Policy: Exceptional Use v1.9

What is this document about?

This document presents the Rainforest Alliance Exceptional Use Policy (EUP), which defines the limited conditions under which the use of certain Rainforest Alliance prohibited pesticides may be temporarily authorized. It establishes the criteria, obligations, and mitigation measures that Certificate Holders must follow to ensure that such use is responsible, justified, and limited in time and scope.

The EUP complements the Rainforest Alliance Sustainable Agriculture Standard, the Regenerative Agriculture Standard, and the Farming Annex. In particular, for Certificate Holders implementing regenerative agriculture practices, the policy provides guidance to support progressive pesticide reduction plans (specialized requirement 4.6.16), while ensuring responsible management of Highly Hazardous Pesticides (HHPs).

When and how to use this document?

This document must be used by Certificate Holders, Certification Bodies, and Rainforest Alliance staff involved in the implementation, evaluation, or auditing of pesticide use in certified farms. It is a key reference to ensure compliance with base requirement 4.6.2 of the Rainforest Alliance Standards and specialized requirement 4.6.16 of the Regenerative Agriculture Standard.

The EUP should be consulted when:

• Preparing or evaluating Exceptional Use requests according to the procedures established in the Farming Annex.

• Developing or updating Integrated Pest Management (IPM) strategies and progressive pesticide reduction plans for regenerative agriculture.

• Reviewing or verifying mitigation measures for pesticide use during internal inspections or certification audits.

• Completing the Annual Pesticide Use Report required by the Rainforest Alliance.

Changes in update from v1.8 to v1.9

1. Introduction

Healthy resilient agroecosystems can be built and maintained with minimal reliance on pesticides. By implementing good agricultural practices and Integrated Pest Management (IPM) activities, producers can achieve long-lasting pest control while protecting human and environmental health. Despite global efforts to transition to lower-input agriculture, many agricultural models are still dependent on pesticides, including Highly Hazardous Pesticides (HHPs), which are known to be toxic to people and ecosystems.

The objective of this Exceptional Use Policy (EUP), alongside the Rainforest Alliance (RA) Standards, is to accommodate the needs of producers in their journey to phase out the use of HHPs. To do so, the EUP grants limited exceptions for the use of certain agrochemical compounds included in the Rainforest Alliance’s list of prohibited pesticides. Exceptions are granted to specific crop, pest, and country combinations for a specific, limited, period. Exceptions are granted only if no viable alternatives to HHPs are available and if limiting the use of the active ingredient would impede the economic viability of the farm. Further, where exceptions are granted, producers must implement strict risk mitigation measures to minimize the negative impact on people and the environment. Additionally, producers must actively explore less toxic alternatives.

The process of assessing EUP requests and granting exceptions includes a thorough analysis of the specific agroecological and economic context, producers’ needs, pest pressures, and available alternatives. This analysis is carried out by the Rainforest Alliance IPM team and a panel of external scientists and technical experts with extensive knowledge of sustainable production in relevant sectors. Country-specific data on registered pesticides and Maximum Residue Limits are also assessed with the use of external tools such as Homologa (https://homologa.com/) and the Global Crop Protection database.

Important Considerations

• The EUP is developed from requests sent by certified producers through the procedure described in the Farming Annex. Requests are processed and analyzed as described above. Final decisions are taken by RA’s IPM team by majority decision and after careful consideration of the assessment by the external panel. The EUP is updated every six months based on the requests received during the previous half-year.

• Exceptions for paraquat, fipronil, and any other active ingredient classified as hazardous under the Rotterdam Convention, Stockholm Convention, or Montreal Protocol will not be granted. This is in line with RA’s IPM strategy and sustainable agriculture goals.

For more information about Rainforest Alliance’s approach to Integrated Pest Management and the EUP process, please visit our website.

1.1 Interim measures during the extended phase-out period

Despite ongoing efforts to shift toward lower-input agriculture, many crops remain highly vulnerable to pests and diseases, and less toxic alternatives are still limited in availability. As a result, the reliance on Highly Hazardous Pesticides (HHPs) persists. While work is underway to develop and scale safer, viable solutions, a proposed extension of the HHP phase-out timeline to 2026/2028 underscores the need for immediate and decisive action.

During this interim period, producers must implement strong mitigation measures to minimize harm to human health and the environment. It is essential that growers actively prioritize the use of lower-toxicity pesticides, adopt alternative pest control methods, and scale up Integrated Pest Management (IPM) practices to reduce chemical dependence. The continued use of HHPs must be seen only as a last resort—concrete steps toward their complete phase-out must begin now.  

1.1.1 Extension of phase-out period for Mancozeb

Black leaf spot or Black Sigatoka (Pseudocercospora fijiensis) poses a severe threat to banana cultivation, affecting both export-oriented production and varieties essential for local livelihoods. As the most economically damaging banana leaf disease, BLS can devastate entire plantations. It destroys banana leaves, significantly reducing yield and quality, inducing premature ripening, and impacting fruit size, weight, and filling.

The genetic uniformity of commercial banana production and prevailing growing conditions further increase its vulnerability. Commercial banana production therefore requires rigorous disease management, combining cultural and chemical practices.

Cultural practices include:

• Sanitation through the removal of necrotic leaf material to reduce inoculum levels.

• Efficient drainage systems to lower crop humidity.

• Periodic weed control and maintenance of green cover.

• Adequate crop nutrition.

Chemical control is indispensable in this context. Fungicides approved for BLS control fall into two groups: contact (protectant) fungicides and systemic fungicides. Systemic fungicides, particularly those in the benzimidazole group, are widely used but face a high-risk resistance—even when combined with carbamate fungicides. Contact fungicides, especially multi-site action types such as Mancozeb, present low resistance risks and broad-spectrum activity, making them an essential tool.

2. General conditions

This section outlines the general conditions and responsibilities that apply to Certificate Holders (CHs) who use pesticides included in the Rainforest Alliance Exceptional Use Policy (EUP). These conditions are fundamental to ensure the responsible, limited, and safe use of Highly Hazardous Pesticides (HHPs), in alignment with the Rainforest Alliance Sustainable Agriculture Standard (SAS) and the Regenerative Agriculture Standard (RAS). Compliance with these conditions supports the progressive reduction and responsible management of pesticide use, safeguarding human health and environmental integrity.

2.1 Compliance and responsibilities

1. Failing to comply with any of the conditions or requirements in this policy will be considered as a non-conformity against base requirement 4.6.2 of the Sustainable Agriculture Standard and the Regenerative Agriculture Standard.

2. Exceptions are granted for the specific crop, pest, and country combination only, and for the defined timeframe, as specified in the Granted Exceptions section tables.

3. Certificate Holders must aim to eliminate reliance on EUP-listed pesticides by 2028.

2.2 Pesticide management and application

1. Certified operations must follow the label, Material Safety Data Sheet (MSDS), and security tag information and requirements for preparing and applying the pesticides listed in this policy.

2. Certified operations using active ingredients listed in this policy comply with the respective IPM and agrochemicals management requirements, with special focus on:

   • Pest prevention and monitoring (requirements 4.5.1),

   • Training and use of PPE (requirement 4.6.3),

   • Restricted entry and pre-harvest intervals implementation (requirement 4.6.5),

   • Spray drift reduction (4.6.6),

   • Aerial application requirements (requirement 4.6.7),

   • Empty pesticide containers and application equipment management (4.6.9),

   • Agrochemicals storage 4.6.11.

   • Agrochemicals storage 4.6.12 (SAS only).

3. The active ingredients listed in this policy are rotated with lower toxicity substances from different classification groups, as part of a resistance management strategy.

4. Producers using active ingredients listed in this policy select the optimum pesticide application equipment and techniques to maximize effectiveness, limit losses, and reduce spray drift. If a liquid spray is in use, the correct nozzle type is employed. The equipment is calibrated at least annually, after each maintenance and before using it for a different type of agrochemical.

5. Producers must take measures to respect the maximum residue levels (MRLs) set by the production country and known destination countries of the product.

6. Workers who regularly handle the active ingredients listed in this policy receive a medical examination at least once a year. In case of regular exposure to organophosphates or carbamate pesticides^[1][2], the examination includes cholinesterase testing. Workers have access to the results of their medical examination (requirement 5.6.16).

7. In the case of farms in a group, spraying is carried out by centralized, specialized spraying teams.

8. Soil application of triazoles included in this policy (cyproconazole, epoxiconazole, propiconazole and triadimenol) for control of leaf diseases is prohibited. These substances when used must be used in the most precise and efficient way, to minimize contamination risks. For more information please refer to the technical paper: Application of Triazoles for Control of Coffee Leaf Rust (Hemileia vastatrix) | Rainforest Alliance (rainforest-alliance.org)

9. Pesticide application must be based on pest monitoring and established thresholds. It must be limited only to affected areas. Records must justify applications, specifying pest presence, thresholds, and relevant climate events.

2.3 Annual Pesticide use report

1. Certificate Holders using active ingredients listed in this policy must collect usage data annually from January 1st to December 31st and submit it to the Rainforest Alliance by the end of February of the following year, using the designated Annual Pesticides Report

2. The report must include the mitigation measures implemented clearly contextualized to the farm’s specific conditions (e.g., type of tractor cab, application times, etc.).

3. The usage report must also include specific information on the Integrated Pest Management (IPM) Plan with sufficient detail to describe the farm’s context and the IPM strategies that were implemented.

4. Please note that new exceptional use requests will not be evaluated if the Certificate Holders have not submitted the corresponding usage reports for previous years. The report must include justification for pesticide applications and demonstrate measurable progress toward pesticide reduction.

Additional Measures in Cases of Non-Compliance or Suspicion of pesticide misuse

5. In cases of allegations, substantiated suspicions of pesticide misuse, or a history of non-conformities related to base requirement 4.6.2 of the Rainforest Alliance Standards, the Rainforest Alliance reserves the right to require the Certificate Holder to carry out a pesticide residue testing to be conducted on the affected production units by an independent and credible body, at the cost of the CH. The test results must be submitted to the Rainforest Alliance for evaluation at ipm@ra.org within 30 calendar days of the sample collection date.

2.4 Verification mechanisms to ensure compliance with specialized requirement 4.6.16

1. Certificate Holders (CHs) choosing to adhere to the Rainforest Alliance Regenerative Agriculture Standard must comply with base requirement 4.6.2 and specialized requirement 4.6.16. 

2.4.1 Progressive Pesticide Reduction Plan

In alignment with specialized requirement 4.6.16 — which covers both Exceptional Use Policy (EUP) exceptions and emergency requests — Certificate Holders (CHs) implementing regenerative agriculture practices must demonstrate measurable progress in reducing pesticide dependency over time.

This section focuses specifically on the progressive reduction component, complementing the provisions already detailed in the Farming Annex and the Exceptional Use Policy (EUP) without duplicating them.

1. Additional Conditions

   1. CHs must design and implement a progressive pesticide reduction plan for the following years, in terms of quantities applied, toxicity levels, or both. The plan must include a pest-by-pest analysis of alternatives, projected targets for the following year, and an explanation of implementation progress. It should consider one or more of the following strategies: 

   2. Prioritize the use of pesticides with demonstrated lower environmental impact and reduced health risks. 

   3. Gradually reduce the number of highly hazardous pesticides as defined by the Rainforest Alliance in Farming Annex including those authorized only under the Exceptional Use Policy), by decreasing application frequency or combine both strategies. 

   4. Integrate biological, cultural, and physical control measures to reduce reliance on synthetic pesticides. 

   5. Implement Integrated Pest Management (IPM) strategies that reduce the need for pesticide use, applying them only when strictly necessary based on monitoring, sampling, and thresholds. 

   6. Optimize pesticide application by using recommended doses or improved application methods (selectivity in space and time) as per technical guidelines. 

2.  Requirements for the Progressive Pesticide Reduction Plan 

   1. The plan must be updated annually to show measurable progress. 

   2. The plan must incorporate advancements in integrated pest management and include a projected planning for the following year. 

   3. Repeated submission of the same plan in consecutive cycles, citing implementation difficulties, will not be accepted. In such cases, it will be considered that the Certificate Holders (CHs) does not yet meet the necessary conditions to access regenerative certification. The plan must include clearly defined measures leading to the complete phase-out of the use of these active ingredients by December 31, 2028.  

2.5 Verification and monitoring measures for compliance with the regenerative agriculture standard

In addition to complying with the specific requirements under section 4.6.16, Rainforest Alliance may apply complementary verification measures, to ensure alignment with regenerative agriculture principles, particularly regarding pesticide reduction efforts.

1. For Certificate Holders (CHs) seeking certification under the Rainforest Alliance Regenerative Agriculture Standard, such testing may be required to verify progress under the pesticide reduction plan or to ensure general compliance with Regenerative Agriculture requirements. Testing must be conducted on relevant production units at CH’s expense following the specific requirements defined by the Rainforest Alliance IPM team. CHs must submit the results to ipm@ra.org within 30 calendar days of the sample collection.

2. Additionally, CHs must maintain detailed records of all pesticide applications, including active ingredients used, calibration activities, equipment involved, applicator training, pest monitoring efforts, and any biological or cultural alternatives implemented.

3. For group certification, Group Administrators must actively ensure compliance with the regenerative agriculture pesticide reduction requirements. This includes training group members, designing and coordinating group-wide pesticide reduction plans, monitoring implementation at the member level, and consolidating all relevant records and data for submission.

3. Risk mitigation measures

3.1 Risk management requirements for rodenticides:

1. Food sources attracting rodents and debris are eliminated.

2. Rodent reproduction areas are eliminated or reduced.

3. Drainages are well-maintained and functional for water run-off and avoid standing water.

4. Rodenticides are only used if mechanical, bacteriological, or Vitamin D control methods have proven to be ineffective.

5. Rodent carcasses are handled with gloves and buried in locations that do not pose risk to human or wildlife health, or water contamination.

6. Trees or artificial structures are strategically placed on the farm to facilitate perching of raptor birds for rodent control^[3]

7. Plants with the potential to drive away rodents are planted in non-production areas (e.g., Petiveria alliacea, Allium sp., Cinnamomum camphora, Viburnum sp., Euphorbia sp., Artemisia absinthium or Mentha spicata)

3.1.1 Additional requirements for baited traps:

1. Bait stations are tamper-resistant, anchored, and constructed in such a manner and size as to permit only the entrance of the targeted pests.

2. Baited traps are inspected weekly.

3. Baited traps are removed, or its quantity decreased if there is reduced rodent activity or no signs of rodent feeding.

4. Baited traps are placed at a minimum distance of 10 m from aquatic ecosystems.

3.1.2 Additional requirements for pellet formulations:

1. Only product formulations that cannot be confused as food by birds are used.

2. Routine applications are prohibited.

3. Access of bystanders is avoided by fencing or other effective security measures.

4. Pellets are placed at a minimum distance of 10 m from aquatic ecosystems.

3.2 Risk management requirements for substances with acute & chronic toxicity:

1. Women under 50 years old do not apply these pesticides and are not present or near the application areas.

2. Personal Protective Equipment (PPE) is used as prescribed in the product’s label Material Safety Data Sheet (MSDS). If labels do not provide details of PPE for applicators, basic protective clothing with protection for eyes (i.e. a face mask or goggles) and respiratory protection (i.e. a respirator) are worn.

3. Restricted Entry Intervals (REI) as stipulated in the product’s MSDS, label or security tag are implemented, for protecting persons entering pesticide applied areas without PPE. When two or more products with different REIs are used at the same time, the longest interval applies.

4. Daily maximum application time for applicators is limited to eight hours, two shifts of four hours maximum each, with bathing in between application periods to wash off residues, and clean PPE clothing for each shift. Application is conducted during the coolest hours of the day.

5. Potentially affected persons or communities are identified and alerted in advance of application. Explicit flags or signs are used to identify treated fields, and access to treated fields is prevented.

3.3 General risk management requirements for substances with severe effects (pollinator toxicity):

1. Producers do not apply these substances on flowering crops and avoid drift to flowering weeds, or to cover crops that are attractive to beneficial insects (natural enemies and pollinators).

2. Beneficial insects are monitored, and application time is defined based on monitoring results. Applications are avoided during high activity hours. Substances are ideally applied in the late afternoon or night-time from 6 pm onwards during low activity times of pollinators.

3. If beehives are used for pollination, these are temporarily covered during the chemical application. Beehives are provided with a clean water source outside the treated area.

4. Soil cover is maximized (cover crops, mulch, crop residues or similar) to reduce contact of these substances with the soil and leaching into ground water. Not applicable in case of drench applications.

5. Flowering strips of native vegetation are planted outside the farm or at the edges of the crop within the farm to provide food and shelter for beneficial insects and promote a more stable agroecosystem.

3.4 Risk management requirements for fumigants (fatal if inhaled):

1. The product is applied only in closed, controlled, and sealed environments with gas leak detectors (gas meters). These detectors may be portable devices.

2. There is a buffer zone around the storages or containers where fumigation is conducted. The buffer zone can be accessed only by authorized persons wearing protective equipment (e.g. gas masks). The dimensions of the buffer zone are between 3 and 150 meters depending on the application rate, facility, and storage/container size. Gas meters are placed at several locations along the buffer zone perimeter to control acceptable occupational exposure limits as well as fire protection. Parameters are check against the national regulation or the following (whichever is more stringent):

3. If concentrations exceed 0.3 ppm, no presence of unprotected workers or bystanders is allowed, and the area is evacuated.

4. Nearby the area where fumigation is done and where the substances are stored, electricity is set up in a way phosphine gas cannot be accidentally ignited and all sources of ignition are removed.

5. Fumigant handlers have completed mandatory annual training on product-specific training material, and facility-specific information. Personnel working in the sites where the fumigation is conducted or the substances are stored, are trained on the use of and equipped with specific fire-extinguishing equipment (sand, carbon dioxide powder) to extinguish the fire. The use of water for the purpose of extinguishing fires is prohibited.

6. Personal Protective Equipment (PPE) is used as prescribed in the product’s label or MSDS (Material Safety Data Sheet). If labels do not provide details of PPE for applicators, basic protective clothing^[4] with protection for eyes (i.e. a face mask or goggles) and the following respirators:

^{Source: US National Institute for Occupational Safety and Health (NIOSH) recommendations}

4. Granted exceptions and their conditions

4.1 Fertilizers

Rainforest Alliance authorizes the use of the following fertilizers only if the conditions, as included in table 1, are fully complied with.

Conditions: Risk management requirements for chronic toxicity are fully implemented (see above section on risk management). Fertilizer applications are only permitted in soils with demonstrated boron deficiency.

4.2 Rodenticides

Rainforest Alliance authorizes the use of the following rodenticides only if the conditions, as included in table 2, are fully complied with.

Conditions: Only formulated rodenticide-baited traps are allowed. Use is limited to infrastructure only. Risk management requirements in section risk management rodenticides / acute toxicity are fully implemented.

4.3 Nematicides

Rainforest Alliance authorizes the use of the following nematicides only if the conditions, as included in table 3, are fully complied with.

Conditions: Risk management requirements for acute toxicity are fully implemented (see above section on risk management)

4.4 Insecticides/Acaricides

Rainforest Alliance authorizes the use of the following insecticides/acaricide only if the conditions, as included in table 4, are fully complied with.

Conditions: Risk management strategies for acute toxicity, chronic toxicity, and severe effects (pollinators) are fully implemented.

4.5 Fumigants for storage pest control

Rainforest Alliance authorizes the use of the following fumigants for storage pest control only if the conditions, as included in table 5, are fully complied with.

Conditions: Risk management requirements for fumigants (fatal if inhaled) are fully implemented (see above section on risk management)

4.6 Fungicides

Rainforest Alliance authorizes the use of the following fungicides only if the conditions, as included in table 6, are fully complied with.

Conditions: Risk management strategies for chronic toxicity and severe effects (pollinators) are fully implemented.

Other information

Date of first publication of this document (v 1.0): June 30^th 2021.

Documents indicated as “binding” must be complied with for certification. Documents indicated as “non-binding” provide non-mandatory information to help readers understand and implement requirements and other binding content.

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For any question related to the precise meaning of the information in a translation, consult the official English version for clarification. Any errors or differences in meaning due to translation are not binding and have no effect for auditing or certification purposes.

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More information?

For help in obtaining a Rainforest Alliance certificate reach out to our Customer Success team at customersuccess@ra.org.

For more information about Rainforest Alliance, visit http://www.rainforest-alliance.org contact info@ra.org or the Rainforest Alliance Amsterdam Office, De Ruijterkade 6, 1013AA Amsterdam, The Netherlands.

Footnotes

1. These substances have been identified in the tables with an asterisk (*) ↑

2. That is, exposure that occurs frequently due to routine involvement in handling, mixing, or applying these substances throughout the production cycle. ↑

3. Recommendation: Placement of nesting boxes for raptor birds to facilitate reproduction sites. ↑

4. Apparel and footwear for persons handling pesticides include coveralls over a long-sleeved shirt, long pants, socks, and stout shoes, with chemically resistant gloves, with protection for eyes (i.e., a face mask or goggles), and respiratory protection (i.e., a respirator). From Glossary Annex. ↑

5. Recommendation: Depending on the formulation, combination of abamectin with horticultural/narrow oils increases effectiveness and reduce spray drift ↑