Additional declarations and exemptions for RNQP requirements for plants for planting for import into the EU

When do the additional declarations for RNQPs become mandatory?

This obligation applies to all PCs addressed to an EU Member State issued on or after 6 July 2026. If a PC is issued before 6 July 2026, but the consignment arrives in the EU after this date, the PC will be accepted without the RNQP additional declarations. Consignments accompanied by PCs issued on or after 6 July 2026 that lack the required additional declarations will be refused entry.

Relevant regulations

The RNQP requirements are listed in Annex IV and V of the Implementing Regulation (EU) 2019/2072, which was amended in Regulation (EU) 2025/2249 to include additional declarations for RNQPs. The exemptions to the RNQP requirements and their specific additional declarations were published at the end of May in Regulation (EU) 2026/1110.

General considerations

The measures to prevent the introduction of RNQP into the EU are set out in Annex V. Annex V contains parts for different categories of plant for planting. Some of these parts have sections 1 and 2 for measures (field inspection, sampling and testing), and section 3 for additional measures. The ‘general’ measures in Sections 1 and 2 must be met before introduction into the EU but no additional declarations are required. The additional measures in Section 3 must be met as well but different options are provided to comply with the RNQP requirements (e.g. 'grown in an area free from' or 'the consignment has been tested'). The selected measure should be specified in full wording on the additional declaration of the PC.

For some products requirements with and without additional declarations are to be used for a single RNQP. For example, Helianthus annuus seeds are subject to both general measures (field inspection, sampling and testing; no additional declaration) and additional measures (with a mandatory additional declaration) for Plasmopara halstedii.

If a product is subject to requirements for multiple RNQPs, please ensure that all corresponding additional declarations are provided on the PC.

The additional declarations as implemented in the Netherlands are outlined in the 'Checklist of Additional Declarations for cut flowers, grains, seeds, and potatoes' and the 'Checklist of Additional Declarations for plants for planting'.

Exemptions

Certain conditions allow for the import of products that do not yet comply with the applicable RNQP requirements. These conditions are described in Article 6 of Regulation (EU) 2019/2072. Following the publication of Regulation (EU) 2026/1110, this article has been amended: Article 6 details the exemptions for plants for planting including seeds imported for certain purposes, while article 6a covers exemptions for ‘seed as grown’ and 'seed not finally certified'.

Exemptions for plants for planting including seeds

Plants for planting including seeds, imported for specific purposes — such as scientific research, official testing, inspections, re-export, processing, or packaging — remain exempted from the RNQP requirements at the moment of introduction into the EU. The full list of these exemptions is detailed in the letters a to f of Article 6(3) of Regulation (EU) 2019/2072, as amended by Regulation (EU) 2026/1110. For products covered by one of these exemptions, the following additional declaration must be included on the PC:

'Subject to the exemption laid down in Article 6(3) of Commission Implementing Regulation (EU) 2019/2072, point [insert the letter of the selected exception, a to f]'.

Exemptions for seeds

In addition to the exemptions outlined above, specific exemptions apply to 'seed not finally certified' and to 'seed as grown'. These seeds require treatment, conditioning, or testing in the EU before marketing within the EU.

Please note: These exemptions apply to certain RNQPs only. The RNQPs covered by this exemption are specified in Article 6a(1) of Regulation (EU) 2019/2072 as amended by regulation (EU) 2026/1110. For any RNQPs not exempted under this article, the PC has to include the relevant additional declaration for that RNQP.

Seed not finally certified

Seeds that are not finally certified under the OECD or EU Seed Schemes are exempt from some of the RNQP requirements, as detailed in Article 6a of Regulation (EU) 2019/2072 amended by Regulation (EU) 2026/1110. Consignments need to bear an official label that indicates that the seeds are not finally certified and the following additional declaration should be included on the PC:

'Subject to the exemption laid down in Article 6a(1) of Commission Implementing Regulation (EU) 2019/2072, point a.'

This exemption mainly applies to seeds of field crops.

Seed as grown

Vegetable seeds imported as seeds grown — unprocessed seeds imported for processing and packaging before marketing — are exempt from RNQP requirements. In this case, the PC must include the following additional declaration:

'Subject to the exemption laid down in Article 6a(1) of Commission Implementing Regulation (EU) 2019/2072, point b.'

Virtually all consignments of vegetable seeds imported into the EU qualify for this exemption.

Certified seed are not exempted

EU/OECD finally certified seeds must comply with RNQP requirements at the time of import. The EU/OECD label from countries listed in Annex I to Council Decision 2003/17/EC guarantees that the product concerned meets the RNQP requirements. The country of (re-)export can use this EU/OECD certification label to issue the PC with the required additional declarations, even if these declarations are not stated on the PC of the country of production. For future consignments, please ensure that the additional declaration is provided on the original PC by the country of production.