FPA Memorandum Circular No. 2024-25

Also known as: FPA MC No. 2024-25 · Enhanced Rules and Regulations on Agricultural Pesticide Application Using RPAS · The RPAS pesticide circular · Series of 2024 drone spraying rules

Agricultural drone technology and practice

Definition

FPA Memorandum Circular No. 2024-25 is the Philippine Fertilizer and Pesticide Authority’s circular on the “Enhanced rules and regulations on agricultural pesticide application using remotely piloted aircraft system (RPAS)” — the national rulebook for spraying farm chemicals from drones. Issued on October 1, 2024, it sets the requirements and guidelines governing pesticide use through RPAS, and binds drone controllers, operators, technicians, service providers, pesticide companies, end-users, research institutions, state universities and colleges, other government agencies, and local government units engaged in drone spraying. (DA — FPA Drones4Rice, FPA — MC No. 2024-25)

The circular is the pesticide half of a two-regulator system: the Civil Aviation Authority of the Philippines and the Civil Aeronautics Board keep commercial drone registration, flight permits, and air traffic coordination, while the FPA — an agency attached to the Department of Agriculture — registers agricultural inputs applied by drone and prescribes their safe use. It was issued as the operational safeguard of the DA’s Drones4Rice project, the subsidy program that put drone services in rice clusters from late 2024, and FPA officials continued presenting it to farmer and industry audiences through 2026. (FPA — Inter-agency meeting, DA — Subsidized drone access, FPA — Banana growers)

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Also Known As

FPA MC No. 2024-25
Enhanced Rules and Regulations on Agricultural Pesticide Application Using RPAS
The RPAS pesticide circular
Series of 2024 drone spraying rules

Examples and Analogies

A driver’s license plus a pharmacist’s license: flying spray over a Philippine field requires two separate permissions — CAAP credentials for the aircraft and pilot, and FPA rules for the chemical being released — and this circular is the pharmacist’s half of the gate. (FPA — Inter-agency meeting, FPA — PAMB Davao del Sur)
A manual carried to the field: the circular is not just filed law; FPA regulators present it directly to farmers, as its Pesticide Regulations Division chief did before 291 participants at a Sultan Kudarat caravan in November 2024 and a senior agriculturist did before banana growers in Davao City in September 2026. (FPA — Sultan Kudarat caravan, FPA — Banana growers)
The second edition: it replaces a thinner first edition — Memorandum Circular No. 28, series of 2018, on good agricultural practices for RPAS spraying — the way updated drug labels replace old ones as usage grows. (FPA — PAMB Davao del Sur)

Usage Scenarios

1. Compliance by Drone Service Providers

Spray-service companies, their pesticide applicators and spray operation crews operate under the circular’s requirements, working alongside CAAP-licensed drone controllers — the arrangement FPA regional officers have described to local boards since the 2018 rules. (FPA — PAMB Davao del Sur, DA — FPA Drones4Rice)

2. Government Information Caravans

The circular is the teaching text of Drones4Rice information caravans, piloted in Regions XII and III in calendar year 2024 — including Lambayong, Sultan Kudarat on November 27, 2024, with a follow-on caravan in Region III in December — where its rules are presented beside live drone demonstrations. (DA — FPA Drones4Rice, FPA — Sultan Kudarat caravan)

3. Inter-Agency Rule Harmonization

The circular is the reference document when the FPA, CAAP, and Civil Aeronautics Board align agricultural and aviation rules — a March 10, 2026 meeting at the Bureau of Plant Industry used it as the baseline for discussions on night flying, flight permit processing, pilot licensing, standard terminology, and security, and agreed a revised circular would be drafted with CAAP coordination. (FPA — Inter-agency meeting)

4. Industry Briefings and Feedback

The FPA uses the circular to brief crop industries taking up drone spraying — most extensively the banana sector, whose growers in Davao City were walked through its requirements in September 2026 and surveyed on their practices, experiences, and challenges to inform future regulatory and capacity-building work. (FPA — Banana growers)

Strategies

Standardize before scaling: the FPA issued the enhanced rules on October 1, 2024 — ahead of the voucher-funded expansion of drone services — so that protocols for drone application of seeds, fertilizers, and pesticides would exist before mass adoption, not after. (DA — FPA Drones4Rice)
Anchor promotion and protection together: the circular is framed as “anchored on the principle of promoting the advancement and adoption of drone technology” while safeguarding public health and the environment from pesticide risks — growth and guardrail in one instrument. (DA — FPA Drones4Rice)
Regulate the whole chain: rather than targeting pilots alone, the circular binds controllers, operators, technicians, service providers, pesticide companies, end-users, researchers, SUCs, agencies, and LGUs — every actor who decides what is sprayed and how. (DA — FPA Drones4Rice)
Teach the rule where the users are: dissemination runs through caravans in rice-cluster provinces and sectoral dialogues in plantation regions, paired with demonstrations and structured surveys of current practice. (FPA — Sultan Kudarat caravan, FPA — Banana growers)
Revise with the aviation regulators: rather than amending alone, the FPA committed in March 2026 to draft the successor circular in coordination with CAAP, after the two agencies mapped where pesticide rules and aviation rules touched. (FPA — Inter-agency meeting)

Security and Safety Measures

Coverage of all spraying actors: the circular’s requirements reach drone controllers, operators, technicians, service providers, pesticide companies, end-users, research institutions, SUCs, agencies, and LGUs engaged in drone spraying — the widest compliance net the FPA has cast for aerial application. (DA — FPA Drones4Rice)
Dual licensing with aviation authorities: drone controllers also need CAAP licenses, and operator companies are accredited by the FPA as pesticide applicators with spray operation crews — two agencies checking two different risks. (FPA — PAMB Davao del Sur)
Operational safety practice: FPA briefings under the RPAS regime cover safe pesticide handling, flying altitude, pesticide transport, post-application safety, and post-spraying reporting, with approved chemical lists published on the agency website. (FPA — PAMB Davao del Sur)
Health-and-environment safeguard principle: the rules exist to keep product effectiveness from being purchased at the cost of applicators, communities, crops, consumers, and the environment — the FPA’s stated basis for regulating drone spraying at all. (DA — Subsidized drone access)

Historical Context

Aerial pesticide application was regulated in the Philippines well before drones: the FPA traces its mandate to Presidential Decree No. 1144, and as remotely piloted aircraft spread in the late 2010s the agency issued Memorandum Circular No. 28, series of 2018, setting good agricultural practices for RPAS spraying and starting the accreditation of drone-spraying operator companies. Local friction surfaced early — in February 2023 a Protected Area Management Board technical working group in Davao del Sur raised drift concerns over aerial spraying near banana plantations in Kapatagan, Digos City, and the FPA defended its guidelines while the board drafted local rules. (FPA — Sultan Kudarat caravan, FPA — PAMB Davao del Sur)

The enhanced circular arrived with the national drone-spraying program. Issued October 1, 2024, as the DA prepared Drones4Rice — about ₱300 million in National Rice Program support and ₱2,000-per-hectare service vouchers — it gave the subsidy program its pesticide rulebook, and its roll-out ran through caravans in Regions XII and III in late 2024 and, later, sectoral briefings such as the September 2026 dialogue with banana growers in Davao City. (DA — FPA Drones4Rice, DA — Subsidized drone access, FPA — Banana growers) In March 2026 the FPA, CAAP, and Civil Aeronautics Board met to harmonize drone regulation for pesticide applications and agreed that a new memorandum circular revising MC No. 2024-25 would be drafted with CAAP coordination; as of that meeting the 2024 circular remained the operative rule. (FPA — Inter-agency meeting)

Challenges and Controversies

The Aviation–Agriculture Seam

Because one aircraft answers to two regulators, gaps surfaced in practice: the March 2026 inter-agency meeting had to work through night-flying guidelines, flight-permit processing, pilot licensing requirements, inconsistent terminology, and security screening before agreeing to jointly draft the circular’s revision. (FPA — Inter-agency meeting)

Community Concerns over Drift

The circular’s subject — pesticide released over farms near communities and protected areas — keeps it under local scrutiny; the Davao del Sur board’s 2023 concerns about drift and wind velocity near banana plantations previewed the questions that accompany every expansion of drone spraying. (FPA — PAMB Davao del Sur)

Regulating a Moving Practice

The rules chase a fast-growing technology: FPA’s own banana-sector dialogue in 2026 surveyed growers’ actual practices and challenges precisely because field reality and regulation were developing together, and the planned revision of the circular is an admission that the 2024 text will not be the last word. (FPA — Banana growers, FPA — Inter-agency meeting)

Security Framing

The FPA justified regulating even farm users by warning that drones could be used “for terrorism activities” — a rationale that folds agricultural drones into national-security oversight, and that critics of broad drone regulation cite as over-inclusive. (DA — Subsidized drone access)