On May 30, 2023 Governor Tim Walz signed bill HF 100 legalizing the production and sale of recreational marijuana in Minnesota starting August 1, 2023.
For more information about the new program, please visit the Office of Cannabis Management.
Pesticide Use on Cannabis
The MDA recognizes that cannabis growers have limited options for managing pests on their crop. There are no EPA registered pesticide products approved for use on cannabis due to a lack of established tolerances under the Code of Federal Regulations (40 CFR Part 180). However, growers may be able to use certain pesticide products on cannabis if the label language for these products does not prohibit their use. For this reason, the MDA has prepared some guidance to assist growers in their determinations of pesticide products that may potentially be used on cannabis.
Please note that the MDA does not intend for this guidance to endorse the use of pesticides on cannabis. Additionally, please note that any use of a product in a manner inconsistent with its labeling is a violation of Federal law.
The MDA has the authority to inspect and enforce the use of products on cannabis based on product labeling. It should be noted, however, that the final determinations for MDA enforcement actions are made by the MDA staff on a site and case specific basis.
Products that may be acceptable for use on cannabis
WARNING: The following guidance can be used for determining whether a product may be used on cannabis or not. This guidance is based on the product label language only and does not evaluate safety or risks to human health or the environment. The EPA is responsible for evaluating human health risks for pesticides on crops. The EPA has not evaluated human health risks for any pesticide on cannabis. Pesticides may pose risks to human health, especially when the crop they are applied to is ingested or inhaled.
- Minimum Risk Pesticides: As per the United States Environmental Protection Agency (USEPA) determination, minimum risk pesticides pose little to no risk to human health or the environment. The USEPA has exempted minimum risk pesticides from the requirement of registration under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (40 CFR 152.25(f)). This exemption provision can be found in the MDA's Registered Product Search. At this time, the MDA does not register minimum risk pesticides. Though the MDA is not currently registering these products, it does regulate these pesticides and may take enforcement actions for violations of their label language. As with any other pesticide, the applicators should read and follow the label carefully when using minimum risk pesticides.
- Select EPA Registered Pesticides: As there are no federally approved pesticides for use on cannabis, an EPA registered pesticide may only be used on cannabis if both scenarios below are met:
- The pesticide product is actively registered in the state of Minnesota.
- A products registration status may be found on our MDA's Registered Product Search; and
- The label language does not explicitly prohibit the product’s use on cannabis. The majority of EPA registered pesticide products can only be used on specific crops/sites listed on the label. Labels specifying use for specific crops and/or crop groups would disqualify a product from use on cannabis. However, growers may be able to use certain pesticide products on cannabis if the label language for these products does not explicitly prohibit their use.
- Some examples of product label language which does not prohibit their use on cannabis include:
- "can be used on the following crops, including but not limited to:"
- “may be used on most crops since the active ingredient is exempt from residue tolerances when applied to growing crops."
- “VEGETABLE, CEREAL GRAINS, AND OTHER MISCELLANEOUS CROPS (including but not limited to)”
- "Crop Use: [Product Name] is an effective insecticide for crops and orchards"
- Some examples of product label language which exclusively prohibit use of pesticide products on cannabis include:
- "FOR USE ON SELECT AGRICULTURAL GREENHOUSE CROPS"
- "For greenhouse applications on the crops and pests listed"
- "crops including but not limited to: group 4, group 5, group 8, group 19"*
- “For use on the following crops”
- “For use on Fruit Trees, Shade Trees, Roses, Ornamental Shrubs, and Vegetables as listed on this label.”
- “Not for use on agricultural establishments growing agricultural crops or commodities for resale.”
- “For household use only.”
- Some examples of product label language which does not prohibit their use on cannabis include:
- The pesticide product is actively registered in the state of Minnesota.
If after reviewing the following guidance there is still doubt about any product use, consult the MDA prior to using that product.