Spray Drone Certification: Part 137, Exemptions and What It Takes to Apply by Drone
Spraying or spreading anything from a drone, even water or cover crop seed, puts you under 14 CFR Part 137, the same rule that governs crop dusters. Here is the full certification stack, in the order you tackle it, and how long each piece takes.
- Every spray drone path starts with a Part 107 Remote Pilot Certificate. The knowledge test is the first domino
- Dispensing any substance for agriculture requires a Part 137 Agricultural Aircraft Operator Certificate plus an FAA exemption. Drones are not excused from the crop dusting rules
- Under 55 pounds loaded, you fly under Part 107 with an exemption. At 55 pounds or more, which covers most loaded DJI Agras, Hylio and XAG rigs, you move to Parts 91 and 137 with an N-number
- The FAA asks for exemption petitions at least 120 days ahead, and the process often runs longer. Spraying next season means filing this winter
- Nearly every state also requires a commercial pesticide applicator license with an aerial category before you spray anything with a label on it
Why a spray drone needs more than Part 107
Part 107 covers flying a drone for business. It does not cover dispensing. The moment product leaves the aircraft, two more rules wake up: 14 CFR 107.36, which bans carrying hazardous materials under Part 107, and 14 CFR Part 137, which regulates agricultural aircraft operations. The FAA treats a 10-gallon spray drone the same way it treats an Air Tractor in this respect. You need an exemption from the rules written for crewed aircraft, and then a Part 137 operator certificate issued on top of it.
Track 1: spray drones under 55 pounds
A handful of smaller spray and spreader drones stay under 55 pounds fully loaded. The stack for them:
- Hold a Part 107 Remote Pilot Certificate
- Petition the FAA for an exemption from 107.36 and the Part 137 sections written for crewed aircraft
- Register the aircraft at FAADroneZone and receive an FA number
- Apply for the Part 137 Agricultural Aircraft Operator Certificate on FAA Form 8710-3 once the exemption is granted
Track 2: spray drones 55 pounds and over
Most working spray drones cross 55 pounds the moment the tank is full, and that changes the paperwork:
- The aircraft gets an N-number through the FAA Civil Aviation Registry instead of a FAADroneZone registration
- You petition for an exemption under 49 U.S.C. 44807 covering portions of Parts 61, 91 and 137
- You apply for the Part 137 operator certificate after the exemption is approved
- The FAA's standard conditions still require the pilot in command to hold a Part 107 certificate, so the knowledge test remains step one
The state layer: pesticide applicator licensing
The FAA side gets the attention, but the state side grounds just as many operations. Applying pesticides by drone requires a commercial pesticide applicator license in nearly every state, usually with an aerial application category, issued by your state department of agriculture. Product labels still govern: if the label does not allow aerial application, a drone cannot legally put it on. Some states add an aerial applicator business license and recordkeeping on top. Budget time for the state exam the same way you budget for the FAA test.
A realistic season-planning timeline
| When | What |
|---|---|
| 12+ months out | Get your Part 107 certificate and your state applicator license. Pick the aircraft |
| 6 to 9 months out | File the exemption petition, register the aircraft, line up insurance |
| 3 to 6 months out | Exemption granted, submit Form 8710-3 for the Part 137 certificate, work with your FSDO |
| Season | Certificated, licensed and legal to spray |
Frequently asked questions
Do I need Part 137 to spread dry product like cover crop seed or fertilizer?
Yes. Part 137 covers dispensing any substance intended for plant nourishment, pest control or soil treatment. Dry spreading is treated the same as spraying.
Does spraying my own farm change anything?
No. Dispensing from an aircraft is regulated regardless of whose land it is or whether money changes hands. You still need the Part 107 certificate, the exemption, the Part 137 certificate and your state applicator license.
Can my employee spray under my Part 137 certificate?
The operation runs under your Part 137 certificate, but each pilot in command still needs their own Part 107 certificate and must be listed per your exemption's conditions. State rules add their own requirements for who holds the applicator license.
How long does the whole process take?
Plan on 6 to 12 months from deciding to spray to being fully legal, driven mostly by the exemption docket. The FAA asks for petitions at least 120 days out and the queue regularly runs past that.
Is water or a rinse tank still regulated?
Yes. Dispensing anything, water included, from the aircraft falls under Part 137. There is no de minimis carve-out for harmless liquids.
Step one is the Part 107 test
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