Notification of sales and exports of plant protection products

Notifications according to § 64 of the Plant Protection Act

Article 64 of the Plant Protection Act requires that manufacturers and distributors of plant protection products report to the BVL by the 31st of March each year the amount of plant protection products, and the active substances they contain, which were sold in Germany in the previous year or were exported from Germany.

Parallel imports must also be reported in the context of domestic sales.

The person liable to reporting domestic sales is the one who placed the product on the market for the first time. In most cases this will be the authorisation holder. For imports of plant protection products into Germany - this applies particularly to parallel imports - the person liable to reporting sales is the one who puts the goods into free circulation.

As of February 2012, the amounts of plant protection products placed on the market in the context of authorisations for emergency situations (according to Article 53 of Regulation (EC) No 1107/2009 in conjunction with § 29 PflSchG) must also be reported. If a regular authorisation has already been granted for the plant protection product it is sufficient to report the entire amount of the product placed on the market; the quota placed on the market in the context of emergency authorisations does not have to be stated separately.

If a plant protection product is sold for both professional and non-professional use, these amounts have to be reported separately.

According to the reporting obligation set out in Article 64 of the German Plant Protection Act ('PflSchG'), the quantities of treated seed do not have to be reported - neither in the case of domestic sales nor in the case of export sales. However, domestic sales/export of the seed treatment product must be reported by the company having been the first to place the product on the market, which is usually the authorisation holder. Contract coating companies or exporters of seed should therefore coordinate their reports with the authorization holders of the seed treatment products.

Exports of formulated plant protection products must be reported, regardless of whether they are authorised in Germany or not. Exports of technical active substances do not have to be reported.

Further useful information and forms for domestic sales and export notifications are provided by the BVL in electronic form.

The BVL publishes a summary of the notification results in an annual report.

Notifications according to EU Regulation No 649/2012

According to Article 10 of Regulation (EU) No 649/2012, trading with non-EU countries (third countries) in imports and exports of certain chemicals, including plant protection products and their active substances, must be reported. The respective chemicals are listed in Annex I of the named Regulation. The competent authority for these notifications is not the BVL but the Federal Institute for Occupational Safety and Health (BAuA), Federal Office for Chemicals / Authorisation of Biocides.