Enhancing RNQP Traceability, Digital Trust and Data Interoperability

Our feedback welcomes the European Commission’s proposed amendments to Commission Implementing Regulation (EU) 2019/2072, particularly the opportunity to modernise Annex V to enhance the traceability, digital trust, and cross-border interoperability of declarations concerning regulated non-quarantine pests (RNQPs). We recognise that effective RNQP management is essential not only for plant health and agricultural productivity but also for the smooth functioning of the EU Single Market and international trade flows. To future-proof the regulatory framework, we advocate for the integration of key digital enablers already advanced under broader EU strategies—namely the Digital Product Passport (DPP), verifiable Legal Entity Identifiers (vLEIs), the electronic Freight Transport Information (eFTI) system, and qualified trust services under eIDAS 2.0. These tools can transform RNQP declarations from static, paper-based attestations into dynamic, machine-readable, and cryptographically secured data sets that are interoperable across customs, phytosanitary, environmental, and logistics systems. By anchoring RNQP controls in a unified digital ecosystem—linked to platforms such as TRACES, the Customs Single Window, and CBAM registries—the EU can ensure legal certainty, reduce administrative burdens, prevent fraud, and support sustainability objectives like pesticide reduction and biodiversity protection. Our proposed amendments aim to embed these capabilities directly into Annex V, ensuring that RNQP governance evolves in lockstep with the EU’s ambitions for a data-driven, secure, and green Single Market.