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Bergeson & Campbell, P.C.'s (B&C®) recently published Forecast 2026 includes a deep dive into what stakeholders can expect this year regarding the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), excerpts of which are shared here.
Policy shifts and uncertainties are expected under FIFRA and the Endangered Species Act (ESA) in the agricultural and biocidal area. ESA has been, and will continue to be, the most important issue affecting pesticide use and regulation in the United States for the next few years. During 2026, EPA will face decisions regarding a much larger number of pesticides, that may reveal the impact on pesticide users and the reaction by all stakeholders to the U.S. Environmental Protection Agency's (EPA) approach. Continued progress during 2025 on the long overdue integration of ESA and FIFRA requirements has quieted the previous routine ESA litigation that has characterized many registration decisions in recent years. Whether stakeholders — both agricultural and environmental — "maintain the peace" during 2026 is among the uncertainties surrounding the immediate future of the ESA pesticide efforts.
Although PRIA 5 is authorized until September 30, 2027 (the end of Fiscal Year (FY) 2027), work on PRIA 6 will begin asstakeholders evaluate further changes to the current law tomake program improvements generally and to incorporaterecommendations from the various internal and externalreviews for how to address decision backlogs and reducedcongressional appropriations. Efforts to formulate PRIA6 options in 2026 by environmental groups, farmworkeradvocacy organizations, and registrant groups will aim tokeep this broad coalition together to support legislative approval of any proposal.
As the October 1, 2026, deadline approaches for completing the initial reviews of 734 cases of pesticides registered before October 1, 2007, and 65 new active ingredients registered after 2007, EPA is under tremendous pressure to complete its review of the remaining cases before the statutory deadline. We provide an in-depth review of ongoing activities in the full Forecast 2026, which is available to download from our website: https://www.lawbc.com/2026-forecast-for-u-s-federal-and-international-chemical-regulatory-policy/.
On Tuesday, January 27, 2026, at 11:00 a.m. (EST), B&C will present "What to Expect in Chemicals Policy and Regulation and on Capitol Hill in 2026," a complimentary webinar building upon Forecast 2026's analysis of trends and key developments in 2026. We invite you to join Lynn L. Bergeson, James V. Aidala, Richard E. Engler, Ph.D., and Ryan N. Schmit as they discuss policy shifts and uncertainties expected under the Toxic Substances Control Act (TSCA), FIFRA, and ESA and take your questions regarding what to expect in 2026.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
