Congress Gave EPA Until Oct. 1 to Review Every Pesticide. One Chemical Made It.

The Federal Register notice that appeared on Sept. 28 is barely a page: the Environmental Protection Agency announcing that its final registration review decision for 4-chlorophenoxyacetic acid — 4-CPA — is now available, at 91 FR 61228. The signature on it belongs to Jean Anne Overstreet, director of EPA's Pesticide Re-Evaluation Division inside the Office of Chemical Safety and Pollution Prevention, and it is dated Sept. 23.

Three days after that notice published, the deadline arrived.

The deadline is not EPA's invention. It is Congress'. Under the Federal Insecticide, Fungicide, and Rodenticide Act, every registered pesticide is supposed to get a fresh safety review once every 15 years, and the current cycle — covering the chemicals registered before October 2007 — carried a statutory completion date of Oct. 1, 2026. What slipped through the gate on time was one active ingredient used to hold back root growth during the germination of mung beans, registered for indoor use only. EPA's review found no risks of concern across dietary, occupational, residential or aggregate exposure, needed no risk mitigation, produced a "no effect" finding for the mung bean use under the Endangered Species Act, and closed out the chemical's Endocrine Disruptor Screening Program obligations. No label changes were required beyond a clarification that the product stays indoors.

Sitting in the same queue, with far larger footprints in Texas fields, is chemistry that critics of the deadline extension name most often: several organophosphates and neonicotinoids, neither of which is finished.

Getting an exact count of what remains is harder than it should be, and the two published estimates measure different things. The regulatory law firm Bergeson & Campbell, which tracks EPA's pesticide docket, puts the number of active-ingredient cases subject to the October 2026 deadline at roughly 800 and says the agency has finished only a small share of them; the firm expects Congress to need to pass another extension before the rest are done. The Center for Biological Diversity counted differently in April 2026: of 726 review packages covering more than 1,100 active ingredients, the group said EPA had issued final decisions for roughly 150, most of them antimicrobials and low-toxicity products such as mosquito repellents. One count tracks ingredient cases, the other tracks review packages, and they were compiled months apart. Both describe the same long, slow line.

A fix is already drafted. Section 10204 of the Food, Farm, and National Security Act, the 2026 farm bill proposal moving through Congress, would push the registration review deadline out to Oct. 1, 2031 without attaching any new conditions to the extension. More than 30 national and regional organizations have written to Congress to oppose an unconditional delay, pointing at the size of the office doing the work: EPA's pesticide program has fallen from more than 900 full-time employees in 2004 to about 520 in 2026.

Worth being precise about what a missed review deadline does and does not do. It does not pull anything off the shelf. Pesticides whose reviews are unfinished stay registered, stay legal, and keep being sold and applied under their current labels while the evaluation grinds on. What the deadline's passage costs is leverage — the statutory pressure that was supposed to force the queue to move.

Texas has been working the exception route rather than the standard one. When the pasture mealybug turned up in dozens of Texas counties and there was no labeled chemistry for it, AgriLife Extension went to EPA with an emergency exemption request, and on Aug. 11 Centric 40WG came back approved under a FIFRA Section 18 crisis exemption. Ranchers got a tool. They also got a control window that runs an estimated 21 to 28 days, in the assessment the Texas & Southwestern Cattle Raisers Association published on Oct. 8, which means populations can rebuild and a single application rarely ends the problem. That is what a stopgap looks like when the routine review machinery is years behind: the work gets done one emergency at a time.

EPA did close 19 review cases this fall, announced on Sept. 15 — but not because the agency finally reached them. Those cases closed because the last U.S. registrations for alpha-chlorohydrin, citral, dicloran, fenitrothion, ferbam, methiocarb, methyl-parathion and the rest had already been canceled, in most instances by manufacturers who chose not to fund the data EPA asked for. The agency's own announcement describes the action as "safely concluding their registration review process."

So the scoreboard for the 2026 deadline reads like this: one chemical reviewed and cleared, a batch of cases retired by cancellation, roughly 800 packages or 1,100 ingredients still open, and a bill sitting in Congress that would move the finish line five more years down the road.