REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL to present the experience gained from the extension of the plant passport system to all movement of plants for planting within the Union territory
Date: 2021-12-10
Institutions: Directorate-General for Health and Food Safety, European Commission
Subjects: import restriction, pest, plant disease, plant health control, protection of plant life, surveillance concerning imports, traceability, transport document

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 10.12.2021  COM(2021) 787 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL to present the experience gained from the extension of the plant passport system to all movement of plants for planting within the Union territory  
 
 
Contents 

1 

INTRODUCTION ............................................................................................................ 3 

2  EXTENSION OF THE PLANT PASSPORT SYSTEM TO ALL PLANTS FOR 
PLANTING .............................................................................................................................. 5 

3  OTHER PLANT PASSPORT SYSTEM ELEMENTS COVERED BY THE 
QUESTIONNAIRE.................................................................................................................. 6 

3.1  Harmonised format of plant passport .......................................................................... 6 

3.2  Attachment of a plant passport to the trade unit.......................................................... 6 

3.3  Requirements on authorised operators that issue plant passports ............................... 7 

3.4  Arrangements for distance sales – issuance of a plant passport for a final user ......... 8 

3.5 

Electronic plant passports............................................................................................ 9 

3.6  Regulated non quarantine pests (RNQPs) ................................................................... 9 

3.7  General awareness of plant passports........................................................................ 10 

4  CONCLUSIONS ............................................................................................................. 10 

1 

 
 
 
 
 
 
ABBREVIATIONS 

CA: Competent Authority 

DG SANTE: Directorate General for Health and Food Safety 

EU: European Union 

NPPO: National Plant Protection Organisation 

RNQP: Regulated Non-Quarantine Pest 

QP: Union Quarantine Pest 

2 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1 

INTRODUCTION 

For the past almost twenty years, until 2019, the EU plant health legislative framework was 
governed  by  Council  Directive  2000/29/EC1.  The  Directive  contained  the  concept  of  plant 
passports as an agreed mark developed with the aim to balance the free trade of plant material 
across the EU and the protection of the Union territory against the spread of regulated plant 
pests occurring in the EU. The plant passport started being used to accompany plant material 
moved  between  Member  States,  replacing  the  phytosanitary  certificate,  which  is  the 
international  document  foreseen  under  the  International  Plant  Protection  Convention.  Plant 
passports were also to be used for movements of plants inside a Member State to attest the 
compliance  of  those  plants  with  the  respective  plant  health  requirements  of  the  EU 
legislation.  Also,  official  controls  on  plant  passports  were  now  to  be  made  where  the  plant 
material  was  produced  (operator  premises)  instead  of  at  the  border  or  at  destination,  and  a 
registration  obligation  was  established  for  operators  handling  regulated  plants  and  plant 
materials, and issuing plant passports.  

Under Council Directive 2000/29/EC, and until 2019, a plant passport was required only for 
specified species of plants and seeds and certain types of plant material, linked to specifically 
identified  phytosanitary  risks.  With  the  preparation  of  the  new  Plant  Health  Regulation 
(Regulation (EU) 2016/20312) it was however considered that the plant passport system was 
not functioning to its full potential and it was agreed that the requirement that a plant shall be 
accompanied  by  a  plant  passport  would  be  extended  to  a  larger  range  of  seeds  and,  in 
particular, to all plants for planting3. The extension of the plant passport system to all plants 
for planting has been complemented with some other provisions aimed at strengthening the 
plant passport system, at making it more robust and reliable and at improving its recognition 
namely with professional operators. The main changes introduced were the introduction of a 
harmonised format of a plant passport; an obligation for operators to attach a plant passport to 
the  trade  unit  of  the  plants  or  plant  material,  or  to  their  package,  bundle  or  container;  and 
obligations  for  operators  to  ensure  traceability  of  plants  or  plant  material  and  to  carry  out 
examinations for plant passport. 

Under Article 79(6) of Regulation (EU) 2016/2031, the Commission is required to submit to 
the  European  Parliament  and  the  Council  a  report  on  the  experience  gained  from  the 
extension  of  the  plant  passport  system  to  all  movement  of  plants  for  planting  within  the 
Union  territory  including  a  clear  cost-benefit  analysis  for  the  operators,  accompanied,  if 
appropriate by a legislative proposal. This report addresses these requirements. 

1OJ L 169, 10.07.2000, p. 1. 
2 OJ L 317, 23.11.2016, p.4  
3 This covers all species of plants and all types  – e.g. pot plants, trees and shrubs, seedlings, grafts, rootstock, 

etc. – in which plants are traded and that allow their further planting and growth. 

3 

 
 
 
 
 
 
 
                                                
Methodology  

In  order  to  answer  these  requirements,  the  Commission  has  looked  into  all  the  available 
evidence. Due to the fact that the legislative change only started applying in December 2019 
and that the analysis was undertaken in February 2021, publically available data could not be 
used. Moreover, there are no reporting obligations for the Member States for the aspects that 
would  need  to  be  evaluated,  neither  any  results  yet  of  audits  of  the  implementation  of  the 
plant passport system in the Member States. Therefore, the only approach available to obtain 
evidence  to  respond  to  the  reporting  requirements  was  to  directly  ask  involved  economic 
operators and administrative bodies in the management and implementation of intra-EU trade 
on plants as they are the ones experiencing the legislative changes. For this the Commission 
drafted  a  questionnaire  with  70  questions  that  was  validated  by  Member  States  and  EU 
associations.  The  questions  aimed  at  getting  results  on  the  experience  gained  from  the 
extension of the plant passport to all movements of plants for planting, as well as on costs, 
benefits and impacts, to carry out the cost-benefit analysis. The questionnaire4 was sent to 27 
Member  States  NPPOs  and  Certification  CAs  and  to  48  relevant  EU-level  associations. 
Member-State-level  associations,  operators,  and  the  general  public  could  access  the 
questionnaire  via  DG  SANTE  website.  In  the  latter  case,  the  Commission  and  EU  NPPOs 
helped advertise the questionnaires via social media and other channels. A total of 177 replies 
from 25 Member States were received. The level of participation varied amongst the different 
categories  of  stakeholders  as  follows:  24  NPPOs 5,  9  Certification  CAs  from  7  Member 
States6,  43  operators  from  10  Member  States7,  44  national  associations  from  13  Member 
States8, 50 replies from citizens from 5 Member States9 and 7 EU-level associations.  

To support this report, the Commission produced a technical report10 with information about 
the feedback received and an extensive analysis of that feedback that is publically available.  

The  Commission  analysis  is  hampered  by  three  factors:    first,  the  contribution  from 
Certification  CAs,  operators,  associations  and  citizens  was  very  limited  and  as  such,  the 
analysis  cannot  be  conclusive  for  these  stakeholder  groups;  second,  the  very  short  time 
between the entry into application of the different provisions and the feedback request; and 
last,  the  impact  of  COVID-19  pandemic  on  trade  and  activities  related  to  the  scope  of  this 
report. 

Because  of  the  abovementioned  limitations,  conclusions  on  the  experience  gained  from  the 
extension  of  the  plant  passport  system  to  all  movement  of  plants  for  planting  within  the 
Union  territory  could  not  be  drawn  in  certain  cases.  The  assessment  of  costs  and  benefits 
linked to the extension of the plant passport system to all movement of plants for planting for 
operators  was  carried  out  to  the  extent  possible  because  of  the  scattered  feedback  on  the 
quantitative  data  requested,  and  their  unavailability  from  other  sources.  An  in-depth 
qualitative  analysis  of  the  costs  and  benefits  was  undertaken  instead.  Finally,  for  these 

4 https://ec.europa.eu/eusurvey/runner/PH-art-79-PP-portal 
5 AT, BG, CY, CZ, DE, DK, EE, ES, FI, FR, GR, HU, IE, IT, LV, LT, LU, MT, NL, PL, PT, SI, SK, SE 
6 DE, FI, FR, NL, PL, SI, SE 
7 AT, CZ, DE, ES, FR, IT, NL, PT, SK, SE 
8 AT, BE, CZ, DE, DK, ES, FI, FR, IT, LT, NL, PL, SE 
9 BE, DE, FR, NL, PL 
10 https://publications.jrc.ec.europa.eu/repository/handle/JRC126789   

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reasons,  the  Commission  has  restricted  itself  to  identifying  topics  that  merit  further 
discussions. 

2  EXTENSION  OF  THE  PLANT  PASSPORT  SYSTEM  TO  ALL  PLANTS  FOR 

PLANTING 

Article 79 of Regulation (EU) 2016/2031 introduced the obligation for all plants for planting, 
other than seeds, to be accompanied by a plant passport for their movement within the Union 
territory.  

The extension of the plant passport system aimed at increasing the effectiveness of protection 
against  Union  quarantine  pests  (QPs),  improving  the  preparedness  for  the  identification  of 
new plant pests of EU concern, and having a uniform application of the policy and a better 
understanding  and  awareness  of  relevant  stakeholders.  This  extension  was  perceived  as 
positive  for  the  increase  of  traceability  of  the  plants  by  half  of  the  respondents  and  the 
effectiveness of protection against plant QPs was mostly seen as increased or the same by the 
majority of the stakeholders. The preparedness for the identification of new plant pests of EU 
concern  was  either  rated  as  improved  or  the  same  and  the  understanding  and  awareness  of 
relevant  stakeholders  was  also  either  rated  as  improved  or  the  same  by  most  of  the 
respondents. 

On  the  other  hand,  the  extension  of  the  plant  passport  system  (the  transition  to  and  the 
implementation  of  this  new  rule  and  the  overall  complexity  of  the  process  of  issuing  or 
replacing  a  plant  passport)  has  been  seen  by  about  two  thirds  of  the  stakeholders  as 
burdensome  and  difficult  and  only  about  a  quarter  considered  the  change  manageable  or 
experienced no changes. Such perception of the changes  may be related, apart from  certain 
specific aspects that are addressed in the following sections of this report, to a short period of 
time between the start of the application of the new rules and the evaluation exercise for this 
report (December 2019 – February 2021). 

With the aim to identify the groups of plants that triggered the most technical difficulties, the 
stakeholders  were  asked  to  list  up  to  three  plants  or  groups  of  plants  for  which  they  had 
experienced  the  most  technical  difficulties  due  to  the  extension  of  the  plant  passport  to  all 
plants for planting. The top three groups were ornamental plants for planting, seeds and fruit 
plants for planting. In reply to the opposite question, i.e. which were the top three groups with 
the  greater  technical  ease,  the  stakeholders  listed  the  same  three  groups,  but  with  a  lower 
number of replies. 

There have been changes in the staff and the workload for operators and NPPOs due to the 
extension of the plant passport to all plants for planting. The impact on the workload of the 
NPPOs had been bigger than the changes in the staff. This might be explained by the fact that 
some  institutions  have  reached  their  maximum  staff  ceiling,  with  no  possibility  to  increase 
the staff number in  spite of increased workload.  The  change had no uniform impact  on the 
staff  for  the  operators,  as  more  than  half  declared  no  changes  or  no  opinion  while  others 
declared both, increases  or decreases. However,  it has increased the workload of more than 
half of the operators replying to the questionnaire.  

5 

 
 
 
3  OTHER  PLANT  PASSPORT  SYSTEM  ELEMENTS  COVERED  BY  THE 

QUESTIONNAIRE 

3.1  Harmonised format of plant passport 

Article 83 of the Regulation (EU) 2016/2031 has introduced a common format for the plant 
passport for all the Member States11 to ensure uniform conditions for the implementation of 
the  Regulation.  This  change  seems  to  be  accepted  by  the  stakeholders,  as  most  of  the 
stakeholders  that  replied  to  the  questionnaire  considered  the  transition  to  this  new 
requirement has been manageable or easy. Likewise, the implementation and the complexity 
of  this  change  have  been  rated  quite  positively,  as  there  were  more  positive  than  negative 
replies12 from the stakeholders that replied to the questionnaire. 

There  have  been  changes  in  the  staff  and  workload  for  operators  and  NPPOs  due  to  the 
harmonised  format  of  the  plant  passport.  The  change  had  a  similar  impact  on  the  staff  and 
workload for operators, but a bigger impact for the workload of the NPPOs.  

3.2  Attachment of a plant passport to the trade unit 

Article 88 of the Regulation (EU) 2016/2031 introduced the obligation of the plant passport 
to be attached by the professional operators to the trade unit of the plant, plant product and 
other objects before they are moved within the Union territory to increase the traceability of 
the plants, reduce the risk of movement of plant pests, and increase the recognition of the EU 
plant health system amongst stakeholders. The replies received from the stakeholders in the 
questionnaire indicate that  this has been one of the most difficult changes introduced by the 
Regulation , and is perhaps one of the reasons why most of the stakeholders considered the 
extension of the plant passport system to all plants for planting as burdensome and difficult 
(see section 2).  

The transition to this new requirement has been rated as burdensome or very burdensome by 
65%  of  the  stakeholders,  its  implementation  complicated  or  much  more  complicated 
(compared to the previous requirements) by 81% of the stakeholders and the complexity of 
the process to issue or replace the plant passport more difficult by half of the stakeholders. 

The  attachment  of  the  plant  passport  to  some  types  of  plants,  such  as  turf  in  rolls,  logs  of 
wood, consignments with multiple small lots, lots with multiple species or multiple species in 
a single pot has also proven difficult.  

While NPPOs considered that the attachment of the plant passport to the trade unit was useful 
and  that  it  had  contributed  to  an  increased  prevention 13,  the  operators  had  the  opposite 
opinion (not useful and it had not contributed to an increased prevention14). For these reasons, 
the  operators  had  suggested  to  allow  the  plant  passport  to  be  included  in  the  delivery 
documents, such as invoices and to introduce an electronic version of the plant passport.  

11 OJ L 331, 14.12.2017, p. 44–52  
12 The transition to, and the implementation and the complexity of the introduction of, the common format of a 
plant  passport was rated positively by 68%, 56% and 50%, respectively, of the stakeholders replying to the 
questionnaire compared with 28.9%, 39% and 43% respectively that rated these aspects negatively. 

13 17 and 14 NPPOs respectively, out of the total of 24 NPPOs responding to the questionnaire 
14 27 and 30 operators respectively, out of the total of 43 operators responding to the questionnaire 

6 

 
 
                                                
There  have  been  changes  in  the  staff  and  workload  for  operators  and  NPPOs  due  to  the 
attachment of the plant passport to the trade unit. This change has had bigger impact on the 
workload of the NPPOs than the operators.  

The requirement to attach the plant passport to the trade unit has implied additional costs and 
time for operators and the supply chain, in particular for some types of materials, or for the 
need  of  new  IT  systems  or  equipment,  in  addition  to  administrative  burden.  Also,  all 
stakeholders  replied  that  there  has  been  a  need  for  intensive  communication  to  inform 
operators due to the transition to the new plant passport rules. 

3.3  Requirements for authorised operators that issue plant passports 

To  ensure  uniformity  in  the  application  of  the  plant  passport  system  and  increase  the 
credibility  of  the  information  contained  in  the  plant  passport  itself,  Regulation  (EU) 
2016/2031  introduced  new  requirements  to  be  fulfilled  by  the  operators  issuing  plant 
passports, by setting the rules to  ensure the traceability of the plants,  the conditions  for the 
examinations,  the  conditions  for  the  authorisation  of  professional  operators  to  issue  plant 
passports  and  the  obligations  of  these  authorised  operators  (Articles  69,  87,  89  and  90 
respectively).  For  the  NPPOs,  there  have  been  also  detailed  rules  for  the  registration  of 
professional operators (Articles 65 and 66) and the authorisation of professional operators to 
issue plant passports (Article 89).  

Although the plant passport should generally be issued by authorised operators, this was the 
case for only 12 Member States out of the 24 that replied to the questionnaire. From the other 
12 that replied, in 6 the plant passports were mostly issued by the competent authorities, in 3 
by both and in the other 3 depending on the commodity.  

However, there was a quite general agreement (more than 70% of the respondents) that it is 
not necessary that the competent authority issues the plant passports for certain plants, plant 
products or other objects. Only in a minority of Member States, 7 out of 24, fees are charged 
by public authorities to operators to authorise them to issue plant passports. 

Some  Member  States  have  faced  some  delays  regarding  the  registration  of  the  professional 
operators established in Article 65. Up to the date when the questionnaire was replied to, in 
13  out  of  23  Member  States  whose  NPPOs  replied  to  the  question,  all  the  professional 
operators were already registered following the provisions of Article 65. The work was still 
ongoing  in  the  other  Member  States.  In  the  latter  group  of  Member  States,  the  delays  are 
because there are new operators that were not issuing plant passports before, the need to set a 
new IT system for registration or lack of information on distance sellers.  

Article  89  of  Regulation  (EU)  2016/2031  on  the  authorisation  of  professional  operators  to 
issue  plant  passports  has  been  supplemented  by  Commission  Delegated  Regulation  (EU) 
2019/827 15 .  Article  2  of  that  Regulation  introduces  the  obligation  for  the  competent 
authorities  to  ensure  that  professional  operators  have  access  to  a  technical  guidance  on  the 
criteria to be fulfilled in the examinations relating to the issuance of plant passports. Up to the 
date  when  the  questionnaire  was  replied  to,  the  half  of  the  NPPOs  replied  that  they  have 

15OJ L 137, 23.5.2019, p. 10–11  

7 

 
 
                                                
already provided that technical guidance, the other half replied that they have not yet done so. 
From  the  operators  who  replied,  there  was  a  higher  percentage  of  those  who  has  already 
received the technical guidance than of those who have not received yet such documentation. 
The  quality  of  the  guidance  provided  was  rated  insufficient  only  by  a  minority  of  the 
respondent operators, the other replies rating it mostly average or good. However, it is worth 
recalling  that  Regulation  2019/827  was  applicable  from  14  December  2020  and  the 
questionnaire was launched in February 2021. 

Another aspect that has improved due to the new requirements for authorised operators that 
issue plant passports is the possibility to identify pests since the operators are responsible for 
the examinations in order to issue the plant passport. Almost half of the operators who replied 
to the questionnaire declared that they use their own expertise to ensure the detection of QPs 
in their premises, while 44.2% of the operators replied that they outsourced it.  

There have been changes in the staff and workload for operators and NPPOs due to the new 
requirements  on  authorised  operators  that  issue  plant  passports,  increasing  the  workload  of 
both, operators and NPPOs.  

Sixteen  NPPOs  provided  data  of  the  total  number  of  registered  operators  and  authorised 
operators  subjected  to  the  plant  passport  for  the  years  2018,  2019  and  2020.  According  to 
data provided, since 2019 the total number of registered operators have increased by 17%. In 
addition,  the  total  number  of  professional  operators  authorised  to  issue  the  plant  passport 
have more than doubled between 2019 and 2020.  

3.4  Arrangements for distance sales – issuance of a plant passport for a final user 

Article  81  of  Regulation  (EU)  2016/2031  introduces  an  exception  for  the  obligation  of  the 
plants to be accompanied by a plant passport when they are supplied directly to a final user, 
but this exception cannot be applied when the plants are received by means of sales through 
distance contracts. Although this requirement was considered as appropriate by about half of 
the respondents, about 40% considered it unnecessary or burdensome. There was a significant 
difference between the different types of stakeholders that replied to the questionnaire: while 
more  than  half  of  the  NPPOs  considered  the  requirement  appropriate,  only  one  quarter  of 
operators shared this  opinion  and more than half considered it unnecessary  or burdensome. 
There  were  also  some  specific  sectors,  e.g.  in  plant  varieties  conservation  activities,  where 
operators considered the impact of the provisions as disproportionate to their capacities. 

The  opinion  of  the  stakeholders  consulted  about  the  enforcement  of  the  provisions  of  plant 
passport  to  final  users  receiving  plants,  plant  products  or  other  objects  by  means  of  sales 
through  distance  contracts  was  evenly  distributed  between  appropriate  and  inappropriate, 
although about 40% had not expressed any opinion on this issue. On the other hand, half of 
the NPPOs consulted considered insufficient the clarity of the provisions of plant passports to 
final  users  receiving  the  plants  by  means  of  sales  through  distance  contracts,  and  it  was 
pointed out that different Member States have different approaches. 

The  opinion  on  the  need  for  a  more  harmonised  approach  for  the  use  of  plant  passports  in 
relation  to  distance  contracts  to  final  users  was  evenly  distributed  between  necessary  and 
unnecessary, although about a quarter of the respondents had not expressed any opinion on 
this issue. 

8 

 
 
There have been  few  changes  in  the staff of  NPPOs and operators due to the exception for 
direct supply to final users by means of sales through distance contracts that required to be 
accompanied by a plant passport, but an increase in the workload of the NPPOs.  

3.5  Electronic plant passports 

According  to  Article  88  of  Regulation  (EU)  2016/2031,  the  plant  passport  has  to  be 
physically  attached  to  the  trade  unit;  however,  Article  83(8)  introduces  the  possibility,  by 
means  of  implementing  acts,  to  set  the  technical  arrangements  for  the  issuance  of  an 
electronic  plant  passport.  The  introduction  of  an  electronic  plant  passport  was  considered 
feasible and useful by more than half of the respondents to the questionnaire. However, the 
detailed  analysis  of  the  responses  revealed  that  there  were  differences  among  the  different 
groups of stakeholders. The electronic plant passport was considered not feasible only by 1 
out  of  24  NPPOs  compared  with  14  out  of  43  operators.  While  no  NPPO  considered  the 
electronic plant passport ‘not useful’, 12 out of 13 operators shared this opinion. Among the 
reasons  provided  by  the  operators  that  considered  the  electronic  plant  passport  not  feasible 
and not useful are new burdens and costs, mostly for small professionals. It was proposed that 
if an electronic plant passport is introduced, the paper version should be allowed to be used. 

3.6  Regulated non quarantine pests (RNQPs) 

Before the entry into force of Regulation (EU) 2016/2031, the plant passports guaranteed that 
the  traded  plant  material  was  free  from  quarantine  pests.  According  to  Article  85  of  this 
Regulation,  the  plant  passport  now  confirms,  in  addition  to  freedom  from  QPs,  that  the 
requirements for and measures against RNQPs have been complied with. 

A  clear  outcome  of  the  questionnaire  is  the  need  for  more  coherence  between  the  Plant 
Health Regulation and the legislation on the production and marketing of plant reproductive 
material,  because  in  the  case  of  fruit  propagating  material  and  fruit  plants  and  vine 
propagating  material  provisions  on  RNQP  occur  both  in  the  plant  health  and  plant 
reproductive material legislation, creating confusion about what legal requirements to follow. 
It  is  difficult  to  draw  any  conclusions  about  the  benefit  of  the  new  plant  passport 
requirements  in  relation  the  RNQPs  because  the  number  of  respondents  rating  the  rules  as 
either efficient or inefficient was evenly distributed, whereas about a third of the respondents 
rated the newly extended plant passport system as neither efficient nor inefficient. A possible 
reason  for  the  divergent  opinions  stems  from  the  approach  to  seed  certification,  which  is 
composed  of  a  multi-stage  process  comprising  official  controls  during  and  after  the 
certification  process.  Several  respondents  did  not  see  the  need  for  the  plant  passport  to 
contain information on compliance with RNQP requirements as official controls during and 
after seed certification already guarantee that the traded seed lots are free from RNQPs. 

The new rules on plant passports did not have an impact on the efficiency of official controls 
for  RNQPs  as  most  NPPOs  and  Certification  Competent  Authorities  were  already 
undertaking simultaneous official controls for RNQPs and QPs before the entry into force of 
the  Regulation  (EU)  2016/2031.  Only  two  NPPOs  and  one  Certification  CA  declared  that 
they started doing the controls for RNQPs and QPs simultaneously since the entry into force 
of the Plant Health Regulation. A clear benefit of the simultaneous controls for RNQPs  and 

9 

 
 
QPs is that they are mostly carried out by the same inspector (91%). The majority of official 
controls are done at the place of origin (82%). 

Regulation  (EU)  2016/2031  did  not  have  a  significant  impact  on  the  number  of  official 
controls for RNQPs (42% of competent authorities replied that the number of official controls 
related to the plant passports for RNQPs has remained the same whereas 33% of respondents 
declared an increase of less than 25%). The extension of the plant passport requirements did 
not  cause  an  increase  in  the  number  of  non-compliances  with  the  RNQP  requirements  and 
measures. In case of non-compliance, most competent authorities informed the Member State 
concerned and rejected the consignment. Some competent authorities informed that the action 
taken  depends  on  the  specific  case  and  others  did  not  yet  encounter  non-compliant 
consignments.  

3.7  General awareness of plant passports  

To  know  what  the  citizens’  knowledge  about  plant  passport  requirements  was,  the 
questionnaire included also specific questions to this group of stakeholders. Over half of the 
responding  citizens  knew  that  plants  have  to  be  accompanied  by  a  plant  passport  at  the 
business  level;  however,  only  about  a  third  knew  that  plants  bought  online  also  need  to  be 
accompanied by a plant passport. Although most of them were not aware of the plant passport 
requirements for plants bought online, more than half considered this requirement as a good 
idea compared with only about a third who believed it is counterproductive. 

4  CONCLUSIONS 

Overall, the extended plant passport system has contributed towards achieving the objectives 
of Regulation (EU) 2016/2031, in particular towards an increased effectiveness of protection 
against QPs, improved preparedness for the identification of new plant pests of EU concern, 
improved  understanding  and  awareness  of  relevant  stakeholders  on  the  plant  health 
importance and increased possibility to identify pests.  

However, the extension of the plant passport system to all plants for planting has been seen 
by most of the stakeholders as burdensome and difficult. Furthermore, the feedback gathered 
from  stakeholders  indicates  that  the  transition  to  the  new  requirements  was  not  always 
smooth  and  the  new  rules  related  to  the  plant  passports  were  not  always  clear,  making  the 
implementation in the beginning more difficult. Stakeholders agreed that the new provisions 
increased the protection of the Union territory  against pests and the costs they declared are 
not significant. However, at the same time they consider that some of the requirements pose 
additional administrative burden and associated costs that outweigh their perceived additional 
benefits. This is particularly so for the need to attach the plant passport to each single trade 
unit  and  for  the  provisions  governing  distance  sales.  Respondents  also  considered  that  the 
overall functioning of the plants for planting and seed sector had not experienced a significant 
change.  

To  enhance  the  effectiveness  and  practical  implementation  of  the  extended  plant  passport 
system and to achieve better usefulness, more discussions are needed in order to define what 

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targeted  improvements  might  be  necessary.  These  concern  (1)  the  provisions  for  the 
attachment of plant passports to  trade units and  (2) the arrangements for distance sales; (3) 
further discussion is also needed on a possible introduction of an electronic plant passport and 
how this change could be implemented without unnecessarily increase of the administrative 
burden on small producers and without losing the traceability that the attachment of a plant 
passport  to  the  trade  unit  provides  with  the  new  rules  that  are  now  in  place.  Any  putative 
amendment  of  the  new  plant  passport  regime,  however,  should  be  limited  in  scope,  as  it 
would mainly relate to adjustments to the existing system. 

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