Postponement of mandatory closed filling system imminent

In September 2023, then Minister of Agriculture Piet Adema announced that the long-awaited closed filling system would become mandatory for professional users of crop protection products as of 1 January 2025. The necessary adjustment of the Environmental Activities Decree (BAL), to anchor this in legislation, had to be put in order this year. At the beginning of November, under the auspices of Minister Wiersma, nothing has happened yet.

Transition period
"As a sector, we have always assumed – and have also insisted on this – that farmers and contractors will be given a one-year transition period for the implementation of the closed filling system (CTS ed.)", says Jo Ottenheim of the industry organisation Crop-Life NL. "The ministry was somewhat vague about this at the time. What we do know is that no adjustments have been made to the Decree to date. It is not feasible to achieve this this year. For example, there are fixed change moments to do this, internet consultation is mandatory and it must be submitted to Brussels."

Whether the deadline will be postponed by a year, Ottenheim does not dare to say at this time. "It is possible that postponing the legislation will have consequences for the transition period. That is why we at Crop-Life say: As a sector, we will put our shoulders to the wheel in 2025 to make this happen." Answers from the ministry are still pending, but Ottenheim expects to be able to provide more clarity on this in the short term.

Holding back
In practice, many companies have been reluctant to invest in a closed filling system. Partly because of hesitant legislation and partly because of practice. Not all packaging manufacturers were ready for it. Also, multiple systems are available and it takes research to find out what best suits your situation and machines. For example, do you opt for an integrated system on the field sprayer, which is still only offered very sparingly by manufacturers, or a stand-alone system.

The latter has the advantage that it can also be applied to other machines that use crop protection products. Think of a row or hood sprayer or even a simple spray system on your sowing or planting machine. In theory, all these machines should be equipped with a filling system.

Packaging
According to Ottenheim, four different filling systems are now available in practice and a fifth is in development. "It is clear that the EasyConnect cap is used as the European standard," he explains. "Resource manufacturers are still working on making their packaging suitable. The ISO standard requires that all cans from 1 to 20 litres are provided with a cap. That is why many manufacturers are returning to 15-litre packaging size, in order to avoid a strange dividing line. For backpack sprayers and in greenhouse horticulture, an exception applies to the CTS."

Ottenheim and his industry colleagues hope that postponement will not lead to cancellation. "First and foremost, it's about your own health," he says. "And then there's the environment. All multinationals in the crop protection world support it. Together, the parties have agreed that every European farmer must have a CTS by 2030. In the Netherlands, we're ahead of the game, but that's not a bad thing at all."

On 23 September, the European Council for Agriculture and Fisheries met. Several member states requested a postponement of the mandatory digital registration of crop protection products, which was also due to come into effect next year. This was announced this week by Minister of Agriculture Femke Wiersma. She also requested a postponement of the measure, despite the fact that in practice this is not a major stumbling block for Dutch farmers. The closed filling system was not discussed during this meeting because this is a subject for the Ministry of Infrastructure and Water Management.

Three years of data storage
Most Dutch companies already have a digital register for their substance use. This is confirmed by figures from the NVWA. This is not yet legally required, but if it is up to Europe, this will change. The digital register must store which substance has been used, the dosage, location and time. This data must be stored for at least three years. It is up to the European Commission whether the two-year postponement will also come.

This decision may have consequences for other ongoing projects. Think of the digital label for crop protection products. In the Netherlands, a project started this year. At the moment, it is nothing more than a digital version of the label, which you can read with the Agro E-label app, but it is not inconceivable that the label will also be used for registration.