Appeal to Exporters: New Provisions for Supplementary Declarations on Phytosanitary Certificates Intended for Exporting Plants to the European Union

To provide more detailed information to entities that have not previously exported to EU member states, we note that Implementing Regulation (EU) 2019/2072 regulates, among other things, the requirements for importing certain plants, plant products, and other objects originating from third countries, including Montenegro, into EU member states. One of the prescribed requirements is that shipments of certain plants, plant products, and other objects exported to EU members must be accompanied by a phytosanitary certificate containing appropriate supplementary declarations mandated by Regulation (EU) 2019/2072, related to relevant quarantine pests. In addition to requirements concerning quarantine pests, Regulation (EU) 2019/2072 also stipulates requirements for regulated non-quarantine pests (RNQP), which shipments must meet. The certification of compliance with these requirements in the form of supplementary declarations on the phytosanitary certificate is not mandated by the EU as an additional guarantee of the shipment's health status. In cases where exemptions from these obligations are provided by Regulation (EU) 2026/1110, which effectively amends the aforementioned regulation, the phytosanitary certificate must include a reference in accordance with this regulation to clearly indicate which exemption applies to the shipment intended for entry into the EU territory. For more detailed information on the prescribed EU obligations, we emphasize that the textual writing of supplementary declarations on the phytosanitary certificate regarding the mentioned categories of harmful organisms is mandated by EU Regulation (EU) 2024/3115, which supplements the overarching regulation for plant health, Regulation (EU) 2016/2031. We urge exporters and entities involved in the plant export chain to the EU member states to consider this new requirement to avoid detention and rejection of shipments by inspection authorities of EU member states, especially when the relevant supplementary declaration on the phytosanitary certificate is missing, incomplete, or incorrect (in whole or in part).