Proposed Rule: Petition: Bayer U.S.-Crop Science; Determination of Nonregulated Status and Draft Plant Pest Risk Assessment for Herbicide Resistant MON 96012 Cotton (Gossypium hirsutum) Regulations.gov Document ID: <a href="https://www.regulations.gov/document/APHIS-2026-1387-0001" target="_self"><ins>APHIS-2026-1387-0001</ins></a> Comment Period: September 21, 2026 to November 20, 2026 Agency: U.S. Department of Agriculture (USDA)
View the <a href="https://www.regulations.gov/user-notice" target="_self"><ins>terms of participation</ins></a> and <a href="https://www.regulations.gov/privacy-notice" target="_self"><ins>privacy notice</ins></a> for Regulations.gov. All comments made on <a href="http://regulations.gov" target="_self"><ins>regulations.gov</ins></a> action centers will be public comments, so we encourage action-takers not to include personally identifiable information in their messages. Five Herbicides. One GMO Crop. An Endless Toxic Treadmill.
Thirty years ago, when Monsanto brought the first GMO herbicide-tolerant crop to market—Roundup Ready soybeans—scientists warned that widespread use of glyphosate would result in weeds developing resistance. Monsanto said it wouldn’t happen.
It happened.
The widespread adoption of glyphosate-tolerant GMO crops has helped fuel an epidemic of glyphosate-resistant weeds. But rather than breaking this cycle, the pesticide industry just keeps piling on, adding herbicide after herbicide to the mix. 
Big Ag's solution isn't to use fewer chemicals. It's to engineer crops that can withstand even more of them, stacking multiple herbicide-tolerant traits into a single crop.
Now Bayer-Monsanto wants the USDA to greenlight cotton genetically engineered to tolerate a chemical cocktail of five toxic herbicides or herbicide classes: glyphosate, glufosinate, dicamba, HPPD inhibitors, and PPO inhibitors.
Five toxic herbicides. One crop. And the same failed chemical treadmill.
We’ve seen it all before. The consequences don't stop at the edge of the cotton field. Herbicide drift can and will damage neighboring non-GMO and organic crops, home gardens, trees, and wild plants that provide critical food and habitat for pollinators and other wildlife.
Farmers are left battling increasingly resistant weeds while becoming more dependent on expensive, proprietary seeds and toxic chemical inputs.
Bayer calls it agricultural “innovation.” We call it doubling down on a broken system.
USDA must fully evaluate the environmental and health-related consequences of this technology, including its potential to perpetuate herbicide resistance in weeds, contribute to herbicide-related drift damage, groundwater and environmental contamination, and the harmful effects on farmers’ health.
Our farmers and environment deserve solutions that reduce chemical dependence, not deepen it.
Tell the USDA to reject Bayer's petition for five-herbicide-resistant GMO cotton.
TAKE ACTION: STOP THE PESTICIDE TREADMILL!
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Tell the USDA: Reject Bayer's Five-Herbicide-Resistant GMO Cotton!

Comment for Docket APHIS-2026-1387-0001

I urge USDA to deny Bayer's petition to deregulate MON 96012 cotton, genetically engineered to tolerate five herbicides or herbicide classes: glyphosate, glufosinate, dicamba, HPPD inhibitors, and PPO inhibitors.

The history of herbicide-resistant GMO crops demonstrates the serious problems associated with relying on chemical weed control. Widespread herbicide use has contributed to the evolution of resistant weeds, prompting the development of crops that tolerate additional herbicides.

This escalating chemical arms race is not a sustainable solution.

I am particularly concerned that Bayer's proposed cotton could encourage greater dependence on multiple herbicides, intensify the development of herbicide-resistant weeds, and contribute to additional herbicide drift that damages neighboring crops, trees, gardens, and wild plants essential to pollinators and other wildlife.

USDA must thoroughly examine the potential for increased weediness, the persistence and spread of herbicide-tolerance traits, and the biological and ecological consequences associated with this genetically engineered cotton.

I urge APHIS to address these concerns and expand its risk assessment beyond “plant pest risk,” which is only a small part of the risks associated with the growing of this 5 herbicide tolerant cotton. APHIS must deny Bayer's petition.

Farmers and the environment deserve sustainable solutions to weed management, not another generation of genetically engineered crops that perpetuate dependence on chemical herbicides and put their health at risk.

Action REG Federal APHIS-2026-1387-0001 5-Herbicide Cotton

GMO/Toxin Free USA

Oppose Deregulation of Bayer's MON 96012 Herbicide-Resistant GMO Cotton

Comment for Docket APHIS-2026-1387-0001

I strongly oppose Bayer's petition to deregulate MON 96012 genetically engineered cotton, which is designed to tolerate five herbicides or herbicide classes.

We have already witnessed the devastating consequences of herbicide-resistant GMO crops. Dicamba drift has damaged millions of acres of neighboring crops and vegetation, harming farmers, home gardens, trees, and natural habitats. Introducing another GMO crop engineered to withstand dicamba and four additional herbicide categories threatens to perpetuate these problems.

Wild plants are not simply weeds. They provide essential food and habitat for pollinators, birds, and other wildlife. When herbicides drift beyond agricultural fields, the resulting damage can disrupt ecosystems and threaten biodiversity.

I am also concerned that the continued development of crops resistant to multiple herbicides will accelerate the evolution of herbicide-resistant weeds, encouraging even greater reliance on chemical weed control.

USDA must carefully evaluate the potential for MON 96012 cotton to become a plant pest risk, including the consequences of unintended gene flow, increased weediness, and the development of herbicide-resistant volunteer plants.

The solution to herbicide resistance should not be engineering crops to withstand an ever-expanding arsenal of weedkillers.

I urge USDA to reject Bayer's petition and prioritize the protection of farmers, biodiversity, and our environment.

Protect Our Farms, Wildlife, and Environment — Reject MON 96012 GMO Cotton

Comment for Docket APHIS-2026-1387-0001

I urge USDA to reject Bayer's petition to deregulate MON 96012 genetically engineered cotton.

For decades, the pesticide industry has promoted herbicide-resistant GMO crops as a solution to weed management. Yet widespread reliance on these technologies has contributed to the emergence of increasingly difficult-to-control herbicide-resistant weeds, resulting in the escalation of a chemical war on weeds.

Now Bayer proposes cotton engineered to tolerate five herbicides or herbicide classes. Rather than addressing the underlying causes of herbicide resistance, this technology risks perpetuating the very problems it claims to solve.

Farmers should not have to rely on increasingly complex combinations of proprietary seeds and chemical herbicide cocktails to remain productive. Such systems can increase input costs, reduce flexibility in weed management, and leave growers vulnerable when weeds inevitably develop resistance.

The potential consequences also extend to neighboring farmers whose crops may be damaged by herbicide drift. Farmers who choose not to grow herbicide-resistant GMO crops should not have to bear the economic and environmental costs of these technologies.

USDA must rigorously evaluate the plant pest risks associated with MON 96012 cotton, including potential changes in weediness, the persistence of herbicide-tolerance traits, and the consequences of gene flow. The Agency must also look beyond the plant-pest risk and consider other harmful impacts that will result from the approval of this 5 herbicide-tolerant cotton.

Agricultural innovation should help farmers reduce dependence on chemical inputs, protect soil health, and build resilient farming systems. Engineering crops to tolerate more herbicides moves us in the opposite direction.

USDA must protect the health of our farmers and our environment. I urge USDA to deny Bayer's petition and support a future in which farmers are not trapped in a costly and dangerous endless cycle of herbicide resistance and chemical dependence.