By: Adrienne Held

BASF has submitted a proposed label for its dicamba product, Engenia, to the Environmental Protection Agency (EPA) for registration after the label was vacated earlier this year. 

The proposed changes include a maximum of two applications for both cotton and soybeans and a maximum annual rate of 25.6 oz per acre, which is half the previously labeled rate. In soybeans, a June 12 application cutoff date with applications allowed before, during, and after planting including over-the-top (OTT) through the V2 growth stage (second set of trifoliates leaves are fully unfolded). This is a slight change from the proposed Bayer XtendiMax label last month in which no OTT application is allowed in soybeans. In cotton, OTT uses will be allowed with a cutoff date of July 30. 

What does this mean for farmers who use dicamba in soybeans to battle resistant weeds like Palmer amaranth, waterhemp, and others that emerge after June 12? 

“It will force growers to be more reliant on residual preemergence herbicides, and on glufosinate postemergence for those growing dicamba-tolerant soybeans,” says Bill Johnson, weed science specialist with Purdue University. “It will increase selection pressure for glufosinate resistant pigweeds.” 

The registration for Engenia was vacated earlier this year, and the EPA issued an existing stocks order, allowing farmers to use dicamba sold before Feb. 6. 

In a statement, BASF said the proposed label reflects its interest in supporting growers’ needs to overcome weed resistance in soybeans and cotton. BASF noted that any final product label approved by the EPA may differ from the current label proposal.  

Alan Meadows raises soybeans in Tennessee and serves as an American Soybean Association director. Having the option to apply dicamba postemergence in his soybean fields has offered a tool for effective management of Palmer amaranth and waterhemp. “While I do wish the proposed OTT application window in soybeans was later, it’s better than nothing.” 

Meadows expressed that there is uncertainty moving forward around dicamba and alternate options. “We do have the option with XtendFlex soybeans to apply glufosinate postemergence,” he said. “But there was a reason why we moved away from that to dicamba. Without a later dicamba application window, we’ll be forced to go back to that or change technologies altogether.”

Brady Holst raises corn, soybeans, and wheat near Augusta, Illinois, and serves as at-large director of the Illinois Soybean Association. He also feels that the dates for the proposed dicamba labels are too restrictive. “Farmers like to have as many tools in the toolbox as possible. We were late getting started in Illinois this year and the June 12 cutoff date would have a huge impact this year. I think farmers will take that into account when deciding what traits to use,” says Holst. 

Because the application involves a new use pattern for dicamba, in order to stay consistent with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), EPA is required to provide a 30-day public comment period and is also seeking comment on the associated draft labeling that BASF has submitted. This comes on the heels of the comment period for Bayer’s XtendiMax that ended on June 3, 2024, and had more than 18,500 comments. The last day to submit a comment regarding Engenia’s proposed registration and label is July 5, 2024.

In a statement, BASF said, “We remain committed to working with regulatory authorities and other stakeholders throughout this process so OTT uses of dicamba remain an option for farmers in the future. The 30-day public comment period is a crucial step in ensuring that the voices of interested stakeholders are heard and considered in the EPA’s assessment, and we encourage farmers and industry stakeholders to contribute their insights and perspectives on the use of dicamba as a valuable tool in controlling resistant weeds.” 

The EPA can take up to 17 months to review the application from the date that the action gets processed. If it uses the 17 months, it may mean that dicamba use may remain prohibited for the 2025 crop season. If needed, an endangered species evaluation by the U.S. Fish and Wildlife Service could add additional time.

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