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UK: Users of Professional Plant Protection Products reminded to register with Defra

Users of Professional Plant Protection Products (PPPs) in England, Wales, and Scotland are reminded to register with the Department for Environment, Food & Rural Affairs (Defra). This registration can be made as a business, organization, or sole trader and requires the completion and submission of a spreadsheet to Defra.

Together with users in England, Defra will also collect registration information on behalf of the Scottish and Welsh Governments.

What are Plant Protection Products?
Plant Protection Products is an umbrella term for products (and components of products) used to control pests, weeds, and diseases. This includes insecticides, fungicides, herbicides, molluscicides, and plant growth regulators sold and used as solid granules, powders, or liquids. PPPs also include safeners, synergists, co-formulants, and adjuvants.

Why is registration being introduced?
The Official Controls (Plant Protection Products) Regulations 2020 are the reason for this registration. They were introduced as part of an EU regulation in December 2019 and have been retained in UK law under the European Union (Withdrawal) Act 2018.

The regulations were introduced to enable regulatory authorities to support compliance and enforce legal requirements that apply to the placing on the market and use of PPPs throughout the supply chain.

Where do the regulations apply?
The Official Controls (Plant Protection Products) Regulations 2020 apply to the whole of Great Britain and supplement existing regulations that govern the sale and use of PPPs. Under the 2020 Regulations, the competent authorities are the Secretary of State for England, the Scottish Ministers for Scotland, and the Welsh Ministers for Wales. The main regulatory authority for the competent authorities is currently the Health and Safety Executive (HSE).

The Northern Ireland Executive has put in place its own legislation implementing and enforcing official controls for PPPs in Northern Ireland, and users in Northern Ireland are therefore not required to register.

Who needs to register?
Two categories of stakeholders need to register:

  1. Businesses that produce, manufacture, process, import, store, distribute, and sell PPPs, their components, and adjuvants to be used with PPPs.
  2. Any person or business that uses PPPs and any adjuvants in a professional capacity in Great Britain (England, Scotland and Wales)

What is the definition of professional user?

A 'professional user' is any person or business who uses PPPs in the course of their work activities, which may include agriculture and horticulture, amenity or forestry in Great Britain and do any of the following:

  • use professional PPPs and any adjuvants as part of their work, including if they are hired to spray PPPs on someone else's land
  • have professional PPPs and any adjuvants applied by a third party as part of their work in agriculture or horticulture, amenity or forestry
  • use PPPs when working in agriculture or horticulture, for example, when farming or maintaining arable crops, forage crops or livestock, or when treating seeds

Association members are likely to fit into the amenity or forestry sectors. These are defined as follows:

Amenity users are those who do professional work in gardening, landscaping, or grounds maintenance or another role in an amenity setting, such as:

  • schools
  • parks
  • sports grounds, including golf courses
  • public or private property
  • infrastructure, such as roads, railways and waterways
  • utilities, such as transport and water companies

Forestry users are those who work in forests or woodlands, such as:

  • tree management
  • tree planting
  • use of forests or woodland

Note: It is not necessary for amateur users of PPPs, such as homeowners using products in their own garden, to register.

Which business address should I register with?
Defra requires businesses to register every address where they:

  • store Professional Plant Protection Products*
  • keep records of Professional Plant Protection Products*
  • apply Professional Plant Protection Products, providing these are applied on users' own business property (such as land they own or rent) only. Users are not required to disclose client addresses where they apply PPP on behalf of clients.

* It is necessary for users to enter all addresses that apply. For example, if users store PPPs and any adjuvants at 2 addresses and keep records at a separate office, they must provide the details of all 3. It does not matter that some addresses will be registered twice by both a landowner and their tenant, for example.

Users must register at least one permanent business address. Users do not need to register temporary addresses; for example, users will only use addresses for up to 2 years.

Submitting total use of PPP to Defra
A question on the registration form asks users to advise Defra of the amount of PPP used, stored, or applied in a typical year. In relation to this question, Defra advises users to enter an amount they use, store, or apply in a typical year and that an estimate is acceptable.

Defra also advises users who use PPPs during some years but not others to provide the typical amount they would use during a year that they do.

When do I need to register?
Users of PPPs must register within 3 months of starting a business. If users have not yet registered and their organization or business has been using PPPs for more than 3 months, they should register as soon as possible.

For more information:
British Association of Landscape Industries
www.bali.org.uk

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