Summary of Comments on PRO2026-01, Consultation on permitting pesticide application by Remotely Piloted Aircraft Systems (RPAS; commonly known as drones) for products currently registered for aerial application
Health Canada
Healthy Environments and Consumer Safety Branch
Pesticides Regulatory Directorate
30 June 2026
Executive summary
Health Canada sought input from stakeholders in winter 2026 on Regulatory Proposal PRO2026-01, Consultation on permitting pesticide application by Remotely Piloted Aircraft Systems (RPAS; commonly known as drones) for products currently registered for aerial application. More than 150 comments were received from across the country with representation from industry, user associations, farmers, provinces, non-governmental organizations, and members of the public. Health Canada is grateful to all participants for their time, expertise, and thoughtful contributions that have helped shape the final policy – SPN2026-02, Allowing Pesticide Application by Remotely Piloted Aircraft Systems (RPAS; commonly known as drones) for Products Currently Registered for Aerial Application. In general, comments received could be categorized into various themes. This document is intended to summarize those themes and outline changes that were made to the policy in order to address them.
General support and concerns
Over 80% of respondents expressed support for the proposal, with many citing the anticipated benefits of the technology and advocating for expedited timelines for implementation to support agricultural productivity and Canada's global competitiveness. Other comments recommended a more phased implementation approach to allow for individual product assessments and training materials to be developed. Of the stakeholders who were not supportive of the policy, some raised concerns related to broader risks to human health, pollinators, and the environment, while others noted that increased accessibility of RPAS (for example, due to lower costs and simpler deployment compared to conventional aerial application) could lead to greater overall pesticide use.
Standardization, training, and certification
Stakeholders feedback on this topic highlighted the need for standardization of equipment and operational practices for RPAS pesticide application. Several commenters noted the need for the development RPAS specific spray quality frameworks, similar to ANSI/ASABE S572 – Spray Nozzle Classification used for conventional aerial spraying, given concerns of the variability that has been observed between proprietary rotatory atomizer designs available on the market. With respect to operational practices, stakeholders emphasized the need for standardized approaches to labelling and consistent protocols for recording keeping, flight planning, calibration, mixing and loading, maintenance and decontamination.
Respondents also identified gaps in the regulatory proposal regarding training and certification, emphasizing the need for clearer expectations for pilot competency and programs that bridge drone operation and pesticide application expertise, including practical instruction on spray dynamics, drift mitigation, and factors affecting efficacy. Recommendations included the development of standardized RPAS-specific training and certification programs, supported by supplementary measures such as flight reviews, specialized agricultural certifications, and hands-on training and coordinated efforts across provinces and territories in collaboration with Health Canada and other regulatory bodies, industry, and academic institutions.
Compliance and enforcement
Stakeholders providing feedback on this theme raised several considerations related to compliance and enforcement, such as clarifying how requirements will be enforced beyond label directions under the Pest Control Products Act and complementary provincial and municipal frameworks. Some expressed concerns about potential non-compliance with label requirements and requested individual label amendments before finalizing the policy. Other stakeholders emphasized the potential value of integrating technological solutions, such as GPS logging, calibration standards, and digital record-keeping, to support monitoring, traceability, compliance, and enforcement. One commenter also requested clarity on whether the policy would have any impact on maximum residue limits.
Buffer zones and spray drift
Stakeholders commenting on this theme expressed differing views on appropriate buffer zones, with some indicating that RPAS drift characteristics are more comparable to ground equipment and supporting less conservative approaches, while others emphasized uncertainties related to deposition variability and rotor wash, warranting caution to protect non-target areas. Comments on this topic also highlighted the need for clearer policy rationale (for example, surrogate selection and buffer zone assumptions) and supported the development and adoption of internationally aligned RPAS-specific drift models and tools, such as Unmanned Aerial Pesticide Application System Task Force (UAPASTF) or Organisation for Economic Co-operation and Development (OECD) approaches, including eventual integration into buffer zone calculators.
Worker exposure
Stakeholders commenting on personal protective equipment (PPE) generally supported the use of ground-based PPE as a surrogate for drone operations. However, some stakeholders commenting on this topic emphasized the need for clearer, consistent, and standardized requirements in the policy, including clarification of closed-cab and closed-mix provisions that are on some pesticide labels and resolving perceived inconsistencies in current policy language (for example, using aerial label directions but following ground equipment PPE).
Several stakeholders did not support the separation of roles for the pilot and mixing and loading citing feasibility and compliance challenges, lack of alignment with existing ground application practices, and evidence suggesting that exposure risks are driven more by mixing practices and PPE than by pilot role. However, a minority of stakeholders expressed support for the separation of roles.
Other comments
Some stakeholders requested greater clarity on policy scope, including whether multi-drone operations (swarming) is permitted, how the policy applies to tank mixes with foliar fertilizers, and requirements for transporting dangerous goods. Some also suggested expanding the policy to address broader considerations, such as restricting aerial use in residential areas and enabling night spraying to reduce pollinator exposure.
Summary of changes integrated into the final policy
In response to stakeholder feedback, the policy was expanded to improve clarity and address key operational, safety, and regulatory considerations for RPAS pesticide applications. An RPAS user pamphlet was also developed to inform users of the steps to take before applying pesticides by drones and support them in interpreting and following the policy and pesticide label directions.
Clarifications were introduced to strengthen compliance and enforcement, including confirmation that requirements are supported through both product labels and the policy, alignment with Transport Canada regulations (including transportation of dangerous goods), and confirmation that existing maximum residue limits apply to RPAS use. It was emphasized that the aerial directions for use must be followed except for PPE and safety measures for the drone pilot, where ground application requirements must be used. Label expectations were clarified to ensure adherence to aerial application requirements, while recognizing practical limitations of RPAS design. Additional operational guidance was provided to support safe use, including requirements for loading practices, positioning workers upwind of drone spraying, and visual line-of-sight conditions.
The policy also clarifies training and operational requirements, including the use of the RPAS Pesticide Applicator Manual and Transport Canada pilot certification. Expanded guidance was provided on calibration, spray performance, drift mitigation, and PPE for drone pilots. The policy also explains the conservative risk management approach for buffer zones and separation of roles and the potential for future refinement as RPAS-specific data become available. Additional updates include confirmation of acceptable pesticide value when label directions are followed and allowance for multi-drone operations (swarming) where permitted by Transport Canada.
Collectively, these changes seek to address comments received from stakeholders and enhance clarity; supporting the safe and consistent integration of RPAS within the existing regulatory framework.
Next steps for supporting RPAS use in Canada
Health Canada will continue to support the effective implementation of RPAS pesticide application by enhancing clarity, strengthening collaboration, and incorporating evolving science. Ongoing collaboration with provinces, territories, the Federal/Provincial/Territorial Pesticide Education and Training Certification committee, industry, and international partners will remain a priority to advance standardized approaches to training, certification, health and environmental risk assessments, and operational practices, as well as to support alignment with global initiatives, including the development of improved models for drone-based pesticide application.
Health Canada will continue to monitor emerging scientific evidence, and operational experience, including through its continuous oversight and incident reporting programs, and consider stakeholder feedback to inform future refinements to the policy.