Science Policy Document SPN2026-02, Allowing 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
ISSN: 2368-1861 (PDF version)
Catalogue number: H113-13/2026-2E-PDF (PDF version)

Table of Contents

• 1.0 Introduction
• 2.0 Background
• 3.0 Allowing RPAS application when aerial application is present on the registered     pest control product label
• 4.0 Importance of proper RPAS use
• 5.0 Registrants opting out
• 6.0 Restricted uses
• List of abbreviations
• Glossary
• References

1.0 Introduction

1.1 Purpose

The purpose of this document is to communicate the change in policy regarding the use of remotely piloted aircraft systems (RPAS; commonly known as drones) to apply pest control products (or pesticides) that are already registered for conventional aerial application. This policy is intended to be read in conjunction with the Pest Control Products Act and the Pest Control Products Regulations. Pesticides not registered for aerial application still require a Health Canada approved label amendment in order to use RPAS for pesticide application in accordance with existing registration processes.

Health Canada acknowledges the importance of proper training to ensure RPAS are used correctly and that RPA pilots and the field crew understand safe pesticide application practices, using required personal protective equipment (PPE) and engineering controls, where required, and following all label directions. RPAS operations must comply with both Federal and Provincial/Territorial regulations and policies, as regulation of pesticides in Canada is shared among all levels of government.

With the publication of SPN2026-02, existing aerial application labels together with this policy will support the compliance and enforcement approach for the application of pesticides by RPAS. In addition, Health Canada will continue to track incidents associated with pesticide use, including those involving RPAS, through its Incident Reporting Program, as well as information related to potential environmental and human health risks through its Continuous Oversight approach. Regulatory or policy measures may be updated if new risks are identified.

1.2 Supporting innovation in pesticide application through RPAS

Applying pesticides by air is an important crop protection tool in Canadian agriculture and industrial vegetation management. Aerial application using conventionally piloted aircraft (fixed-wing or rotary) is often the preferred and sometimes the only practical option when terrain is soft, wet or too difficult for ground application equipment; when pest outbreaks occur late in crop growth; or for areas that are either too large or inaccessible for ground application. The use of RPAS introduces a new way to apply pesticides in Canada.

Health Canada recognizes that using RPAS can give pesticide users more flexibility and clear benefits compared to traditional application methods. Allowing RPAS to be used without requiring changes to product labels will help these benefits reach Canadian pesticide users faster and avoid extra regulatory requirements.

This approach encourages innovation and supports the development of technologies that work well for Canada’s agricultural conditions. It also aligns Canada with other countries like the United States and Australia, helping Canadian agriculture stay competitive internationally.

Using RPAS to apply pesticides can make farming more efficient by helping farmers protect crops while using fewer inputs—such as pesticides and other resources needed for crop production, including labour, fuel and equipment use. This will support food security and help keep food affordable. By encouraging research and development and combining RPAS with digital tools such as mapping and crop monitoring, this approach supports more informed and precise pest management and broader goals for sustainable agriculture. Over time, these advances could also support new uses of aerial application in other sectors where it has not traditionally been used.

2.0 Background

The Pest Control Products Act and Regulations require that registered pest control products include clear directions for use on their labels. This ensures products are used safely and effectively.

In Canada, RPAS operation is regulated by Transport Canada, whereas the regulation of pesticides, including registration and label use directions, is under the jurisdiction of Health Canada. Transport Canada considers aerial drones to be aircraft, and all RPA pilots must understand and follow Canadian Aviation Regulations (SOR/96-433).

As explained in Health Canada’s 2023 Information Note on Drones, pesticides can currently only be applied by RPAS if the product label specifically allows it. This restriction was originally put in place because there were limited RPAS-specific data and information on RPAS use to sufficiently characterize the potential risks associated with this method of application.

Since then, Health Canada has worked with partners in Canada and internationally, to gather new scientific data. This includes information on dietary exposure (food residue levels) and environmental risks (spray drift) associated with RPAS use. The results support a more flexible approach to allowing RPAS use (see Section 3.0).

The data show that the risks of applying pesticides by RPAS are generally similar to those of conventional aerial application. However, RPAS have unique features. They are remotely piloted and have the potential to apply pesticides very precisely, similar to some ground-based spot treatments. Because of this, worker exposure considerations overlap with both aerial and ground application methods.

3.0 Allowing RPAS application when aerial application is present on the registered pest control product label

3.1 Basis of the science policy

For aerial application to be permitted, registered end-use products must include specific instructions for such use. Furthermore, if the label states “DO NOT apply by air” or the label does not include aerial application, then aerial application is prohibited. This label restriction also applies to the use of RPAS for pesticide application.

For currently registered end-use products, where the product label permits aerial application (in other words, conventionally piloted fixed-wing or rotary aircraft), Health Canada allows their application using RPAS, including multi-drone operation (swarming), where permitted by Transport Canada. While differences exist between RPAS application and what is currently considered as conventional aerial application methods, recent advances outlined below have demonstrated that the existing label directions are sufficient to address the potential health and environmental risks related to the application of pesticides by RPAS. Application using RPAS requires users to follow all label directions for aerial application, with no changes to spray volume, application rate, droplet size, spray buffer zones, or any other conditions of use specified on the label, with some clarifications regarding nozzle placement, and PPE and safety measures for RPA pilots (more details provided in Section 3.5.2, PPE and safety measures for RPA pilots).

This policy is based on the following considerations:

• Value: Health Canada recognizes that pesticide performance, such as efficacy and/or crop tolerance, may differ when products are applied by RPAS compared to conventionally piloted aircraft. However, when the use directions currently appearing on the registered aerial label are followed without changes, using RPAS is still expected to provide acceptable value of the pesticide being applied, given the benefits associated with this technology. As a result, RPAS-specific value information is not required to support the addition of RPAS aerial applications to a pest control product label.
• That said, it is important that RPAS are used properly. Similar to the use of other pesticide application equipment, RPAS equipment must be correctly calibrated and operated to ensure a uniform spray pattern throughout the area being treated (see Section 4.0 for more details).
• Environment: Under SPN2026-02, RPAS operations must apply the spray buffer zones established for conventionally piloted rotary aircraft. These larger buffer zones are used as a precaution to protect sensitive habitats. This approach will remain in place until RPAS-specific spray drift models become available to support the establishment of RPAS-specific spray buffer zones. Once those models are available, registrants can request updated buffer zones from Health Canada to amend their product’s label, or new drone-specific spray buffer zones will automatically be added to product labels during regular review, provided the applicant or registrant has access to the supporting Task Force data.
• Conventional aerial spray buffer zones were chosen as a conservative surrogate for RPAS because drone spray drift is not yet well understood. While the literature review produced by the Organisation for Economic Co-operation and Development (OECD) Drone/Uncrewed Aerial Spray System (UASS) Subgroup of the Working Party on Pesticides (OECD 2021) and subsequent work by CropLife America (Bonds et al. 2024) suggest that the RPAS drift is closer to ground spraying, the research used to make this conclusion is not strong enough to generate reliable RPAS-specific spray drift curves. The industry-led Unmanned Aerial Pesticide Application Systems Task Force (UAPASTF) was formed to address the recommendations set forth in the OECD literature review, including the evaluation of spray drift potential from pesticide applications via RPAS. The new studies are being reviewed by Health Canada in collaboration with other regulators within the OECD Drone/UASS Subgroup. Early results suggest that RPAS drift may be higher than field sprayers and somewhat similar to airblast sprayers, but not close enough to use as a surrogate for RPAS spray buffer zones.
• Furthermore, some labels that allow aerial application for a given use may not have a corresponding field sprayer application for the same use, and even fewer include airblast application for that use. Considering RPAS represents an aerial application and SPN2026-02 permits RPAS application for products currently registered for conventional aerial application, it is therefore appropriate to apply the labelled aerial spray buffer zones. This approach will remain in place until drone-specific spray buffer zones can be calculated and added to product labels.
• Dietary exposure: Field crop residue data collaboratively generated by Agriculture and Agri-Food Canada (AAFC) and industry have been submitted and assessed by Health Canada. Health Canada concluded that pesticide residues on food crops resulting from RPAS applications are not higher than those resulting from conventional application methods. As such, current label directions for aerial application will be adequately protective of dietary health risks when pesticides are applied by RPAS. When the use pattern remains the same for RPAS compared to conventional application methods, additional residue data generated by RPAS application are not required to support this application method. Therefore, pesticide residues potentially remaining in/on the crop following treatment by RPAS can be adequately monitored through the established maximum residue limit (MRL) for that crop.
• Occupational exposure: RPAS can have an important safety advantage compared to conventional aerial and some ground application methods because the RPA pilot is not in close contact with the equipment during application—they control it remotely. Early research (Felkers et al. 2024 and Kuster et al. 2023) shows that the main sources of exposure happens during mixing, loading and maintenance (in other words, handling, clean-up, repair and battery changing) of the RPAS. While pesticide-specific studies are not available, the evidence suggests that the risk is unlikely to be higher than with conventional equipment. This is because some tasks, like mixing and loading, are similar, and others—such as application—must be done by different people, as required on pesticide labels for conventional aerial application.

3.2 RPAS directions for use when label instructions are not RPAS-specific

Based on the data and information reviewed so far, Health Canada requires the following:

Existing label directions for aerial application will continue to protect human health and the environment, with some clarifications needed, particularly around nozzle placement, as well as PPE and safety measures for RPA pilots (more details provided in Section 3.5.2, PPE and safety measures for RPA pilots).

3.3 Use pattern

Key elements of the existing aerial application label directions must be followed.

The use pattern, particularly:

• The application rate, number of application and retreatment interval
• The spray volume

  Caution: The spray volume must not be reduced below the minimum volume required for aerial application on the product label.

• The required aerial spray buffer zones
• Any additional requirements for aerial application specified on the label must be followed, except those related to the specific RPAS design (for example, nozzle distribution along the spray boom), as these are impractical to comply with.

Accordingly, the following label statement is not applicable to RPA: “Nozzle distribution along the spray boom length MUST NOT exceed 65% of the wing- or rotor-span.”

3.4 Other important directions for use

• Important precaution: To minimize exposure to spray drift, DO NOT position the RPA pilot, visual observer, or crew members down wind of the spraying drone.
• Separation of key roles
  • The person who mixes and loads the pesticide must not be the RPA pilot. This follows the label instruction: “Do not allow the pilot to mix chemicals to be loaded onto the aircraft.”^{Footnote 1}
  • If the label also states: “The pilot is allowed to load premixed chemicals with a closed system”, then the RPA pilot may load the RPA, as long as another person has already mixed the pesticide, and a closed transfer system is used during loading.
  • If a closed transfer system is not available, the RPA pilot must not load the pesticide.
• Applicator Manuals: Federal/Provincial/Territorial Committee on Pesticide Education, Training, and Certification (PETC) has developed applicator manuals for pesticide education, including conventional aircraft and RPAS use. These materials may be available as applicator manuals through the provincial or territorial agency responsible for delivering pesticide education and licensing programs.
• Product labels currently include the following references to applicator manuals:

  For conventional aerial application: applicators must comply with the National Aerial Pesticide Application Manual.

  For RPAS application: Remotely Piloted Aircraft System (RPAS) Pesticide Applicator Manual.

  While product labels currently registered for conventional aerial application refer to the National Aerial Pesticide Application Manual, RPA pilots and their crew can refer to the relevant provincial or territorial manuals in the jurisdiction (where applicable) where pesticide application is to occur. In addition, RPA pilots should consider the additional resources described in Section 4.0 to ensure they have the knowledge required to use RPAS safely, effectively, and in accordance with the label.

3.5 PPE and safety measures

All required PPE and safety measures must be followed during mixing, loading, piloting, handling (including battery changes), clean-up and repair activities.

3.5.1 PPE and safety measures for all individuals involved in RPAS application

All individuals involved in RPAS applications, including pesticide handlers (mixers/loaders), RPA pilots, visual observers (when required; as recommended by Transport Canada), and any workers present in the field during application must wear the minimum PPE required on the label. This requirement applies to anyone handling pesticides, lifting or carrying the RPA, changing batteries, or touching any part of the RPA, as pesticide residues may be present.

The required minimum PPE for all pesticide products applies to all activities and consists of a long-sleeved shirt, long pants, chemical-resistant gloves, socks and shoes. If the pesticide label requires additional PPE (like coveralls or goggles), engineering controls (like closed mixing/loading systems) or limits on the amount of pesticide handled per day, these requirements must also be followed.

For more information on PPE, consult the fact sheet on Personal Protective Equipment webpage on Canada.ca.

3.5.2 PPE and safety measures for RPA pilots

Before applying a pesticide, the RPA pilot must carefully read and understand the label and pay close attention to the applicable PPE requirements and safety measures.

• RPA pilots, visual observers, and any workers handling the RPA during application must follow the PPE and mitigation measures required for ground application (either groundboom or airblast equipment depending on the crop/use site).
• When one of the mitigation measures requires the use of a closed cab for ground application, the product must not be applied using an RPAS unless an equivalent “closed cab” protection, designed for RPAS, is available for the pilot. If such protection is not available, the pesticide cannot be applied using an RPAS. In these cases, the pilot should select an alternative product, allowed for aerial application, that does not require closed cab protection.
• If the product is registered only for aerial application, the PPE requirements for aerial application must be followed instead.

Important precaution for RPA pilots: Do not touch clean surfaces, like the remote controller, while wearing contaminated gloves. To reduce this risk, it is recommended that the person responsible for mixing and loading the pesticide also handle battery changes. This approach helps prevent the RPA pilot from transferring pesticide residues onto clean equipment. For more information, consult the fact sheet on Pesticide Gloves webpage on Canada.ca.

• Why gloves matter: Hands are the main way pesticides get into the body for workers, so wearing gloves is essential.

4.0 Importance of proper RPAS use

To ensure the effectiveness of pest control approach, the following factors must be carefully taken into account.

• RPAS operators should work closely with technology experts, manufacturers, and drone associations, such as the Canadian Agricultural Drone Association (CADA), to optimize pesticide applications. Similar to other pesticide application equipment, RPAS equipment must be properly calibrated to ensure a uniform spray pattern, droplet sizes that comply with label requirements (for example, ASABE S572, low-drift nozzles), and an effective and consistent swath width during each spray pass to minimize the potential for under- or over-application.
• Health Canada recommends that RPA pilots determine the actual swath width for each drone before its first application and whenever the operational parameters change, using available resources such as online videos (for example, demonstrating the use of water sensitive paper and/or Kromekote paper) and in-person training from industry experts or drone associations. Accurate swath width determination is critical for achieving optimal spray coverage while minimizing spray drift.
• Health Canada also encourages the RPAS industry to develop and adopt standardized classifications for droplet sizes produced by rotary atomizers, similar to ASABE S572 standard for hydraulic nozzles. All spray equipment with rotary atomizers sold in Canada should use these droplet size standards to support label compliance, reduce spray drift, maintain or improve application efficiency, and minimize exposure to workers and bystanders.

Federal Requirements – Certification by Transport Canada

To ensure the safe application of pesticides by RPAS:

• Pilots must undergo training and obtain appropriate certification. Prior to each flight, the RPA pilot must be familiar with the qualification of all crew members.
• Visual observers must hold, at a minimum, a basic RPA pilot certificate.

All RPA pilots (including pesticide users applying on their own land and commercial applicators) must register their RPA with Transport Canada and hold a valid RPA pilot certificate, issued by Transport Canada, that corresponds to the type and size of the RPA used for application.

• As an example, medium RPA (25 kg to 150 kg) require an Advance Pilot Certificate if operated within visual line-of-sight, or a Level 1 Complex Pilot Certificate if operated within lower-risk beyond visual line-of-site.
• When operations require visual line-of-site and the RPA pilot is unable to maintain it independently, an additional person—known as a visual observer—must be present to assist the pilot in maintaining unaided visual line-of-sight, in order to meet Transport Canada regulatory requirements. The visual observer is only required for operation of a small or medium RPA under certain conditions of advance operations.

Furthermore, when activities associated to the dispersal of pesticides classified as dangerous goods involve handling, transporting, offering for transport, and importing, these must be conducted in compliance with the Transportation of Dangerous Goods Act, 1992, and the Transportation of Dangerous Goods Regulations.

For more details, consult the Transport Canada website on Drone safety and Drone operation categories and pilot certificates: Overview.

Provincial and Territorial Requirements - Licenses, Certificates and Permits

For education and training related to handling or application of pesticides using RPAS, conventional aerial equipment, or both, individuals should contact their provincial or territorial agency responsible for delivering pesticide education and licensing programs. Before operating an RPAS, the pilot must ensure that all required permissions have been obtained, as provinces and territories may further restrict pesticide in a manner that considers provincial and territorial conditions. Provincial legislation regulates the sale, purchase, storage, transportation, use and disposal of registered products. For example, permits may be required for aerial application or buffer zones may be set around sensitive ecosystems.

The Standing Subcommittee on Pesticide Education, Training and Certification (WGPETC) works to align and foster consistency among the pesticide education training and certification programs across Canada at a national level to protect the health and welfare of pesticide vendors, handlers and applicators, the public and to protect the environment.

Before using RPAS to apply pesticides, pilots and crew members must ensure they understand provincial requirements, complete any training and certification required and obtain any applicable licences, permissions and permits for pesticide use that are required by provincial or territorial regulators.

Health Canada is committed to continue working with PETC and the Provincial and Territorial partners to support the development of training materials for RPAS.

5.0 Registrants opting out

Some registrants may decide that one or more of their products labelled for conventional aerial application should not be used with RPAS. If so, they should submit a Notification (Category F application) to update their product label to add the statement: “DO NOT apply by Remotely Piloted Aircraft Systems (RPAS)”.

6.0 Restricted uses

Aerial application of pesticides to forest management or woodland management sites, residential areas, and aquatic sites constitutes a Restricted use. End-use products must not be applied by air unless aerial application is specified for these use areas on the label and the application of the end-use product is consistent with label instructions, rates, and precautions.

RPA pilots, like all other pesticide applicators, must comply with these restrictions and obtain a permit from their province or territory to be able to apply pesticides to these areas.

List of abbreviations

ASABE

American Society of Agricultural and Biological Engineers

Kg

Kilogram

FPT

Federal/Provincial/Territorial Committee on Pest Management and Pesticides

OECD

Organisation for Economic Co-operation and Development

PETC

Pesticide Education, Training, and Certification

PPE

Personal Protective Equipment

RPA

Remotely Piloted Aircraft

RPAS

Remotely Piloted Aircraft Systems

UAPASTF

Unmanned Aerial Pesticide Application Systems Task Force

UASS

Uncrewed Aerial Spray System

Glossary

Crew member:

Any individual participating in some aspects of the RPAS operation.

Handler:

A worker who performs tasks that involve direct contact with the pesticide or with RPAS surfaces when residues may be present, including mixing and loading before application and tasks such as lifting or carrying the RPA, battery changes, clean-up, or repair during or after application.

Maintenance:

Work performed to inspect, lift, service, or repair the RPA, including battery changes or cleaning.

Operator:

in respect to an aircraft, means the person that has possession of the aircraft as owner, lessee or otherwise.

Pilot:

The individual who remotely controls the RPA using a remote controller or ground control station and is responsible for its flight operations, as defined by Transport Canada. The pilot must hold the required Transport Canada RPA pilot certificate and may be a pesticide user applying on their own land or a commercial applicator.

RPAS:

Set of configurable elements consisting of a remotely piloted aircraft, its control station, the command and control links, and any other system elements required during flight operation.

Visual observer:

A crew member who is trained to assist the RPA pilot in ensuring the safe conduct of an RPA flight by maintaining unaided visual line-of-sight with the aircraft, monitoring the surrounding airspace and ground environment for hazards, and remaining in direct communication with the pilot, as required by Transport Canada.

References

• Bonds JAS, Pai N, Hovinga S, Stump K, Haynie R, Flack S, Bui T, Spray Drift, Operator Exposure, Crop Residue and Efficacy: Early Indication for Equivalency of Uncrewed Aerial Spray Systems with Conventional Application Techniques. J. ASABE 67: 27-41 (2024). DOI: 10.13031/ja.15646.
• Felkers E, Kuster CJ, Hamacher G, Anft T, Kohler M, Pesticide exposure of operators during mixing and loading a drone: towards a stratified exposure assessment. Bayer AG. Pest Management Science published by John Wiley & Sons Ltd on behalf of Society of Chemical Industry (2024).
• Kuster CJ, Kohler M, Hovinga S, Timmermann C, Hamacher G, Buerling K, et al., Pesticide exposure of operators from drone application: a field study with comparative analysis to handheld data from exposure models. ACS Agric Sci Technol 3:1125–1130 (2023).
• OECD, Report on the State of the Knowledge – Literature Review on Unmanned Aerial Spray Systems in Agriculture, OECD Series on Pesticides, No. 105, OECD Publishing, Paris (2021).
• Pest Control Products Act (2002). URL: https://laws-lois.justice.gc.ca/eng/acts/P-9.01/.
• Pest Control Products Regulations (SOR/2006-124). URL: https://laws-lois.justice.gc.ca/eng/regulations/sor-2006-124/index.html.
• PMRA Guidance Document, Pesticides for Aquatic Applications. 21 May 21 2024. https://www.canada.ca/en/health-canada/services/consumer-product-safety/reports-publications/pesticides-pest-management/policies-guidelines/pesticides-aquatic-applications.html, accessed June 2026.
• PMRA Guidance Document, Updated Residue Chemistry Guidelines. 19 October 2022. https://www.canada.ca/en/health-canada/services/consumer-product-safety/reports-publications/pesticides-pest-management/policies-guidelines/updated-residue-chemistry-guidelines.html, accessed June 2026
• PMRA Guidance Document, Value Guidelines for New Plant Protection Products and Label Amendments. 27 July 2023. https://www.canada.ca/en/health-canada/services/consumer-product-safety/reports-publications/pesticides-pest-management/policies-guidelines/new-plant-protection-products-label-amendments.html, accessed June 2026.