New Requirements for plant protection product (PPP) record-keeping by professional users

Update: Delayed Start for Mandatory E-Transfer Commission Implementing Regulation (EU) 2025/2203, adopted on 31 October 2025 and effective immediately, allows Member States to defer the requirement to transfer PPP usage records into the electronic format until 1 January 2027. These adjustments aim to accommodate implementation readiness challenges, such as training needs, especially for non‑agricultural users and small-scale operations.  Accordingly, the Department is delaying the mandatory electronic transfer for PPP use until 1 January 2027

Introduction

Keeping accurate and detailed records of plant protection product (PPP) applications are essential to demonstrate legal compliance and good stewardship in PPP use. Under Article 67 of Regulation (EU) 1107/2009, all professional users must:

• document and maintain PPP usage details—including product name, application time, dose, treated area, and crop.
• retain spray records for at least three years.
• provide PPP usage records to the competent authority on request. 

Third parties such as arm's length bodies, research institutions, or residents may also request access to this information, under The Environmental Information Regulations 2004, through the competent authority. Any disclosed information will be provided in line with data protection requirements and taking account of commercial confidentiality, or other protected interests. 

In addition, the Code of Practice for Using Plant Protection Products (CoP) recommends recording extra information to confirm that PPPs have been applied safely, appropriately, and in line with the conditions of use.

What changed on 1 January 2026

From 1 January 2026, new content and format requirements and timing rule apply:

• Professional users must record each use of a plant protection product promptly, without unnecessary delay.
• Additional mandatory details must be included in records:
  • Product authorisation number (MAPP).
  • EPPO codes for crops/land uses.
  • Crop growth stages in line with the BBCH Monograph (where the label states the use of the PPP is restricted to a particular growth stage).
• Contractors must provide the person or business they work for access to or a copy of all relevant PPP records without undue delay or restrictions.
• The professional user (the person who carries out the spraying) must keep the records in the specified format and if requested to do so by the Department, submit such records within 10 working days of a request, unless an alternative timeframe is specified by the Department at the time of the request.

During 2026 DAERA will not apply penalties to users who are found to be in non-compliance in terms of the new content requirements. This will allow the Department time and opportunity to provide any necessary guidance to users. However, this does not remove existing record keeping requirements already in place under Regulation (EC) 1107/2009, which will still be applicable.

Requirements that apply from 1 January 2027

To support a smooth transition and allow professional users additional time to prepare, DAERA has exercised the option to postpone the mandatory electronic transfer of PPP records until 1 January 2027.

From this date all professional Users must comply fully with the mandatory requirements, including compliance with the electronic, machine-readable standards.

If records are initially created on paper, they must be converted into the prescribed electronic format without undue delay. The final deadline for all records to be held electronically is 31 January of the year following the year of use.

Example: Any PPP application carried out during 2027 must be recorded electronically by 31 January 2028.

Acceptable machine-readable electronic formats

Machine-readable electronic formats are those that allow data to be readily extracted, searched, analysed, and transferred between systems without manual re-entry. Examples of acceptable machine-readable formats include:

• CSV (.csv)
• Microsoft Excel workbooks (.xlsx)
• XML (.xml)
• JSON (.json)
• Other structured electronic formats capable of being electronically processed and analysed

The format used should preserve all required pesticide application record data and enable the information to be provided to the Department upon request.

Formats that are NOT machine-readable

While formats such as PDFs or scanned images (for example, JPEGs) are digital and electronically accessible, they are not machine-readable because the data cannot be readily extracted, searched, or analysed by computer systems.

What if I use a contractor?

Where a contractor is carrying out work on behalf of a business, the contractor, as the professional user, is responsible for creating and retaining the pesticide records in the required machine-readable format. The contracting business may retain a copy of the record in another format, such as a PDF, for its own reference, provided the contractor maintains the original record in the correct machine-readable format.

Where requested by the contracting business, the contractor must provide the pesticide records in the required machine-readable format without undue delay, including where the records are required to be supplied to the Department.

DAERA Template and Supporting Information

To support agricultural and horticultural (food crop) users with no access to specialised software or mobile applications, DAERA has developed, with input from key stakeholders, an excel template that can be downloaded and used, along with supporting guidance on EPPO codes and the BBCH Monograph available via the green button below. 

Using this template guarantees that all required data fields are captured correctly and in line with Regulation (EU) 2023/564. However, you are free to use your own template or software. 

PPP Spray Record Template and Guidance 

Data protection  DAERA adheres to UK General Data Protection Regulation (UK GDPR 2016), Data Protection Act 2018, Freedom of Information Act 2000 and Environmental Information Regulations 2004. These laws require that; Personal data is only shared when there is a lawful basis, data is anonymised or pseudonymised before being shared or published. When DAERA divisions share data internally, for example with Agents working on their behalf, safeguards access is role-based and limited to staff with a legitimate need, Data Protection Impact Assessments (DPIAs) are conducted for high-risk data sharing activities and Information Management Branch oversees compliance.