The United States Environmental Protection Agency has required an unprecedented insect resistance management (IRM) program for Bt cotton. The specific IRM strategies and requirements for Bt cotton (Bollgard? cotton) in the United States have been developed by a coalition of stakeholders including EPA, USDA, academic scientists, public interest groups, Monsanto Company, and grower organizations. There are seven basic IRM requirements: structured refuge, resistance monitoring, remedial action plan, compliance assurance, grower education, grower agreements, and annual reports. The mandatory refuge requirements for Bollgard cotton are: (1) 5% external, unsprayed refuge option, (2) 20% external, sprayed refuge option, (3) 5% embedded refuge option, or (4) a community refuge option that may utilize the 5% external, unsprayed refuge option and/or the 20% external, sprayed refuge option. Each refuge option also has specific deployment requirements. The current registration for Cry1Ac plant-incorporated protectant as expressed in cotton (known as Bollgard cotton) expires September 30, 2006, except for the 5% external, unsprayed structured refuge option, which will expire September 30, 2004. Additional research data will be integral to strengthening the existing IRM plans for Bollgard cotton and promoting greater sustainability.