Electronic plant protection records from 2027: what applies now
From 1 January 2027, plant protection records must be electronic and machine-readable. Deadlines, formats, retention and preparation for farms in Germany.
Key points
- Legal basis: Article 67 of Regulation (EC) No 1107/2009, specified by Implementing Regulation (EU) 2023/564. Regulation (EU) 2025/2203 allowed member states to require the electronic format only from 2027; Germany uses this postponement.
- Since 1 January 2026: extended mandatory content such as the EPPO code of the crop, the BBCH stage where relevant to the authorisation, and the georeference of the field.
- Until 31 December 2026: handwritten records are still permitted if they are complete.
- From 1 January 2027: electronic and machine-readable. Records not created electronically must be converted no later than 30 days after the application.
- Format: CSV, JSON or XML are suitable. A PDF does not count as machine-readable.
- Retention: at least three years.
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Keeping records of plant protection product applications has long been mandatory. What is new is the form: from 1 January 2027, professional users in Germany must keep their records in an electronic, machine-readable format. The content of the records was already extended on 1 January 2026. This article summarises what applies, which formats count and how farms can prepare.
Who is affected?
The duty applies to professional users of plant protection products: farms and horticultural businesses, contractors and others who apply plant protection products professionally. It covers applications in the field, in greenhouses, in storage and the treatment of seed and planting material. The plant protection services of the German federal states publish their own guidance; the information from Lower Saxony, Hamburg, Hesse and North Rhine-Westphalia agrees on the key points.
Timeline
| Date | Requirement |
|---|---|
| since 1 Jan 2026 | extended mandatory content under Implementing Regulation (EU) 2023/564 |
| until 31 Dec 2026 | records handwritten or electronic, if complete |
| from 1 Jan 2027 | electronic, machine-readable format mandatory |
| from 1 Jan 2027 | conversion of records not created electronically within 30 days after the application |
| ongoing | retention for at least three years |
What does "machine-readable" mean?
Machine-readable means that the data are structured and a program can process them without retyping. The plant protection services name structured formats such as CSV, JSON or XML and digital farm record software. According to the guidance of the federal states, no specific data schema has been prescribed so far; a nationwide uniform column structure was announced.
Not sufficient are:
- a PDF document, even if it was created on a computer
- a scanned or photographed paper form
- free text without fixed fields
A table with fixed columns saved as CSV meets the requirement for the form. In addition, all mandatory details must be included.
What must a record contain?
The required details are covered in Plant protection records: required fields. In short:
- name of the person applying the product
- type of use: field, greenhouse, storage or seed treatment
- date, and the time where the authorisation restricts the time of application
- product with authorisation number and the quantity actually applied
- field with name, georeference and treated area
- crop with EPPO code and, where the authorisation requires it, BBCH stage
Each treated crop is a separate entry; with staggered plantings, each planting date counts separately.
Deadlines: without delay and at the latest after 30 days
Records must be made without delay after the application. Anyone who first notes an application on paper or in a notebook must transfer it into the electronic format within 30 days after the application from 2027. This gives some leeway during the season but does not replace a timely note: quantities, times and fields can hardly be reconstructed reliably after weeks.
Retention and presentation
Records must be kept for at least three years. The Chamber of Agriculture North Rhine-Westphalia counts from the start of the following year: an application in 2025 is kept until the end of 2028 and may be deleted from 2029. Records are presented at the request of the competent authority; according to the chamber there is no automatic data retrieval. Records, conditions of use and evidence of sprayer inspections are also checked within conditionality inspections.
Which tools are available?
- Digital farm record software with a plant protection module and export
- PSM-DOK: a free web application of the German federal states for records
- Spreadsheet template of the Julius Kühn Institute, which becomes machine-readable when saved as CSV
- DiPAgE: a platform being developed by the Julius Kühn Institute
Which solution fits depends on the farm. A spreadsheet is formally sufficient but quickly becomes confusing with many fields, plantings and people. Farm record software links the records to fields, crops, stock and evidence.
Preparation in five steps
- Fields with georeference: store the FLIK or a GPS point for each field. In horticulture, internal names such as "House 1" remain permitted but need a point.
- Crops with EPPO codes: look up codes for your crops. What counts is the crop or crop group the product is authorised for.
- Products with authorisation numbers: create the farm's product list with authorisation numbers from the BVL register.
- People: keep the names of users and their certificates of competence at hand.
- Test the tool: record one application completely as a trial and open the CSV export.
How PhytAI handles the records
PhytAI records every application with all required details and shows what is still missing before an entry is completed. Products come with authorisation numbers from a mirror of the BVL register, crop and EPPO code from the crop cycle, the georeference from the field or a GPS point. Corrections are stored with a reason and history. The export is machine-readable as CSV and JSON. PhytAI does not make a final legal assessment of whether an application was permitted; that responsibility stays with the farm.
Frequently asked questions
Does the duty apply to small farms? The record-keeping duty applies to professional users regardless of farm size.
Is an Excel file enough? Yes, if it contains all required details and can be saved in a structured format such as CSV.
Do I have to send the data to an authority? According to the federal states' guidance, not automatically. Records are presented on request, for example during an inspection.
What about other EU countries? The EU requirements apply in all member states; national details such as deadlines and additional fields can differ. Check the guidance of your national authority.
Sources
- Plant Protection Service Lower Saxony: Dokumentationspflicht von Pflanzenschutzmittel-Anwendungen: Neue Vorgaben ab 2026, 15 Jan 2026, retrieved 13 Sep 2026
- Free and Hanseatic City of Hamburg: EU implementing regulation on digital, machine-readable documentation, retrieved 13 Sep 2026
- German Raiffeisen Association: Elektronische Aufzeichnungen gemäß PflSchG ab 2027, retrieved 13 Sep 2026
- Hesse State Agricultural Agency: Pflanzenschutz-Dokumentation: Hinweise zu den Neuerungen ab 2026, retrieved 13 Sep 2026
- Chamber of Agriculture North Rhine-Westphalia: Dokumentationspflicht von Pflanzenschutzmittel-Anwendungen (nurseries), retrieved 13 Sep 2026
- EUR-Lex: Implementing Regulation (EU) 2025/2203 and Implementing Regulation (EU) 2023/564, retrieved 13 Sep 2026
This article reflects the situation on the date shown, based on the sources named, and is not legal advice. Laws, approvals, official decisions and the guidance of the competent authorities prevail.