Understanding the new regulations as a Cooperative
The Farm to Fork strategy in the EU has been introduced to promote better decision-making on farms and thereby reduce the environmental impact of chemical pesticide usage. These new regulations come with legally binding targets that are expected to be finalized by the end of 2023. But did you know that there are already legally binding regulations for farm reporting? Effective 1 January 2026, all EU farms will legally be required to comply with stricter requirements for chemical use reporting, and cooperatives are in a unique position to support farms with this important transition.
If you own, manage or advise a farm in an EU member country, you need to know what’s already law and what to expect to become legally binding within the next two growing seasons.
Many agricultural cooperatives are key to the success of grower compliance and supporting farms with their reporting processes, so these new laws demand critical attention from farms and from the cooperatives that support them.
Here is what we know is legally binding for January 1, 2026:
- Product usage records must be kept up to date within 30 days of the latest applications.
- Product usage should be documented back to a specific geospatial location (i.e. field map).
- Records must be available to the necessary authorities, and ultimately accessible to the EU.
- Records must be stored in an electronic format or transferred to an electronic format within 30 days of the latest application.
- Whenever applicable, standard EPPO codes for plants and pests should be used in record keeping.
- Whenever applicable, standard BBCH codes for growth stages should be used in record keeping.
The targets in the Farm to Fork strategy include a proposal to cut pesticide use on farms by 50% within the next 6 growing seasons. (See targets in detail below). While the exact details of the targets will become law in a few short months, the trend is clear: chemical usage on EU farms needs to be reduced and proven. So, what does this mean in practice? Each country will make their own plan to meet these targets, and it goes without saying that IPM (Integrated Pest Management) will play a key role in reaching the reduction targets.
If you have experience with IPM, then you understand its adoption requires the following, at a minimum, with respect to chemical applications on farm:
- The farm must document the necessity of every spray and fertilizer application.
- A certified agronomist reviews and signs off on the spray applications planned by every farmer for every field.
- Every application needs to be planned and reviewed beforehand, not just documented after completion.
We can confidently predict that these work processes from IPM will soon be adopted as EU regulations, which means it’s important to start thinking about how the current work processes on the farm and the cooperative can adapt to future requirements.
Want to stay up to date on the changing EU Regulations in Agriculture? The team at Farmable distributes a digital newsletter on EU Compliance. You can join our mailing list for free in English, German or Spanish. ⬇️
The following infographic has been provided by the Entomological Society of America.
Current practices in the Cooperative (and on farm) aren’t compliant
Currently, it is common for farmers to document their crop treatment jobs after completion, often postponing it until just before an audit. It is also common for farmers to inform their cooperatives about completed jobs (via phone, SMS, email or even fax), and the cooperative maintains the spray logs on behalf of the farm. While this practice may have felt convenient, it is in direct conflict with the new legally binding regulations (and the regulations we expect to be legally binding very soon).
Here are some key questions to reflect on as a cooperative:
- If a coop submits compliance data that was received initially via phone or SMS from the farm, who is responsible for the data being correct?
- What if the farmer reports having sprayed a product the coop does not agree with?
- How can a coop ensure traceability of decision-making between an agronomist and a farm manager?
- How to collect digital signatures or authorizations?
Cooperatives, particularly those who take on the responsibility of agronomy advice or compliance reporting, will need the following changes to support their member farms in just two short farming seasons:
- Electronic, two-way communication between the farm and the cooperative to provide a traceable timeline of decisions taken with respect to treatment applications.
- Digital signatures from the agronomist on all treatment applications recommended to the farm, including a geospatial reference to a specific field (i.e. a digital field map).
- Continuously updated farm records on a secure channel, with documented consent from the farm. Quarterly or end-of-season submissions from the farm to the cooperative will no longer be sufficient.
Cooperative support is essential for farms to adapt
To meet the new regulations, farmers and coops need to align their work processes and ensure user-friendly systems are in place to exchange information. Here’s how the necessary changes can be made together:
1) Direct, digital data access: Instead of relying on manual communication with the farm, like a phone call or text messages, it is crucial to have authorized access to digital farm data (i.e. a planned spray job or a pest observation) directly from the farm. This ensures the data is traceable, timely, and easily shared with pre-approved parties.
As the cooperative, there is a significant upside to supporting your member farms in their use of a digital tool as early as possible. First and foremost, compliance. All farms in the EU will legally be required to document pesticide and fertilizer use electronically within the next 2 growing seasons. Further, this is an opportunity to radically reduce the administrative workload for both the farm and the cooperative. If we can eliminate data entry, we can improve accuracy and timeliness and support better business decisions by the farm and the cooperative, in addition to meeting the new legislative requirements. Imagine the buying power of a cooperative with farm production data at their fingertips? Digital processes will start with pesticides and fertilizer applications but could also include production volumes or qualities and can significantly improve the market outcome for farms and their cooperatives as a team.
2) Certified advisor verification: As per the regulatory requirements, a certified advisor must verify crop treatment jobs before execution. Coops should establish clear guidelines on the cooperative’s role in this process, including if/how they will assist farmers in engaging with certified advisors and facilitating the verification step. Suppose the cooperative is not directly responsible for agronomy advice. In that case, it will still be essential for the cooperative to access a clear timeline of crop treatments and the corresponding approvals every 30 days in order to market the crops or submit compliance reporting on behalf of the farm.
Verifying every approval for every crop application for every field for every farm opens a complex web of emails, spreadsheets and paperwork. This underlines the need for direct, digital data to be exchanged between the farm and the cooperative. It will require an investment of time to evaluate digital tools that can support both the capture of farm data and the communication between farms and their advisors, but it will be impossible to keep up with the legislative requirements using the old ways of working.
3) Establishing cooperative responsibilities: Each cooperative should define its formal responsibilities and liabilities towards the new EU regulations, specifically the Farm to Fork strategy (never heard of it? Get a summary here). This includes understanding the coop’s role in ensuring compliance, assisting members with data quality and maintaining the necessary records. It is to everyone’s benefit that the cooperative takes a leading role in supporting the farms to adopt a digital tool that can be used by the farm, its advisors and ultimately, the cooperative. Communicating a clear standard process for reporting and verification will substantially reduce administration work for the cooperative to deliver on its commitments.
Your impact as a Cooperative is far-reaching
In conclusion, adapting the work processes both on the farm and in the Cooperative to facilitate efficient data capture and reporting is essential for complying with the new agricultural regulations in the EU. Cooperatives play a crucial role in supporting their members throughout this transition. By assisting members in using digital tools correctly, ensuring sufficient data quality, and establishing clear responsibilities towards the EU, cooperatives can streamline operations and contribute to the overall success of not just compliance but the business results of its farm members.
At the same time, farm owners and farm managers must acknowledge that the overall responsibility for all operations, documentation, and reporting involving chemicals and fertilizers is their responsibility. This responsibility cannot be handed over to the cooperative.
If you have any questions or need assistance adapting your work processes to facilitate efficient data capture and reporting, please contact us. We are here to support you and your coop in this transition and help create a more sustainable future for agriculture.
Read about the importance of getting started with digital documentation.
Suggested Further Reading
Want to learn more about the regulatory changes discussed in this article? You can keep yourself informed through the following policy areas within the EU Farm to Fork Strategy.
Sets stricter requirements for the use of pesticides and introduces new enforcement mechanisms for Integrated Pest Management, including mandatory use of electronic records. The sales of plant protection products will be monitored. The law is expected to be approved in 2023.
The new CAP is revised to provide more targeted support to smaller farms and allow EU Member States to adopt measures to local conditions. The policy includes objectives and measures to align it with the targets set forth in the Farm to Fork strategy. The policy introduces stricter conditions on certain CAP payments directly to farmers. It enters into force in 2023 and will run until 2027.
The communication of November 2022 confirms the EU’s targets to reduce fertilizer use and nutrient loss. The strategy defines the actions the EU will take to meet the targets, including a commitment to approve the Integrated Nutrient Management Action Plan early in 2023.
Want to stay up to date on the changing EU Regulations in Agriculture? The team at Farmable distributes a digital newsletter on EU Compliance. You can join our mailing list for free in English, German or Spanish. ⬇️
