The plant passport traceability code (element C), explained
Element C is the part of a plant passport that sellers ask about most. Here is what the code is for, which codes you can use, when you can leave it off and how to tie it to your records.
Short answer
Element C is a traceability code that links the plants in a unit back to your records. It can be a code you already use, such as a batch, lot or consignment code, as long as it traces back to the unit where the passport was issued. It can be left off only when the plants are ready for sale to final users without further preparation and are not a type that always needs a code. Most online sellers include it anyway.
What the traceability code is for
The law describes element C as the letter "C." followed by "the traceability code of the plant, plant product or the other object concerned" (Annex VII).
Its job is to let you, and APHA, follow a plant back through your records. GOV.UK says the code "must provide traceability back to the unit where the plant passport was issued", and that your records "must allow APHA to investigate any pest or disease outbreaks" (GOV.UK). Defra adds that it must cover all the regulated plants in the trade unit (FAQ Q4.3).
Which code can you use?
There is no official format. GOV.UK says the code "can be an existing code used to trace or identify a consignment". Pick something you already track and can look up later:
| Type of code | Example | Works well when |
|---|---|---|
| Batch or lot code | BATCH-0418-03 | Plants come in or are propagated in batches and you note where each batch came from. |
| Delivery or supplier reference | DEL-2026-114 | You buy in plants and record the passport that arrived with each delivery. |
| Date and sequence | 20261012-07 | You pack orders in daily runs and keep a list of what went into each run. |
| Order number | #10452 | Each order record also says which batch or supplier the plants came from. |
A code is only as good as the record behind it. An order number alone does not trace anything unless your records show where the plants in that order came from.
When the traceability code can be left off
The code is not required for plants for planting that meet both of these conditions (Article 83):
- they are prepared so they are ready for sale to final users without any further preparation, and
- they are not one of the types or species for which the code is always required. GOV.UK describes this as plants with no risk of spreading quarantine pests in Great Britain.
Why most online sellers include it anyway
Leaving C blank saves very little. Including it means you do not have to decide plant by plant whether the exemption applies, and it gives you a quick way to answer an inspector’s question: where did the plants in this parcel come from, and which other parcels came from the same batch?
An optional barcode, QR code or other data carrier can be added alongside the code, but it does not replace it (Annex VII).
Splitting supplier deliveries into parcels
If you buy plants with a passport and split them into smaller units, such as individual customer parcels, you must issue new passports for the new units (Defra FAQ Q5.5). Your new code should link each parcel back to the delivery and the supplier’s passport. If you replace a passport, keep a record of the original for at least 3 years.
Linking the code to your records
For 3 years you must keep a record of who supplied passported plants to you, which professional operators you supplied, and the information in each passport you issued. It does not have to be a physical copy of the passport (Defra FAQ Q5.3). Plant passport record keeping has a free spreadsheet template for exactly this.
Plant Passport Ops stores a traceability code for each plant in your catalogue, prints it on the label and saves every batch with its orders and passports, so you can search by code later.
Change ahead: under the UK–EU SPS agreement, the government says EU plant passports will replace UK plant passports, with the agreement intended to take effect in mid-2027 (subject to negotiations). Until new guidance is published, the UK rules on this page apply. See EU plant passports in 2027.
Common questions
Can I use my order number as the traceability code?+
Yes, if your records for that order show where the plants came from. The code has to let you trace the plants back, so an order number works only together with a record of the batch or supplier.
Does the traceability code have to be unique?+
The guidance does not require a unique code per parcel. Many sellers use one code per batch, which is printed on every passport for plants from that batch.
Is a QR code or barcode required on a plant passport?+
No. A barcode, QR code or chip is optional and can supplement the traceability code, not replace it.
Can I reuse my supplier’s traceability code?+
If you move the plants on unchanged and unsplit, they can travel under the supplier’s passport. Once you split a delivery into parcels, you issue your own passports, and your code should link back to that delivery.
Sources
- GOV.UK: Issuing plant passports to trade plants in Great Britain
- Retained Regulation (EU) 2016/2031, Annex VII (plant passport content)
- Retained Regulation (EU) 2016/2031, Article 83 (plant passport content and traceability code)
- Defra Plant Health Portal: Plant passport FAQ
- GOV.UK: SPS agreement, horticulture industry: preparing your business
This guide summarises official guidance for Great Britain as of 12 Oct 2026. Rules can change, so check the linked GOV.UK pages or contact APHA (Scotland: SASA) for your own situation. Plant Passport Ops does not grant official authorisation or provide legal or regulatory advice. It helps sellers organise label and record workflows based on the information they enter.
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