The EU 2027 Digital Pesticide-Record Mandate: What Professional Users Must Capture

From 1 January 2027, every professional user of plant protection products (PPPs) across the EU must keep their application records in an electronic, machine-readable format. A handwritten spray diary, a scan of that diary, or a photo of a paper sheet will no longer satisfy the requirement. The rule applies to professional users generally, with no exemption for farm size or treated area.

This raises practical questions: who is caught, which fields you must record, which formats count as machine-readable, and how to prepare. Here is the detail, point by point.

What is the EU digital pesticide-record rule?

Professional PPP users have long had to record each treatment for traceability. That duty is not new: Article 67 of Regulation (EC) 1107/2009 already requires users to record each treatment and make it available to the competent authority on request. What changes in 2027 is the form of the record, which must now be structured and readable by software rather than kept on free-form paper.

The change comes from Commission Implementing Regulation (EU) 2023/564, adopted on 10 March 2023, which sets out the content and format of PPP records and introduces the machine-readable requirement (machine-readable in the sense of Article 2(13) of Directive (EU) 2019/1024). It originally applied from 1 January 2026. Commission Implementing Regulation (EU) 2025/2203 then added a one-year grace period, so the requirement to hold records in electronic, machine-readable format takes effect on 1 January 2027, with paper accepted through 31 December 2026.

Because both texts are Regulations, they are directly applicable in all 27 member states without separate national transposition. They also reach Northern Ireland through the Windsor Framework, since Regulation (EC) 1107/2009 sits in Annex 2; DAERA is the competent authority enforcing it there, and confirms the NI grace period running to 1 January 2027.

Who is affected by the 2027 obligation?

The obligation falls on professional users of plant protection products, with no threshold of size, area or turnover and no exemption for smaller holdings. If you apply PPPs in a professional capacity, you are in scope. That covers arable crops, horticulture, fruit and viticulture, and it also reaches contractors and spray operators who treat land for others. A contractor has to pass the record of each application back to the holding it worked on, so every farm holds the traceability for its own parcels. Certain non-agricultural professional uses are caught too.

A holding that applies no plant protection products has nothing to record under this rule, which is specific to PPPs: it does not, by itself, create a record-keeping duty for livestock or fertilisation, which sit under separate rules.

What must you record?

The rule keeps the core of the spray record and adds coded fields so software can check the data. For each use of a product, the record must include:

• the product name and its authorisation (MAPP) number;
• the date of application;
• the dose applied;
• the area treated and its size;
• the location of the treatment;
• the crop, identified by its EPPO crop code;
• the crop growth stage, identified by its BBCH code.

An EPPO code pins down the crop and a BBCH code fixes the growth stage at the time of application, so an inspector or an audit system can match each treatment to an authorised use without reading free text. These content fields apply from 1 January 2026; the electronic format arrives on 1 January 2027.

Which formats are accepted?

The format of the record has to be structured and readable by machine.

Compliant

• a structured file, such as a spreadsheet properly organised into columns;
• an XML export;
• a PDF generated by a record-keeping system from structured data.

Not compliant

• a record kept by hand on paper;
• a scan of a paper diary;
• a photo of a sheet filled in by hand.

The test is whether software can read the data back. A PDF that is only an image of a handwritten page cannot be parsed, so it fails, unlike a PDF produced directly by a record-keeping tool from structured fields.

The timeline: how the grace period works

The dates that matter:

1. From 1 January 2026: the new content fields apply. Records must already carry the authorisation/MAPP number, EPPO crop codes and BBCH growth-stage codes, on top of product name, date, dose, treated area and size, location and crop.
2. Through 31 December 2026: paper records are still accepted under the grace period added by Regulation (EU) 2025/2203.
3. From 1 January 2027: all professional-user PPP records must be kept in electronic, machine-readable format across the 27 member states and Northern Ireland.

Ireland: a worked English-language example

Ireland is the cleanest English-language case: the EU rule applies directly, with no separate national deadline displacing it. The competent authority is the Department of Agriculture, Food and the Marine (DAFM), through its Pesticide Registration and Control Division (PCS). Irish professional users already keep records of purchase, use and disposal of PPPs, so the 2027 change is about the format those records take, not a wholly new duty. DAFM's record-keeping guidance for professional users sets out the expectations.

Northern Ireland sits in the same regime by a different route: through the Windsor Framework, Regulation (EC) 1107/2009 continues to apply, DAERA enforces it, and the same 1 January 2027 electronic-format deadline applies, with paper accepted to the end of 2026.

What about the UK, US, Australia and New Zealand?

The EU 2027 rule binds the 27 member states and Northern Ireland. It does not bind Great Britain, the United States, Canada, Australia or New Zealand. Each has its own record-keeping duty, and the EU change is best read as the leading edge, not a rule that reaches across borders.

• Great Britain (England, Wales, Scotland): professional PPP users must keep application records for at least three years under the Plant Protection Products Regulations 2011 and the Sustainable Use Regulations 2012, overseen by the HSE. Records may be paper or electronic, with no machine-readable mandate. Note the UK split: Northern Ireland follows the EU rule, Great Britain does not.
• United States: under FIFRA and 40 CFR part 171, certified applicators must record restricted-use pesticide applications (brand or product name, EPA registration number, total quantity, date and location) and keep them for at least two years. No format is mandated, and there is no federal electronic mandate. USDA AMS even rescinded its own RUP recordkeeping survey rule, effective 11 July 2025. California is the state exception: its Pesticide Use Reporting programme requires detailed reporting of nearly all agricultural use and can be filed electronically, but that is reporting to the regulator, not a rule on on-farm record format.
• Australia: applicators keep records of each application under state law plus the APVMA label Directions for Use, commonly retained for around two years (Western Australia requires a record within seven days, kept two years). The APVMA regulates products, the states regulate use, and there is no EU-equivalent machine-readable mandate.
• New Zealand: written records are required for certain work-use agrichemicals as a PCBU responsibility under EPA and HSWA rules, and new importer and manufacturer reporting requirements phase in from 2026. There is no EU-style electronic record-format mandate for applicators.

Records are expected everywhere; what differs is whether the regulator dictates the format. The EU and Northern Ireland are the only jurisdictions here on a fixed machine-readable deadline.

How to prepare

A few steps:

1. Take stock of how you record today and which fields you already capture.
2. Check that you collect every required field, including the coded ones (authorisation/MAPP number, EPPO crop code, BBCH growth stage).
3. Choose a usable format: a structured spreadsheet for the simplest holdings, or a tool that produces a compliant export.
4. Record at the point of treatment, in the field, to cut re-entry.
5. Set up reliable storage so records can be retrieved at an inspection.

Recording in the field is often the hardest part, especially on parcels with poor mobile coverage. A tool for agricultural data capture and treatment traceability in the field like FormRift lets operators enter treatment details on a phone, even offline, then sync them into a structured, machine-readable record once a connection returns. The digital forms and offline capture keep entry consistent and preserve the audit trail inspectors expect, with the photos, GPS location and secure storage that back up each application. The aim across inspections, audits and reports is the same: simplicity, audit trail, security, on whichever regime applies to you.

Frequently asked questions

Is paper still allowed in 2027?

No. Paper on its own is no longer compliant from 1 January 2027, having been accepted through 31 December 2026 under the grace period in Regulation (EU) 2025/2203. From 2027, the machine-readable record is what counts.

Does a spreadsheet count?

Yes, provided it is properly structured, with clear columns for each required field, including the authorisation number, EPPO crop code and BBCH growth stage. One filled in loosely does not meet the machine-readable requirement.

Who has to keep the record?

Every professional user of plant protection products, with no threshold of size and no exemption. Contractors and spray operators must pass their records back to the holdings they treat, so each farm holds its own traceability.

Does this apply to Great Britain?

No. Great Britain is outside the EU rule: professional users there keep PPP records for at least three years under HSE oversight, in paper or electronic form, with no machine-readable mandate. Northern Ireland is the exception within the UK, following the EU rule through the Windsor Framework, so the 2027 deadline applies there.

Does this cover livestock or fertilisation?

No. The obligation is specific to plant protection products and does not, by itself, create a digital-record duty for livestock or fertilisation, which fall under separate rules.

The takeaway

From 1 January 2027, professional-user PPP records across the EU and Northern Ireland must be kept in an electronic, machine-readable format. The duty to record is not new; the requirement on its form is the change.

• Handwritten paper, scans and photos no longer count; a structured spreadsheet, an XML export or a software-generated PDF do.
• The content fields (authorisation/MAPP number, EPPO crop code, BBCH growth stage) apply from 1 January 2026; the electronic format from 1 January 2027.
• Ireland follows the rule directly via DAFM/PCS; Northern Ireland via DAERA under the Windsor Framework.
• Great Britain, the US, Australia and New Zealand keep their own, separate duties, and none carries the EU machine-readable mandate.

Settling on a usable format and a routine of recording at the point of treatment, well before the deadline, is the steadiest path to compliance.