Colony Record Book: EU Regulation 2019/6 Step by Step

Since 28 January 2022, EU Regulation 2019/6 on veterinary medicinal products has been directly applicable law in all EU member states. For beekeepers this means: everyone who keeps bees -- whether a hobby beekeeper with one colony or a professional with 500 -- must keep a colony record book documenting all medicinal product applications.

This obligation is no paper tiger. The veterinary office can carry out inspections at any time, and violations can result in significant fines. In this lesson we explain step by step what belongs in the colony record book, how to keep it correctly, and which mistakes you absolutely must avoid.

Why a Colony Record Book? The Background

EU Regulation 2019/6

Regulation (EU) 2019/6 of the European Parliament and of the Council of 11 December 2018 on veterinary medicinal products (in short: EU Veterinary Medicinal Products Regulation) replaced the previous Directive 2001/82/EC. It pursues several goals:

• Combat antibiotic resistance: Through complete documentation of medicinal product applications, resistance can be detected and prevented early
• Food safety: Honey is a food product. Traceability of all medicinal products protects the consumer
• Uniform standards: EU-wide harmonisation of documentation obligations
• Improve animal health: Better data foundation for control strategies

Article 108 of EU 2019/6

The central article for beekeepers is Article 108 of EU 2019/6. It obliges animal keepers to keep records of all veterinary medicinal products they administer to their animals. The exact requirements arise from Article 108 (paragraph 3: record-keeping obligations, paragraph 6: retention period):

"Keepers of food-producing animals shall keep records of the veterinary medicinal products used and retain these records for at least five years."

Since honey is a food product, bees are considered food-producing animals -- even if you only use your honey privately and do not sell it.

National Implementation in Germany

In Germany, the EU Regulation is supplemented by the Veterinary Pharmacy Ordinance (TAEHAV) and the Veterinary Medicinal Products Implementation Ordinance. Sections 50-55 of the Veterinary Medicinal Products Act (TAMG) regulate documentation obligations in national law.

What Must Go in the Colony Record Book?

The mandatory fields of the colony record book arise directly from Article 108 EU 2019/6 in conjunction with the German TAMG. Each individual entry must contain the following information:

The 12 Mandatory Fields

Mandatory Fields Explained in Detail

Sample Entry: What a Correct Entry Looks Like

Further Example: Winter Treatment with Oxalic Acid

Digital vs. Paper: Both Forms Are Permitted

Requirements for Digital Record-Keeping

If you keep your colony record book digitally, the software must meet certain requirements:

• Data security: The data must be protected against unauthorised access and loss
• Immutability: Once recorded entries must not be able to be silently deleted or changed (change log)
• Printout: The data must be available as a printout at any time
• Readability: The data must remain readable throughout the entire retention period
• 5 years retention: Even after cancelling an app subscription, data must be exportable

Inspections by the Veterinary Office

How Do Inspections Work?

The veterinary authorities carry out random and event-driven inspections. In practice, inspections occur particularly frequently in connection with:

• AFB restricted zones: When American Foulbrood occurs in your area
• Random checks: Routine inspections, especially for beekeepers who sell honey
• Tip-offs: When someone reports a violation (e.g. neighbour, another beekeeper)
• Honey complaints: When residues are found in honey samples

What Is Checked During an Inspection?

1. Identity Check

   The inspector verifies who you are and whether your beekeeping is properly registered with the veterinary office.

2. Colony Record Book Check

   The colony record book is examined. The inspector checks: Are all mandatory fields completed? Are entries chronological? Are batch numbers given? Do withdrawal periods match?

3. Medicinal Product Stock

   Which medicinal products do you have in stock? Do they match the colony record book entries? Are they approved and not expired?

4. Colony Verification

   Does the number of colonies match the registration? Can the treated colonies be identified?

5. Honey and Food Safety

   For honey sellers: Are withdrawal periods being observed? Are there indications of unauthorised treatments during the nectar flow?

Consequences of Violations

Which Treatments Must Be Documented?

Subject to Documentation: All Medicinal Product Applications

Step-by-Step: Setting Up Your Colony Record Book

1. Choose Format

   Decide on paper or digital. Recommendation: Digital with an app like Hivekraft -- mandatory fields are pre-populated, batch numbers are saved, export available at any time.

2. Record Apiaries and Colonies

   Set up all your apiaries and colonies so you can clearly assign the treated colonies with each entry.

3. Record Medicinal Product Stock

   Document all medicinal products on hand with trade name, active ingredient, batch number, expiry date and supplier.

4. Create First Entry

   At the next treatment: immediately fill in all 12 mandatory fields. Photograph the packaging as backup.

5. Maintain Regularly

   Create each entry immediately after treatment. Do not postpone! For digital solutions: export as PDF at least once a year.

6. Ensure Archiving

   Retain old entries for 5 years. For paper books: secure storage location. For digital books: check backup.

Summary

The colony record book obligation under EU 2019/6 has been binding for all beekeepers since 28 January 2022. The key points:

1. Every beekeeper must keep a colony record book -- from the first colony, even if honey is not sold
2. 12 mandatory fields must be completely filled in per entry
3. The retention period is 5 years
4. Paper and digital are equally permissible
5. The veterinary office can carry out inspections at any time
6. Violations can result in fines up to 30,000 euros
7. Batch number and veterinarian are most commonly forgotten
8. Biotechnical measures (drone brood removal etc.) do not belong in the colony record book

The good news: with a digital solution like Hivekraft, keeping the colony record book is not a major effort. The mandatory fields are predefined, batch numbers are saved, and the export for the veterinary office is done with one click.