and wholesalers ceased on June 3, 2020.  The USEPA cancellation order has allowed the sale and use of the products if they were in the possession of the commercial applicator or private applicator on June 3, 2020.  After July 31, any remaining product must be returned to the registrant or follow the registrant's instructions for disposal.  More information from the registrants is forthcoming on what to do with product after July 31, 2020.  

3.  What can Illinois applicators do with unused product after June 25, 2020?  "Over the top" applications on soybean are banned in Illinois after June 25, 2020.  There are other labeled uses for Engenia, Xtendimax, FeXapan and Tavium on the product labels.  For the 3 products that have been cancelled, these other uses remain valid until July 31, 2020.  But from a realistic and stewardship standpoint, as we continue to move into the hotter summer temperatures of late June and the month of July, the problematic situations that were the primary reason for the June 25 cutoff date in Illinois still remain.  IFCA cautions applicators to consider what is at stake for the future potential use of dicamba technologies in light of the recent tumultuous court rulings.  Keeping these products on-target, no matter what crop they are being used on, is in everyone's best interest as USEPA considers the case for registration and use in the future. 

4.  What if commercial and private applicators have product remaining in inventory after June 25, 2020, but farmers in neighboring states with no cut-off dates (i.e. Iowa, Missouri, Wisconsin) still need product?  According to the IL Dept of Ag's FAQ on the cancellation order, if you are a commercial application business and you also have a commercial application facility in Iowa, Missouri, Wisconsin or any other state that does not have a cut-off date, you can transfer product to those facilities for proper labeled use, even over the top on soybean.  The final date of use in states with no cut-off date remains July 31, 2020 (except for Tavium which is not cancelled). 

Bottom line:  If you are an Illinois commercial application business with facilities in other states, you can continue to sell or apply Engenia, Xtendimax or FeXapan that you had remaining at your Illinois commercial applicatoin facilities after June 25, 2020 into the other states so long as the product sold by your commercial application facility is sold to a private applicator, or is custom applied by your company's commercial application service in that state.  Tavium was not cancelled by USEPA and therefore the sale and distribution of Tavium by the registrant, distributor or commercial applicator remains legal at this time.  

If you have questions, please contact Jean Payne at (309) 826-3236 or jeanp@ifca.com