California Regulatory Update – DCC-2026-03-R
DCC-2025-03-R eliminates the Category I and Category II framework and assigns every pesticide its own numeric action level. Most limits stayed flat or moved up. The harder deadline is April 1, 2028.
On October 1, 2026, California’s residual pesticide testing regulations changed for the first time since the program’s original framework was written. The rule retires the two-category system, gives all 66 pesticides on the current panel a numeric action level for inhalable and non-inhalable products, and changes how results are reported on your COA.
A second phase on April 1, 2028 expands the panel to 80 pesticides and tightens many non-inhalable limits considerably. Here is what changed, what it means for your product, and
what to prepare for next.
Four points that matter most today
- The Category I / Category II framework is gone. Every pesticide on the panel now carries its own numeric action level for inhalable and non-inhalable products.
- 21 pesticides moved off zero tolerance. Chlorpyrifos, chlordane, aldicarb, fipronil and 17 others previously failed on any detection above the limit of detection. They now have numeric action levels.
- 19 action levels were revised, all upward. No action level on the current panel was lowered on October 1. DCC aligned the numbers to health-based recommendations from the Department of Pesticide Regulation.
- COA reporting. All residual pesticide results are reported in µg/g with a pass or fail designation. The “detected / not detected” language for the old Category I list is retired.
What Changed in California's Pesticide Action Levels on October 1, 2026?
| Comparison | Before Oct 1, 2026 | Oct 1, 2026 - Mar 31, 2028 | Beginning Apr 1, 2028 |
|---|---|---|---|
| Pesticides on the panel | 66 | 66 | 80 |
| Structure | Two categories | Single list, no categories | Single list, no categories |
| Category I pesticides (21) | Fail on any detection above LOD | Numeric action levels, most at 0.10 µg/g | Health-based levels, many below 0.10 µg/g |
| Category II pesticides (45) | Numeric action levels | Numeric action levels, 17 revised upward | Numeric action levels, many revised downward |
| Required LOQ | 0.10 µg/g for Category I | At or below each pesticide's action level | 0.10 µg/g, or the action level when it is lower |
| COA reporting | "Detected" for Cat I, µg/g for Cat II | µg/g for every pesticide, plus pass or fail | µg/g for every pesticide, plus pass or fail |
| Captan | Parent compound only | Parent compound only | Captan + THPI metabolite, summed |
| Net effect on pass rates | Baseline | Neutral to favorable | Tighter, particularly for non-inhalables |
Every change, and what to do about it
SC Labs has tracked DCC-2025-03-R since the rulemaking opened in May 2025, through three rounds of proposed modifications. Our California laboratories are accredited to ISO/IEC 17025 and run the full residual pesticide panel in-house. When the rules move, we would rather you hear it from your lab than from a failed COA.
21 pesticides that moved off zero tolerance
These previously failed a batch on any detection above the limit of detection. As of October 1 they carry numeric action levels. This is the change most likely to affect a batch that would have failed last month.
| Former Cat I Pesticide | Inhalable (µg/g) | Non-inhalable (µg/g) |
|---|---|---|
| Aldicarb | 0.10 | 0.10 |
| Carbofuran | 0.10 | 0.10 |
| Chlordane | 0.10 | 0.10 |
| Chlorfenapyr | 0.10 | 0.10 |
| Chlorpyrifos | 0.10 | 0.10 |
| Coumaphos | 0.10 | 0.10 |
| Daminozide | 0.10 | 0.10 |
| DDVP (Dichlorvos) | 0.10 | 0.10 |
| Dimethoate | 0.10 | 0.10 |
| Ethoprop(hos) | 0.10 | 0.10 |
| Etofenprox | 0.10 | 0.10 |
| Fenoxycarb | 0.10 | 0.10 |
| Fipronil | 0.10 | 0.10 |
| Imazalil | 0.10 | 0.10 |
| Methiocarb | 0.10 | 0.10 |
| Methyl parathion | 0.10 | 0.10 |
| Mevinphos | 0.10 | 0.10 |
| Paclobutrazol | 0.10 | 0.10 |
| Propoxur | 0.10 | 0.10 |
| Spiroxamine | 0.10 | 0.10 |
| Thiacloprid | 0.10 | 0.10 |
Etofenprox is the only one that differs between product types. Note that 16 of these tighten again on April 1, 2028, several to 0.02 µg/g for non-inhalables.
Revised action levels on existing pesticides
19 pesticides already on the panel had their action levels revised. Every revision moved the limit up. Values shown are old → new. Asterisk denotes an unchanged value.
| Pesticide | Inhalable (µg/g) | Non-inhalable (µg/g) |
|---|---|---|
| Acetamiprid | 0.1 → 3.0 | 5.0 → 6.5 |
| Azoxystrobin | 0.1 → 16.0 | 40.0* |
| Tebuconazole | 0.1 → 18.0 | 2.0* |
| Chlorantraniliprole | 10 → 14.0 | 40.0* |
| Bifenazate | 0.10* | 5.0 → 6.5 |
| Bifenthrin | 3.0* | 0.5 → 2.0 |
| Boscalid | 0.10* | 10 → 14.0 |
| Captan | 0.70* | 5.0 → 6.5 |
| Clofentezine | 0.10* | 0.5 → 0.85 |
| Fenhexamid | 0.10* | 10 → 25.0 |
| Fenpyroximate | 0.10* | 2 → 4.0 |
| Flonicamid | 0.10* | 2 → 7.9 |
| Hexythiazox | 0.10* | 2 → 6.0 |
| Imidacloprid | 5.0* | 3 → 3.9 |
| Malathion | 0.50* | 5 → 8.0 |
| Pentachloronitrobenzene | 0.10* | 0.2 → 1.0 |
| Prallethrin | 0.10* | 0.4 → 1.0 |
| Spinetoram | 0.10* | 3 → 3.2 |
| Spinosad | 0.10* | 3 → 3.2 |
The four inhalable increases are the significant ones. Acetamiprid, azoxystrobin and tebuconazole each moved from a 0.1 µg/g threshold to levels 30 to 180 times higher for inhalable products.
One caution worth stating plainly
Results that now pass aren’t the same as “clean” results. An action level is a regulatory threshold, not a statement that a residue is absent. If you’re selling into a market with its own limits, or to a brand with internal specs tighter than the state’s, the number on the COA still matters.
Resources
- DCC-2025-03-R: Pesticide Testing – Approved and filed with the Secretary of State July 27, 2026; effective Oct. 1, 2026.
- Final Text of Regulations – §15719 and §15731, Tables 1 and 2 in full.
- Final Statement of Reasons – DCC’s rationale, including the feasibility revisions.
This summary is provided for informational purposes and reflects DCC regulations as filed July 27, 2026. It is not legal or compliance advice. Refer to the final text of 4 CCR §§15719 and 15731 for the complete regulation, and consult your compliance counsel for guidance specific to your operation.
Questions about how the new action levels affect your product?
Talk to your SC Labs account manager. We will walk your recent results against both tables and flag anything that changes.