Fertiliser closing stock: the count that keeps you legal

Every farmer registered to buy fertiliser must tell the Department of Agriculture what is left in the shed at 23.59 on 14 September. The declaration opens on 15 September and closes on 15 October. A nil return is still a return, and missing it is an offence rather than an oversight.

That is the whole job. It takes a few minutes on MyAgFood.ie once you know your figures. The catch is that the figures come from a date that has already gone by the time the form opens.

Does this apply to you?

If you buy fertiliser, yes. You have to be on the Professional Fertiliser End Users' Register to buy it at all. Section 7B(10) of the Fertilisers Feeding Stuffs and Mineral Mixtures Act 1955 requires you to hand your registration number to whoever you buy from.

So if you have bought a bag in the last year, you are on the register. And if you are on the register, the closing stock declaration is yours to file.

What counts as closing stock?

Closing stock is any fertiliser on hand at 23.59 on 14 September. Not the week after. Not the day you get around to filing.

The law is a bit wider than "in the shed". The wording comes from section 7D(6) of the same Act. It covers fertiliser "on his or her premises or under his or her control, whether for his or her own use or not".

A pallet sitting in a rented yard counts. So does fertiliser you are holding for somebody else.

That is why the count has to happen on the night. Walk the shed on 14 September, write down what is there, and the form fills itself later.

What you actually have to write down

DAFM asks for the type of fertiliser and the quantity of each you are holding. Section 7D(7) sets out the detail:

• your professional fertiliser end user registration number
• the name of the fertiliser product
• the manufacturer of the product
• the quantity on your premises or under your control

One more line only appears on request. That is the quantity which is third-party product, or the amount you used over a stated period. It is not part of the standard return, but have the figure to hand.

If you are holding nothing, you still file. The Department is blunt about it: "Farms and premises that have no stocks of fertiliser on hand, must still make a nil declaration."

What about fertiliser a contractor brought in?

If a contractor supplied the fertiliser, that transaction should sit against your herd number rather than theirs. Contractors can move it over themselves using the Farm to Farm Transfer facility on MyAgFood.ie.

Worth checking before you file. If a load never landed on your record, your purchase history and your stock figure will not tell the same story.

Who is responsible if the figures look wrong?

This is the part that catches people, and it is worth being clear about.

Your merchant records the sales. DAFM calls merchants Fertiliser Economic Operators. It is the FEO's job, the Department says, "to ensure the accuracy of data on the National Fertiliser Database (NFD) in respect of their customers". If a purchase looks wrong, raise it with the merchant first. Not with the Department.

The closing stock declaration is the other way round. That one is yours. Nobody files it for you except an agent acting on your behalf.

Merchants do have their own version of the same job, on a different date. Their stock is counted at 23.59 on 30 September. So if you hear 30 September mentioned at the co-op counter, that is their date, not yours. Yours is 14 September.

What happens if you don't file?

Failing to submit is an offence. Section 7D(9) covers it. A registered end user who fails to comply is liable on summary conviction to a class A fine. The same applies if you submit information knowing it to be false or misleading.

The Fines Act 2010 puts a class A fine at a maximum of €5,000.

You may have seen €100,000 quoted around the fertiliser database. That figure is real. It belongs to a different offence — operating as a professional fertiliser end user without being registered at all. A late stock return is not that.

Either way, "legal requirement" in a DAFM press release is not a turn of phrase. And the return takes less time than reading this piece.

Why is the Department collecting this at all?

The database records fertiliser sales along the supply chain and supports water quality targets. It also meets commitments Ireland gave the European Commission under the fifth Nitrates Action Programme.

DAFM expects it to simplify farmers' fertiliser reporting under other schemes in time. That is the only part of this that might eventually save you work rather than make it.

If you are cutting nitrogen use anyway, the nitrates derogation changes are the bigger picture. Planning fertiliser before the spreader moves is where the money actually is. The slurry and fertiliser spreading deadlines are a separate set of dates. Easy to mix up with this one, and nothing to do with it.

Frequently asked questions

Do I have to declare if I have no fertiliser left? Yes. DAFM requires a nil declaration from farms and premises with no stock on hand. It is the same form, and the answer is zero. Skipping it is treated as failing to submit, not as having nothing to say.

Can my agent file the closing stock declaration for me? Yes. DAFM says the declaration can be made by farmers or their agents through MyAgFood.ie. If your adviser already handles your BISS or nitrates paperwork, ask whether they are doing this one too. Do not assume either way.

What if my fertiliser purchases on MyAgFood.ie look wrong? Check the record before you file, then go to your merchant. Fertiliser Economic Operators are responsible for the accuracy of sales data recorded against their customers. A wrong or missing purchase is theirs to correct in the first instance.

Where to get help

The step-by-step guides sit on the Department's National Fertiliser Database page. If you are unsure how the declaration interacts with your nitrates or scheme paperwork, your Teagasc adviser is the person to ask. For anything about a specific purchase on your record, your merchant is the first call, not DAFM.

The bottom line

Walk the shed on the evening of 14 September and write down what is in it. File on MyAgFood.ie any time between 15 September and 15 October. Even if the answer is nothing.