Electronic record of treatments with plant protection products – a requirement that will make life difficult for farmers

• A draft of these regulations was published by the European Commission on 22 June 2022, providing a regulation of the European Parliament and of the Council on the sustainable use of plant protection products.
• There is also a draft implementing regulation prepared by the European Commission regarding the content and form of electronic records of the use of plant protection products by professional users, i.e. farmers and gardeners.

Significantly developed requirements will go beyond the currently established obligations of maintaining records of plant protection products as we know them to date.

as a professor. Marek Mrówczyński, Director of IOR – PIB in 2018-2021 and 2007-2012 These documents show that every order for a plant protection product must be executed by practitioners in electronic form and registered without undue delay after preventive treatment. Procedure. The professional user will have 30 days to do so from the date of application of the plant protection product. This data will be required to provide (perhaps the responsible unit is PIORiN) in the form of electronic records of preventive treatments.

In connection with the above, each processing can be automatically checked by the controller, and the log can become the basis for imposing penalties in case of use in violation of the intended use.

What should be recorded in such a register for fire protection?

Unfortunately, the number of columns in the proposed new “record” has increased.

As noted by the professor. Mrówczyńskie, Appendix to the Regulations states that in addition to the trade name of the plant protection product, you must also enter the authorization number for a specific preparation, which was issued by the Ministry of Agriculture and Rural Development of Poland during the registration procedure. The batch number and date of manufacture of the preparation used must also be recorded.

In addition, in accordance with Article 14 of the draft European Commission Regulation, the electronic record must be accompanied by information on any preventive or intrusive measures related to the implementation of IPM. Information related to pest identification and assessment of their incidence should be provided.

In addition, an obligation to record information electronically has been introduced, in which you must provide the name, surname and date of the consultant, as well as the content of the advice given.

The names of plants and pests protected according to the EPPO codes, i.e. the European and Mediterranean Plant Protection Organization, must be included in the electronic documents.

Furthermore, the date and time of the start of the preventive treatment and the phase of the protected station must be entered according to the BBCH in the electronic records.

The agent dose should also be recorded in liters or kg per hectare or seed treatment per ton. In addition, the total volume of the protected area with a specific preparation should be given (ha if it concerns the application of plant protection products, but also the treated seed material used, m 3 if it is a room, kg or ton for seed hardening).

The geospatial location of the protected farm must also be provided, in accordance with the IACS Management and Control System.

All such data, in accordance with Article 16 of the draft European Commission Regulation, must be stored for at least 3 years from the date of its submission.

It should also be noted that this data will also apply to mortars and this document will have to be accurately supplemented also in the case of dressing, and most importantly, also in the case of purchasing certified materials.

The introduction of the obligation to register the electronic license number issued by the Ministry of Agriculture and Rural Development for a specific plant protection product, in addition to the batch number and production date of the preparation, is unnecessary, as it leads to additional bureaucracy. This will not solve any problem and will only make life difficult for farmers – comments on the professor’s new commitment project. Mrówczyński.

Electronic registration will greatly increase the bureaucracy on the farm

– The introduction of the regulation will lead to higher plant production costs and contribute to regulatory problems, because the professional user, instead of dealing with production technology, will have to spend a lot of time on work related to the electronic record of protection treatments – the professor adds. Mrówczyński.

Moreover, according to prof. Mrówczyński:

In the end, the proposed regulations will prevent the proper and effective implementation of the tasks related to plant protection, which may lead to the development of pests, that is, the quantity and quality of the yield of plant raw materials will be lost.

Is the Polish farmer ready to keep these detailed records?

As noted by the professor. Mrówczyński, an EU project to introduce a commitment to an electronic registry of treatments with plant protection products from 1 January 2025, in Poland will apply to nearly 1.3 million agricultural and horticultural farms. In his opinion, there are currently more than 0.1 million professional users of plant protection products that are technically and organizationally ready to introduce an electronic registry of preventive treatments into plant production within two years.

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