Combines began to roll last week and this officially started the 2023 harvest for tillage farmers.

And with a new CAP, new nitrates and other legislative changes set to be introduced, decisions taken now can have significant implications for the year ahead.

This means that it is important to know what is coming down the track to ensure compliance in 2023.

However, these details are not yet fully known and so I only point you in a direction rather than tell you exactly what you need to do, or do differently, for 2023.

New requirements

There are many new areas that must be addressed, or considered, which relate to the new nitrates regulations and the new CAP, neither of which are fully finalised.

The new sustainable use directive, which is likely to be abbreviated to “SUR” rather than “SUD”, must also be watched in terms of actions taken in the near future.

Nitrates obligations

Most tillage farmers are now aware of the basic requirement to shallow cultivate all stubbles immediately post-harvest.

The measure is supposed to speed up the establishment of vegetative cover on stubbles to help increase nutrient uptake (specifically nitrate) to reduce its potential loss through leaching.

The new Nitrates Action Programme (NAP) will also cause changes to slurry application dates and systems and to buffer zones on land growing late-harvested crops.

We await the finalisation of rules that will pertain to stubble cultivation, as the total removal of overwintered stubble would effectively remove essential habitats for some endangered bird species.


As things stand, all combinable crop land must be shallow-cultivated within seven days of harvest where straw is chopped or within seven days after straw is baled.

However, shallow cultivation of all stubbles is to be completed within 14 days of harvesting.

The ability to do this will be completely dictated by weather at the time.

Also, farmers who do not have suitable equipment to do this may have difficulty in getting a cultivator due to the general supply pressures in the market.

Getting straw baled is one thing, but getting it off fields is another. Many fear that having to clear fields quickly will weaken the hand of the seller.

It is also a concern that this obligatory practice will fly in the face of the new pesticide reduction obligations as the vast majority of such stubbles will need to be sprayed with glyphosate prior to establishing the following crop. This is due to the large volume of vegetation that is likely to be present.

It also flies in the face of the new SUR, which will oblige all farmers to do all they can to minimise the need for pesticide application ahead of having to use it.

Stubble cultivation is questionable ahead of planting a winter crop

A normal, stale seedbed would mean multiple cultivations to get seeds germinated and this would minimise the amount of vegetation ahead of crop establishment.

Stubble cultivation is questionable ahead of planting a winter crop. A new plant will take two weeks to establish and it will be another two weeks by the time they begin to take up nutrients from the ground.

In many species, the first two leaves are fuelled by the energy reserves held in the seed.

In the case of a crop harvested in mid-August and planted again in early October, that is at most two weeks of nutrient uptake by tiny plants and hardly enough net benefit to pay for the cost of the diesel and metal involved. It may have other benefits, however, such as slug control and getting weed seeds to germinate.


In the case of land ploughed between 1 July and 30 November, all efforts must be made to establish a green cover within 14 days of ploughing. This will affect many growers who plough a considerable area post-harvest ahead of autumn planting.

There are now increased limitations on ploughing ahead of winter planting. \ Donal O' Leary

Where a winter crop is not to be planted, the aim should be to establish a green cover, either through natural regeneration or by sowing a cover crop.


New rules also apply around slurry spreading. From 1 January 2023, all pig slurry must be applied using low-emissions slurry spreading equipment. Other slurry can be applied with a splash plate but it must be incorporated within 24 hours of application.

Also, slurry cannot be spread after 8 October in 2022 and after 1 October in 2023. These windows could prove to be very limiting for many tillage farmers. However, there is to be a recognition of certain circumstances where slurry application may be allowed up to 15 October.

The increasing need to delay autumn sowing dates to minimise disease pressure would mean that these date limits will not match up.

We must remember that slurry is a valuable source of manure to build soil P and K and organic matter levels while helping to decrease nitrogen use.

Chemical fertiliser

The closed period for chemical fertiliser application will be extended by 14 days in zones A, B and C.

Also, a fertiliser register will come into effect in 2023, which is to document all fertiliser purchases. It aims to reconcile imported tonnages with sales plus stocks. This will also affect organic fertilisers and a slurry movement register is already in place.

Buffer zones

While buffer zones already exist in tillage, the new programme states that a 6m buffer zone will be needed along critical source areas. These are the specific areas along a watercourse where overland flow is likely to enter waterways.

The 6m buffer applies to late-harvested crops and these critical source areas have yet to be identified. Such crops include potatoes, maize and even late-harvested spring cereals.

While maincrop potatoes and maize may well be harvested from mid-October, potato growers are asking if planting British Queens along by a watercourse (say, 24-30m wide) would negate this requirement in a potato field. This crop would be harvested in July and the ‘stubble’ could sit there after that.

Workload and safety

These new measures will add more pressures and cost on tillage farmers. Diesel for cultivation, plus the need to provide for the 6m buffer on rented land, add cost and inconvenience. It would be helpful to know if these measures will bring a real benefit or just additional cost and inconvenience to farmers.

Harvest is the most pressurised time of the year, particularly when weather is not on your side. These measures will do nothing to help farmers’ mental health, wellbeing or safety at a time when they are extremely busy, working long hours and trying to organise all that goes with harvest and now stubble cultivation.

CAP changes

There are many operational changes proposed for the new CAP, which is still not fully agreed with planting set to begin in less than six weeks.

Changes include the reapportioning of existing entitlement values to establish a new basis for payment known as BISS, have a minimum of 7% (or 10%) non-productive land, the introduction of a higher payment for the first 30 entitlements known as front-loading, the continuing of convergence, the capping of a maximum BISS payment value and the introduction of new eco schemes, which will be funded from 25% of current BPS entitlement values.

To earn eco-scheme payment, a farmer must take on two measures each year or one specific measure to a higher degree

Most of these are outside of the control of the individual grower and involve automatic apportioning of existing entitlement values.

However, if farmers want to recover most of the 25% deduction to fund eco schemes, then they must participate in one or two eco schemes.

Most of these better suit livestock farmers but will some suit a tillage farmer in individual years.

To earn eco-scheme payment, a farmer must take on two measures each year or one specific measure to a higher degree. The options that seem to best suit tillage farmers are:

  • Rotation at 20%.
  • Soil testing the whole farm.
  • Planting hedgerows or supplementing them with native trees.
  • The use of GPS precision-farming technology on sprayers or spreaders.
  • Non-productive land.
  • Rotation

    Tillage farmers can use the break crop measure to access an eco scheme. The crops to be allowed in the 20% are not yet fully agreed.

    The suggested break crops include peas, beans, oilseed rape and oats, but there are questions around temporary grass, potatoes, maize, beet and vegetables.

    The option better suits larger-scale farmers to hit the 20% target with area flexibility, but smaller growers may struggle with this.

    Soil testing

    This is a whole-farm option for one or possibly two years of the five. More clarity is needed around when samples should be taken.

    Hedgerows or native trees

    Some farmers may choose to avail of this measure as a way of adding trees to existing field boundaries. The measure might work for one or two of the five years.

    GPS equipment

    The use of GPS-controlled equipment is another route to eco schemes. Questions remain as to whether this measure would apply for each of all five years or just one. There are also questions around TAMS grant-aiding and the level of technology required.

    Non-productive land

    While this is not something normally associated with tillage farming, all tillage farmers had to have at least 5% for to have environmental focus area (EFA) in the last CAP.

    Many had more than 7% at the time and this level is set as an option for one of the two obligatory eco-scheme measures. If a farm has at least 10% non-productive area, this can be used as a double eco-scheme measure.

  • As harvest begins, there are many new requirements that tillage farmers must be aware of for 2023.
  • An obligation to cultivate all stubbles to help minimise nutrient loss begins post harvest.
  • Planning for next year’s crops must consider the eco-scheme options that will be used and not just for 2023.