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 pesticide 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 records to the competent authority on request. Third parties such as the drinking water industry, retailers, or residents may also request access through the competent authority.

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’s changing in 2026?

From 1 January 2026, new content and format requirements and timing rules will 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
  • BBCH codes for crop growth stages
• 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 only 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.

Useful Guidance

• Lists of crop names and land uses and their corresponding EPPO codes (Coming Soon).
• You can read more about EPPO Codes by accessing the EPPO global database at What is EPPO Global Database?.
• You can search for specific EPPO Codes for the uses of plant protection products by crop group at EPPO Computer codes for the uses of plant protection products.
• Growth stages of mono-and dicotyledonous plants - BBCH Monograph (2. Edition, 2001), Edited by Uwe Meier, Federal Biological Research Centre for Agriculture and Forestry.

Template (coming soon)

Click here to access a downloadable excel template, with guidance, to record PPP usage electronically. This will support users without access to specialized software or mobile applications and guarantees that all required data fields are captured correctly and in line with Regulation (EU) 2023/564.

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.