This review addresses examples of biological control of plant pathogens by bacterial agents which have already reached the market or are likely to be exploited commercially within the next few years. A few plant pathogens have been controlled successfully by commercial formulations of biological agents, but many attempts to develop biocontrol formulations have met with problems in practice. Problems in the development of bacterial biological control agents for plant pathogens can be identified as research or regulatory. Problems created by regulatory agencies involve lengthy procedures to obtain permits for shipment and importation of cultures, research permits to test biocontrol agents in the field, and inadequate communication with scientists on how to initiate the permit or registration process. The terms used by the regulatory agencies are often confusing and many scientist's lack the skills for negotiating with bureaucrats. Other problems discussed in this review are absence of: a national focus on biological control; funding for both basic and applied biocontrol research; appreciation by administrators for biocontrol research; cooperation among scientists, governmental regulatory agencies, and private industries; relevant research, such as population dynamics of biocontrol agents and microbial ecology. In addition, delays in obtaining regulatory approval and the high cost of obtaining patents are also discussed. Possible opportunities for biological control in view of various constraints of production are discussed.