Courtesy of Dr. Anne Nielsen
Memorandum to U.S. Growers on Use of Chlorpyrifos Insecticide
Products in Food Crops for 2024
Background: On February 2, 2024, the U.S. Environmental Protection Agency (EPA) published an “Update on the
Use of the Pesticide Chlorpyrifos on Food.” This EPA update referenced a Federal Register Notice amending
EPA’s rules to reflect the status of chlorpyrifos food tolerances that were previously revoked in 2022. EPA’s update
is provided verbatim in the Appendix to this document (page 4). EPA also posted a notice on March 15, 2024
amending an existing stocks provision for ADAMA product cancellation orders:
https://www.federalregister.gov/documents/2024/03/15/2024-05594/chlorpyrifos-amendment-to-existing-stocksprovisions-in-adama-product-cancellation-orders
In response to questions around which chlorpyrifos products remain registered and available for use on food crops
in 2024, USDA is herein providing a listing in Table 1 (pages 2-3 below) for reference. This table lists chlorpyrifos
products that may be used on food, including products that are still registered and others that have been cancelled
but may still be used on food crops under existing stocks provisions, all on the left on the first page of the table and
highlighted in GREEN. USDA is also providing a list of the chlorpyrifos products that have been cancelled and for
which no use on food crops is permitted, highlighted in ORANGE. USDA’s reference source for this information was
EPA’s multiple public cancellation notices, published via the Federal Register. The chlorpyrifos product status
information has been confirmed by EPA’s Office of Pesticide Programs. These lists are current as of March 21,
2024 and USDA will work to provide further updates with future EPA actions1.
Points for Clarification:
1. As is always the case, the label is the law: when using chlorpyrifos products identified below that may be used
on food, growers may only use chlorpyrifos in accordance with the label use directions of the product that is in
hand. Not every product listed in Table 1 allows for all food uses. Growers must read the label and confirm that
their use is legal for the product they intend to use.
2. As noted by EPA, individual states may impose additional restrictions or prohibitions on chlorpyrifos use,
beyond what is on any EPA-approved product label. Some states have previously enacted full or partial bans
on chlorpyrifos use, including California, Hawaii, Oregon, New York, Maryland, etc. For states that have already
prohibited or further restricted the use of chlorpyrifos, EPA’s actions DO NOT supersede such restrictions.
3. While U.S. food tolerances for chlorpyrifos have been restored at this time, international maximum residue
limits (MRLs) still apply for many agricultural products. Growers should confirm the status of chlorpyrifos MRLs
for their relevant export markets and consider all existing restrictions in any chlorpyrifos use decisions for 2024.
4. USDA’s listings in Table 1 apply to products containing chlorpyrifos for food uses. This table focuses on
products allowed for use on food and should not be used as a reference for any non-food use site such as turf,
ornamentals, tobacco, non-crop areas, structures, indoor uses, etc. Non-food use products ARE NOT and
never have been legal for use on any food crops. However, it should be noted that some products include both
food and non-food uses.
5. Questions for USDA can be directed to Kimberly Nesci (Kimberly.Nesci@usda.gov) or Clayton Myers
(Clayton.Myers@usda.gov) at the Office of Pest Management Policy. Growers can also contact EPA
(OPPChlorpyrifosInquiries@epa.gov) or state/local pesticide regulatory officials for further information.
1 The information provided in this memorandum is not intended to be, nor should it be construed, as legal advice. Information may be
subject to change without notice.