The EPA notice of the cancellation of Transform that we posted today says, “Use of existing stocks by end users is permitted provided such use is consistent in all respects with the previously-approved labeling for the product.” But this does not mean Transform is labeled for use on sorghum, because it is not. We were using Transform in 2015 under a Section 18 emergency use exemption, and that expired on October 31st of this year. So sorghum is no longer a labeled use.
Texas A&M AgriLife Research and Extension personnel have drafted a new Section 18 request for Transform and it was submitted to TDA today. However, it is EPA and not TDA that approves Section 18 requests, and there is no way to guess whether EPA will approve our Texas request.
Outside of sorghum, if the 2015 Section 3 Federal label lists uses on other crops then existing on farm stocks of Transform can still be used for these purposes.