New EU forest seed regulation 2026: what nurseries and reforestation companies must do

Key data

Forest nurseries and reforestation companies operating in the European Union face a significant regulatory change: the Regulation (EU) 2026/1392, published on 26 June 2026, completely replaces the Directive 1999/105/CE, which has been regulating the production and marketing of forest reproductive material for more than two decades. The new framework is not a minor update: it rewrites the rules for traceability, registration and certification to adapt them to climate change and the need for more resilient forests.

The official regulatory reference is OJ:L_202601392, applicable throughout the European Economic Area. In addition to repealing the previous directive, it modifies two key regulations: Regulation (EU) 2016/2031 on plant health and Regulation (EU) 2017/625 on official controls, integrating forest controls into the EU's general phytosanitary system.

What does this regulation establish?

The regulation creates a renewed framework for the production and marketing of forest reproductive material in the EU. This term includes seeds, plants and cuttings intended for forest production and reforestation.

The main changes compared to Directive 1999/105/CE are:

The climate change approach is central to the new regulation: the criteria for registering base materials and certification are updated to ensure that seeds and plants marketed contribute to forests that are more resilient to current environmental challenges.

Economic and operational impact

The impact is not just documentary. Companies in the sector will have to bear real adaptation costs in several areas:

• Update of base material registrations: Existing registrations will need to be reviewed and adapted to the new climate resilience criteria. This involves technical and administrative work, especially for nurseries with large material catalogs.
• Renewal of certifications: Certification procedures are changing. Companies that market forest reproductive material will need to obtain or update their certificates under the new framework.
• Adaptation of labeling and documentation: All batches of seeds, plants and cuttings must comply with the new labeling requirements. This affects the production and distribution chain.
• Integration into phytosanitary controls: As forest controls are integrated into the Regulation (EU) 2017/625 system, companies are subject to the general official controls regime, with the inspection and documentation implications that this entails.
• Transition periods: The regulation provides for transition periods for companies to comply with the new requirements, although the specific dates have not been specified in the initial publication. It is essential to monitor the implementing provisions published by the European Commission.

Who does it affect?

• Forest nurseries: Producers of plants and cuttings intended for reforestation or forest production. They must update registrations, certifications and labeling.
• Forest seed producers: Companies and entities that collect, process and market seeds of forest species. Affected by the new traceability and documentation requirements.
• Reforestation companies: Companies that carry out reforestation projects and use certified forest reproductive material. They will have to require their suppliers to provide material that complies with the new regulation.
• Forest administrations: Public regional and state bodies that manage their own nurseries or supervise the certification of forest reproductive material. They must adapt their administrative and control procedures.
• Importers and exporters of forest material within the EEA: The regulation applies throughout the European Economic Area, so cross-border trade in forest seeds and plants is subject to the new rules.

Practical example

A Spanish forest nursery with production of several pine and oak species, which currently markets plants certified under the Directive 1999/105/CE system, will have to face the following adaptation process:

1. Review all its registered base materials (seed stands, seed orchards, mother plants) and verify whether they meet the new climate resilience criteria of Regulation (EU) 2026/1392.
2. Update the certification documentation of each batch of plants produced, adapting it to the new format and requirements required by the regulation.
3. Modify the labeling of batches that it markets from the effective entry into force, including the information required by the new framework.
4. Prepare for integrated official controls in the general phytosanitary system, which may involve inspections coordinated with the competent phytosanitary authority.

If that same nursery exports material to Portugal or France, it must ensure that the documentation complies with the new regulation, which applies directly throughout the EEA without the need for national transposition.

What should companies do now?

1. Identify all base materials registered under Directive 1999/105/CE and assess whether they meet the new criteria of Regulation (EU) 2026/1392, especially those related to climate resilience.
2. Audit current certification procedures and map the changes needed to adapt them to the new framework. Involve the technical or quality manager of the nursery.
3. Review the labeling and documentation system for batches of seeds, plants and cuttings, and identify what needs to be changed to comply with the new requirements.
4. Monitor the implementing provisions and transition periods published by the European Commission and national forest authorities, as the specific dates for mandatory compliance will be defined in implementing regulations.
5. Contact the competent forest authority (regional or state) to learn about the planned adaptation schedule and the procedures for re-registration or updating of certificates.
6. Inform customers and suppliers (especially reforestation companies and administrations) of the regulatory change, so they can update their specifications and supply contracts for forest reproductive material.

Official source

Consult the complete regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202601392