Dispensing Chemicals and Agricultural Products (Part 137) with UAS

The FAA has become aware of exemption holders conducting commercial agricultural operations in a manner noncompliant with the conditions and limitations of their exemption. Therefore, the FAA is implementing operational validations to ensure that each exemption holder fully understands their obligations to conduct operations in accordance with their exemption, the required Part 137 certificate, their ATO-issued COA, and all pertinent sections of 14 CFR. This includes basic requirements such as obtaining a Remote Pilot Certificate and registering their UAS.
 
The FAA has begun to send requests for information (RFI) seeking basic operational information. Without this information, the FAA will not move forward with a decision letter and will close your petition request for failure to respond to the RFI. If you have any questions about the RFI, please contact 9-AVS-ARM320-Exemptions@faa.gov


14 CFR Part 137 governs the use of aircraft, including drones, to dispense or spray substances (including disinfectants).

Not all substances fall under this regulation, so you should first check to see if your proposed operation is regulated by Part 137. If the substance you plan to dispense does fall within the definitions in Section 137.3 refer to Certification Process for Agricultural Aircraft Operators for guidance on the requirements you must meet before dispensing it.

What's an Agricultural Operation?

Under Part 137, the following aircraft operations are considered agricultural by nature:

  • Dispensing any economic poison as defined in Section 137.3 
  • Dispensing any other substance intended for plant nourishment, soil treatment, propagation of plant life, or pest control.
  • Engaging in dispensing activities directly affecting agriculture, horticulture, or forest preservation.

Note: The FAA considers chemicals used as disinfectants for viruses to fall in the category of economic poisons as defined in Section 137.3.

Applying for a Part 137 UAS Certificate

There’s a new streamlined process for those applying for a Part 137 UAS certificate. This allows the FAA to streamline both the Part 137 agricultural UAS certification and the drone exemption process for visual line of sight (VLOS) operations conducted within the altitude and airspeed limitations stipulated by the exemption.

Applicants are no longer required to submit documents to their local Flight Standards District Office. Instead, the applicant must complete FAA Form 8710-3 and submit their exemption number to UAS137Certificates@faa.gov for the FAA to begin the certification process.

How to Apply:

Last updated: Friday, May 23, 2025