After more than six weeks of limited federal operations, the government funding bill has been signed and EPA employees are returning to work. But for pesticide companies regulated under FIFRA, this reopening won’t mean an immediate return to normal. The EPA’s Office of Pesticide Programs (OPP) was already operating with reduced staff due to layoffs and retirements earlier in 2025, and the shutdown added weeks of inactivity to an already strained system. As a result, registrants should anticipate extended review times for new product applications, label amendments, and PRIA actions, as well as renewed enforcement once inspectors are back in the field. The coming months will be a period of triage, communication, and strategic planning for companies navigating EPA’s backlog.
EPA Staffing Cuts Before the Shutdown
The EPA entered the recent government shutdown already short on staff. In early 2025, the agency announced a major workforce reduction, cutting its staff from roughly 16,000 to around 12,400 positions in an effort to reduce costs and restructure internal programs (EPA News Release, Jan 2025). By the fall, reports indicated that about 4,000 employees had departed through layoffs, retirements, and voluntary separation programs (Federal News Network, Oct 2025). Reuters later confirmed that 388 staff, many of them newer hires, were formally terminated in February as part of that process (Reuters, Feb 2025).
This combination of attrition and layoffs meant that, by the time the government shut down, the EPA’s Office of Pesticide Programs (OPP) was already operating with a smaller workforce and thinner institutional capacity. The 43-day shutdown only compounded that strain, leaving a reduced team to manage a large backlog of pesticide registration actions, label amendments, and tolerance reviews once operations resumed.
The Shutdown’s Impact on Pesticide Work
During the shutdown itself, nearly 90 percent of EPA employees were furloughed. According to the agency’s contingency plan issued on September 29, 2025, almost all activities stopped except those tied to emergencies or programs funded by dedicated user fees, such as certain actions under the Pesticide Registration Improvement Act (PRIA) (EPA.gov). This meant that most FIFRA registrations, label amendments, and experimental-use permits were frozen in place. Even where PRIA funding technically allowed work to continue, the absence of key staff and cross-office support brought progress nearly to a halt.
Routine compliance inspections also stopped, leaving months of enforcement activity to catch up on later. Now that funding has been restored, OPP is slowly resuming normal operations, but “normal” will look very different for the foreseeable future.
What the Reopening Will Look Like
The first and most obvious challenge is the sheer volume of pending work. Thousands of FIFRA applications spanning new active ingredients, formulation amendments, label updates, and data-requirement waivers—have accumulated in OPP’s queue. Consultants and industry observers expect it will take months to clear this backlog, and registrants should plan accordingly (SRC Consultants, 2025).
Within that backlog, the EPA is likely to prioritize fee-funded submissions, high-priority public health products such as mosquito-control or antimicrobial uses, and any actions subject to court orders. Routine amendments and renewals will likely be handled later. This triage process is not new, but given both the staffing cuts and the shutdown pause, it will be more pronounced than in past years.
Even once OPP staff return to their desks, administrative recovery will take time. Internal systems need to be restarted, project teams re-coordinated, and review assignments re-issued. Applicants should expect slower-than-usual responses to clarification requests, label reviews, or data-requirement decisions while staff work through a flood of correspondence that built up during the funding lapse.
These federal delays will ripple down to the states as well. Many state pesticide programs rely on EPA approvals to finalize their own registrations or local-needs (24(c)) decisions. Until the federal queue starts moving again, some states will be unable to complete their processes. For registrants, that means potential hold-ups not just at the federal level but in key markets like California, New York, and Washington that depend on EPA determinations before issuing state approvals.
Enforcement will also ramp back up quickly. The Office of Enforcement and Compliance Assurance and its state partners are restarting inspections that were paused in the fall. Facilities that produce, distribute, or relabel pesticides should be prepared for renewed scrutiny of labeling accuracy, production records, and registration compliance. As Holland & Hart noted during previous shutdowns, “routine inspections and civil enforcement generally pause during shutdowns and resume once funding is restored” (Holland & Hart, 2025). Companies that take time now to review documentation and correct inconsistencies will be better positioned when inspections resume.
What Pesticide Companies Should Do Now
For registrants and manufacturers, the next few months should be treated as a regulatory recovery period rather than a return to normal. Start by taking a full inventory of your submissions to EPA, whether new product registrations, label amendments, or tolerance petitions, and categorize which are PRIA fee-funded versus those handled through general appropriations. Fee-funded actions may progress faster because they have dedicated funding streams, but all will move slower than usual.
Companies should also re-establish contact with their regulatory consultants or EPA points of contact as soon as possible. Confirm that submissions are active, identify where they sit in the queue, and ask whether new target completion dates will be issued once the agency rebalances workloads. The earlier you re-engage, the more likely your applications are to stay visible as the agency triages competing priorities.
Internally, it’s wise to build additional time into your project schedules. Label reviews that might normally take eight to twelve weeks could stretch to double that. Delay label printing or marketing rollouts until approvals are confirmed, and make sure sales and operations teams understand that registration timing is once again uncertain.
Compliance readiness is another priority. Before inspections restart in earnest, review your approved labels, Confidential Statements of Formula (CSFs), and production records to ensure everything matches what’s on file with EPA. Confirm that distributor labels remain aligned with the EPA-approved master label, and that all recordkeeping under FIFRA Section 12(a)(1)(E) is current. A short internal audit now could prevent an enforcement headache later.
Finally, monitor EPA communications closely. OPP often publishes internal updates or process changes following major disruptions, and these can affect how PRIA timelines are recalculated or how submissions are assigned. Regularly check the EPA Pesticides homepage and the Federal Register for any notices that signal new priorities or revised workflows.
Key Takeaways
The reopening of the EPA is a welcome development, but for pesticide companies it marks the start of a long recovery period rather than an immediate return to business as usual. Staffing cuts earlier in the year have left OPP with fewer reviewers, and the shutdown itself added six weeks of idle time to an already strained system. Registrants should expect extended timelines for FIFRA applications and label amendments, slower correspondence, and a gradual ramp-up of inspections and enforcement.
The best strategy now is to stay proactive: communicate early and often with regulators, build flexibility into your launch timelines, and tighten your compliance documentation. In an environment defined by backlogs and limited capacity, preparedness and persistence will determine which companies move through the queue first.
