ENA the European Nurserystock Association welcomes and supports the approach taken in the proposed Implementing Regulation, allowing plant passports, in certain cases, to accompany consignments through commercial or transport documentation instead of being physically attached to the trade unit.
EU consultation
Exceptions and rules for the attachment of the plant passport to the trade unit
9 submissions from 9 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 10 submissions on this file. Shown here: the 9 from organizations. Not shown: 1 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. About this data →
Who showed up
7 submissions from industry (companies and their trade associations) against 1 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 7 industry submissions for every one from civil society.
Industry 7Civil society 1Public authorities, academia, other 1
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations: a body that filed twice is counted twice.
The file, right now
The consultation closed on 23 Sept 2026; it ran from 26 Aug 2026.
- Policy area
- Health & food (DG SANTE)
- Where it stands
- Awaiting adoption
- Adoption expected
- 30 Sept 2026
How it got here
- Draft implementing regulation23 Sept 2026
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Implementing regulation.
Showing 9 of 9 submissions.
IE
IDEE ECONOMICHE
· · filed 23 Sept 2026 · source
The proposed legislation will detail the cases and rules where plant passports are associated with trade units in a way that does not involve physical attachment. In other words, when plant passports do not need to be attached to the trade unit of particular plants, plant products or other objects due to their size, shape or other specific characteristics. Therefore, a QR card should be added next to the plant.
Filed in Italian · English published by the European Commission
DU
Defra (UK)
· · filed 22 Sept 2026 · source
Subject to maintaining robust traceability, this approach could be applied to all plants for planting, including material from multiple sites and sources, improving efficiency, sustainability, and business outcomes. For Beta vulgaris, if adopted clarification would be welcome on how the proposed arrangements would operate where the UK retains protected zone/PFA status, but some or all Member States do not.
VD
Verband Deutscher Hopfenpflanzer e.V.
· · filed 22 Sept 2026 · source
The Association of German Hop Planters (Verband Deutscher Hopfenpflanzer e.V.) welcomes the Commission’s initiative to introduce exemptions from the obligation to physically affix plant passports to the trade unit of certain plants. Hops are unfortunately not included in the draft regulation, but would greatly benefit from this simplification.
Filed in German · English published by the European Commission
CA
COPA and COGECA
· · filed 22 Sept 2026 · source
Copa and Cogeca thank you for the opportunity to respond to this public consultation. With regard to potatoes in certain Member States, the proposal does not appear to modify the export requirements to third countries, which remain subject to phytosanitary certification and the conditions established by the destination country.
Position of the Polish Nurserymen Association. The Polish nursery sector views the presented draft Implementing Regulation with disappointment. While we recognize the positive direction of the proposed changes, namely allowing plant passports to be linked to specific consignments through accompanying documents instead of physical labelling, the proposed solutions have been limited to a very narrow group of products…
The UK forestry sector wishes to have the option of using electronic plant passports for the movement of timber from the forest to the mill. We were told that under the current SPS agreement it was not possible as electronic plant passports are not valid in the EU. I have attached a short paper that describes the problem and possible solution.
LN
LTO Nederland
· · filed 7 Sept 2026 · source
The current Community regime for plant passports sets out the situations in which plant products must be physically accompanied by such passports. There are now (general) situations where products do not need to be foreseen. The latter is also the subject of the present draft legislation.
Filed in Dutch · English published by the European Commission
SP
Stowarzyszenie Polskich Szkółkarzy
· · filed 28 Aug 2026 · source
As a representative and director of the office of the Association of Polish Schoolmakers, whose members produce fruit nursery material, on behalf of our members I express our opinion on attaching passports directly to the nursery material. For purely practical reasons, we believe that passports should not be attached to a bundle but attached to documents such as the nursery accompanying document.
Filed in Polish · English published by the European Commission
Take the dataCSV: all 9 submissionsJSONFull text, not the excerpt. Free to cite.Search every submission →
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed”. You read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.