American Regeneration Submits Comments to EPA on Alternatives to Pre-Harvest Desiccation
On September 30, 2026, American Regeneration submitted formal comments to the Environmental Protection Agency in response to its Innovation Challenge: Alternatives to Conventional Pesticides for Crop Desiccation (Docket EPA-HQ-OPP-2026-3862). The $30 million Challenge seeks practical, cost-effective alternatives to the chemical desiccants many producers spray on crops shortly before harvest. The expertise of our Advisor Team was vital to collecting the most current, accurate data and creative farming strategies for the submission.
Pre-harvest desiccation has become common over the past several decades as a way to control harvest timing, dry down crops in wet weather, and even out field maturity. Glyphosate, paraquat, diquat, saflufenacil, and other chemistries are applied to small grains, pulses, oilseeds, and potatoes. The practice is concentrated in regions with cool, damp, short growing seasons, such as North Dakota, where estimates suggest up to 80% of small grain and oilseed acreage may be sprayed. It also carries human and environmental health concerns, along with financial drawbacks for farmers, including reduced grain quality and potential yield loss.
Our comments draw on peer-reviewed agronomic research, government and industry data, international case studies, and conversations with producers, buyers, and certifiers. Key recommendations include:
Close the data gap. Federal surveys don’t capture desiccant use specifically. We recommend setting aside 5% of Challenge funds to establish baseline data.
Scale proven methods. Swathing, improved seed varieties, earlier planting, and mechanical vine management already work. In one Canadian canola study, swathing had the lowest yield loss and lowest harvest cost of four methods tested.
Partner with brands. We propose that awards center on partnerships between food brands and grower groups, backed by binding, multi-year buying commitments for desiccant-free crops and matched private funding.
Fund four tracks: shared mechanical equipment and training, farmer-to-farmer networks and soil health education, traditional breeding for determinate and even-maturing varieties, and a capped track for emerging technologies like electrothermal systems and bioherbicides.
Use complementary policy levers. These include registration review, aligning U.S. residue tolerances with major trade partners, expanded import testing, crop insurance flexibility, and a consumer-facing desiccant-free label.
Beyond the Challenge itself, this analysis adds to the growing body of knowledge on pre-harvest desiccation. It covers which crops and regions rely on desiccants most, what alternatives exist today, why adoption has stalled, and how market forces are already shifting as buyers and export markets reject chemically desiccated grain. We hope it serves as a resource for farmers, researchers, brands, and policymakers working toward a cleaner, more resilient food system.