Lobbying on Common rules on the plant protection product use records to be kept by professional users under Regulation 1107/2009

Common rules on the plant protection product use records to be kept by professional users under Regulation 1107/2009

Food safety

Under Article 67(1) of Regulation (EC) No 1107/2009, professional users must keep records of the plant protection products they use, containing the following elements: the name of the product, the time and the dose of application, the area and the crop where the product was used. The Implementing Regulation will specify exactly how such elements must be recorded and will provide that the records must be kept in an electronic format.

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Public consultation

ID: 13185

Lobbying Activity

15 responses

ClientEarth leads push for mandatory digital pesticide records

ClientEarth AISBL, 3 Nov 2022

The coalition urges national governments to approve mandatory electronic records for pesticide use. They argue that digital data is essential for effective environmental monitoring and protecting agricultural workers.

Comprehensive digital data helps these groups monitor environmental impacts and pesticide statistics.

Professional users lose the ability to keep simpler, less accessible handwritten records.

CropLife Europe urges digital labels for pesticide record-keeping rules

CropLife Europe, 3 Nov 2022

CropLife Europe suggests Digital Labels to enable the immediate record of product use and facilitate document generation. They advocate for a commonly agreed data standard that supports interoperability across different systems and stakeholders. The group also warns against the risk to double count product uses when recording seed treatments.

Unified digital standards would simplify data management and lower technical barriers for product users.

Environmental monitoring groups lose specific data on seed treatment locations if only sowing is tracked.

Swedish farmers call for flexible digital pesticide reporting

Lantbrukarnas Riksförbund, 3 Nov 2022

The reporting system must be easy to handle and integrate with existing programs. Farmers also want to record product doses according to labels instead of specific weight metrics.

This would minimize unnecessary bureaucracy and technical challenges for professional pesticide users.

Regulatory agencies lose the benefit of standardized digital data for environmental monitoring.

Euroseeds warns against double counting in pesticide record rules

Euroseeds, 3 Nov 2022

The organization requests removing the requirement to record the sowing of treated seeds to avoid double counting pesticide use. They also advocate for electronic systems connected to official databases to simplify data entry.

These changes would reduce the administrative burden and prevent inaccurate reporting of chemical use.

Member States would face higher costs to develop and maintain integrated electronic systems.

Landowners urge EU to build common digital farming records platform

European Landowners' Organization asbl, 2 Nov 2022

The ELO requests a common EU-wide platform to host integrated data for various farming records. They urge better definitions for electronic records and oppose requirements to track specific application hours. This would simplify procedures and prevent excessive bureaucracy.

A unified platform would reduce the bureaucratic burden and simplify administrative procedures for farmers.

Private software providers may lose market share if a free EU platform is developed.

EurEau backs mandatory digital records for pesticide use

European Federation of National Associations of Water Services, 2 Nov 2022

EurEau urges the Commission to adopt the digital recording rules immediately without reducing their scope. They request that records be stored for ten years to allow for long-term water quality tracing. Additionally, they advocate for training programs to assist farmers with the transition.

Digital data simplifies risk management and helps water suppliers identify contamination sources faster.

Farmers face new administrative burdens transitioning from handwritten paper slips to electronic records.

Biocontrol industry seeks specific metrics for electronic pesticide records

International Biocontrol Manufacturers' Association, 3 Nov 2022

IBMA requests including colony forming units as a standard concentration unit for microorganisms. They also suggest specifying application equipment types to prepare for future registers.

Standardized recording would better quantify the market share and usage of biocontrol products.

Chemical pesticide manufacturers face scrutiny as new data monitors the reduction of their products.

European Beet Growers Challenge Electronic Record-Keeping Requirements for Pesticides

International Confederation of European Beet Growers, 3 Nov 2022

The organization requests that farmers be allowed to keep paper records instead of being forced to use electronic formats. They argue the digital mandate ignores rural areas' lack of internet access and digital skills. They also oppose requiring EPPO codes and BBCH growth stages as unnecessary burdens.

This would avoid compliance costs and technical burdens for farmers lacking digital infrastructure.

Public transparency advocates lose detailed, standardized pesticide use data needed for oversight.

Coordination Rurale urges simplification of electronic pesticide recording rules

Coordination Rurale Union Nationale, 11 Oct 2022

The union demands merging separate registers and a drastic simplification of requirements. They oppose the mandatory shift to digital records to avoid administrative burdens.

Simplification would protect farmers from time-consuming tasks and additional software costs.

Regulatory authorities would lose the ability to perform continuous digital oversight and control.

Agricultural contractors warn of costs from electronic pesticide records

Confédération Européenne des Entrepreneurs de Travaux Techniques Agricoles, Ruraux et Forestiers/ European Organisation of Agricultural, Rural and Forestry Contractors / Europäischer Zentralverband der Lohnunternehmer, 3 Nov 2022

CEETTAR is concerned about the additional costs of data recording and the technical complexity of the requirements. They suggest that the volume of data could necessitate the use of advisory services.

Increased administrative complexity for farmers could lead to more business for professional contractors.

Farmers face a more difficult administrative process which may increase their operational expenses.