Digital spray register: what changes on 1 January 2027

What do the rules say?

The spray register is not new: Article 67 of Regulation (EC) No 1107/2009 already requires professional users of plant protection products to keep records of their use, with the product name, the time of use, the dose, and the area and crop treated.

Commission Implementing Regulation (EU) 2023/564 sets out its content and format: every use is recorded without delay, in an electronic, machine-readable format. This regulation has applied since 1 January 2026.

Implementing Regulation (EU) 2025/2203 then allowed Member States not to require conversion to electronic format for treatments carried out before 1 January 2027. This is the "postponement to 2027". France used this option: the register content changed in 2026, and the electronic format becomes mandatory in 2027. In Member States that did not, conversion within 30 days already applies to treatments since 1 January 2026.

In France, the ministerial order of 24 December 2025 sets the details: register content (Annex I), the format of each item (Annex II) and the conversion timeline up to 2030.

Who is concerned?

In France, every establishment identified by a SIRET number that uses plant protection products or their adjuvants, or has them used on its behalf, keeps a register. This covers all farms that use them, whatever their size or sector, and other professional users too: maintenance of green spaces, railways and uncultivated areas.

If you use a contractor, its register states your establishment's SIRET number, and it must give you access to its records or a copy of them, without delay.

Organic farms are concerned as soon as they use plant protection products: organic production is one of the items to record.

What must be recorded?

For every use of a product on a surface or in a facility, for a given crop, Annex I of the French order of 24 December 2025 lists the mandatory information:

• the SIRET number of the establishment keeping the register and, for contract work, that of the client establishment;
• the trade name of the product and its marketing authorisation number;
• the date of the treatment;
• the dose applied per unit of area or volume, for example in kg or L per hectare;
• the area or volume treated;
• the crop treated;
• the location of the treatment: block and parcel numbers in the French land parcel identification system (RPG) and the municipality's INSEE code, or otherwise the GPS coordinates of a point in the plot;
• whether the production is organic.

Where relevant, also record the start and end times when the rules or the authorisation require them (for example for a treatment during flowering outside the regulatory time window), the crop growth stage (BBCH scale) when the use is limited to certain stages, early re-entry into a treated plot, and the batch number of treated seeds or plants. The target pest and the application method may be added. The DRAAF fact sheet also points to the information required by the French order of 16 June 2009: the grazing interval after treatment, harmful organisms spotted and analysis results relevant to food safety.

Which formats are accepted?

The register must be kept in a "machine-readable" electronic format as defined by Directive (EU) 2019/1024: a structured file from which software can identify and extract each item of data.

Annex II of the French order sets the format of several items: 14-digit SIRET number, 7-digit authorisation number, date as DD/MM/YYYY, times as HH:MM, dose as a number with its unit, GPS coordinates in decimal degrees (WGS84). Items with no specific requirement are free format.

In practice, traceability software or a spreadsheet whose columns follow these formats will do: the fact sheet of a French regional agriculture directorate (DRAAF) explicitly mentions spreadsheets. A photo or scan of a paper notebook, on the other hand, is not a structured file under this definition.

The same fact sheet states that the French ministry of agriculture was to provide, during 2026, an application for farmers who have no computer tool.

Paper or digital register: the timeline in France

Treatments in 2026

The new content is mandatory. A paper register remains valid: no conversion to electronic format.

Treatments from 2027 to 2029

The electronic format is mandatory. You may note treatments on paper first, provided the register is converted to electronic format before 31 January of the following year.

Treatments from 2030

Conversion to electronic format must be done within 30 days of the treatment.

During an inspection

The register is provided without delay. If the authority asks for the electronic format before the conversion deadline, you provide it before that deadline or within 10 working days, whichever comes first.

In every case, each treatment is recorded without delay and the register is kept for at least 5 years. Recording directly in electronic format, at the time of treatment, avoids entering everything twice and catching up in January.

Spray register and Certiphyto: two different things

Certiphyto is an individual certificate: it attests that a person has the knowledge required to use, sell or advise on plant protection products as part of their professional activity (Article L254-3 of the French rural code). It belongs to the person, not to the farm.

The spray register records the treatments carried out by the establishment: which product, at what dose, on which plot, on which day. Both obligations apply: holding a Certiphyto does not exempt you from keeping the register.