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

As of 6 July 2026, additional declarations detailing compliance with Regulated Non-Quarantine Pests (RNQPs) requirements are mandatory on all Phytosanitary Certificates (PCs) of consignments entering the EU. While the RNQP technical requirements themselves remain unchanged, the adopted measures must now be specified explicitly on the PC. This article outlines this new requirement and its exemptions and provides references to the relevant regulations to support implementation. The use of the additional declarations for the quarantine pest remains unchanged.

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.

This article is from the NVWA. View the original article here.