Standards and Regulations in Potato Production: An Overview for Germany

There is no single “Potato Act”. Anyone who produces, stores and markets potatoes in Germany operates within a network of EU regulations, German ordinances and private-sector standards. Some are legally mandatory, others are formally voluntary but in practice a prerequisite for being able to supply the retail trade at all.

This article untangles that network. It shows which sets of rules apply to what, where the difference lies between table, seed and processing potatoes, and what documentation ultimately remains to be done on the farm. As guidance, not legal advice: responsibilities lie with the federal government, the Länder and private scheme owners, and the rules are subject to change.

Three Uses, Three Regulatory Worlds

Before going into detail, the most important distinction: what are you producing for?

• Table potatoes are primarily subject to the marketing standards for fresh fruit and vegetables and to food law.
• Seed potatoes are governed by their own strict certification law with official inspection.
• Processing potatoes for fries and crisps are additionally subject to the Acrylamide Regulation, which extends into storage conditions.

Across all three, traceability, plant health, plant protection law and – crucial for market access – private quality standards apply.

1. Marketing Standards and the Abolished Commercial Classes

This is where the most common misconception lies. For table potatoes in Germany, there have been no statutory commercial classes since 1 July 2011. The Ordinance on Statutory Commercial Classes for Table Potatoes was repealed. Since then, terms such as “commercial class” or “class” may no longer appear on table potato labels if they create the impression of a state standard.

They have been replaced by two voluntary schemes:

• The Berlin Agreements, a private-sector scheme with the grades “Quality I” and “Quality Extra”. Anyone labelling according to it must add a reference to the Agreements. In terms of content, the characteristics largely correspond to the former commercial classes: true to variety, sound, whole, clean, firm, free from foreign odour, practically free from sprouting.
• The UNECE Standard FFV-52 for early and ware potatoes. It is internationally recognised, also voluntary and, unlike the Berlin Agreements, requires indication of variety and country of origin.

Above these lies the general EU marketing standard for fresh fruit and vegetables (currently in Regulation (EU) 2023/2429), which lays down minimum requirements for fitness for consumption and labelling. A special feature for seed: potatoes that have not been treated with sprout suppressants and are therefore suitable for propagation must be marketed with indication of variety under plant variety protection law.

2. Seed Potatoes Have Their Own Strict Legislation

Anyone who multiplies and places seed potatoes on the market is playing in a different league. The basis is the Seed Trade Act, specified for potatoes by the Seed Potatoes Ordinance (PflKartV). Seed may only be placed on the market if it has been officially certified.

Certification is carried out by the certification authorities of the Länder, around fifteen nationwide, coordinated in a joint working group. The crop in the field is inspected on site and the quality after processing is checked. Because potatoes are vegetatively propagated and diseases can be transmitted via seed, additional health checks are carried out, such as official testing for quarantine bacteria. Decisions on variety approval are made by the Federal Plant Variety Office.

Seed is classified in EU classes, from pre-basic seed via basic seed to certified seed of classes A and B. The number of field generations for certified seed is limited to two. In practice this means: seamless documentation of every multiplication stage and every processing step, otherwise certification and thus traceability are at risk.

3. Plant Health and Plant Passport

At a higher level, the EU Plant Health Regulation (EU) 2016/2031 applies. It governs protection against plant pests and requires a plant passport for many goods, including seed potatoes, when they are placed on the market. The aim is to prevent the introduction and spread of quarantine pests. Here too, everything depends on traceability: if an infestation occurs, the movement of the goods must be traceable.

4. Food Safety and Traceability

The basis for all foodstuffs, including table potatoes, is Regulation (EC) No 178/2002, the General Food Law. Its core principle for businesses: traceability one step back and one step forward. You must be able to prove where goods came from and to whom they were delivered. In addition, Regulation (EC) No 852/2004 on food hygiene lays down requirements for hygienic conditions along the chain.

In concrete terms, this means for a potato store: each lot must be attributable to an origin, and every movement of goods should remain traceable, from intake through sorting and packing to dispatch.

5. Acrylamide: A Rule That Reaches Into Storage

For processing potatoes, the Acrylamide Regulation (EU) 2017/2158 has been binding since April 2018. Acrylamide is formed when starchy foods are heated strongly and is suspected of increasing the risk of cancer. The Regulation prescribes mitigation measures and benchmark levels.

For potatoes, the key requirement concerns storage conditions: anyone storing affected goods must keep them above 6 °C and keep the level of reducing sugars low in order to avoid sweetening through senescence. Legally, the obligation falls on food business operators, i.e. processors and businesses with their own storage, but via supply contracts it extends to growers. That is precisely why processing potatoes are deliberately stored warmer than table potatoes. The relationship between storage temperature, sugar content and processing quality is explained in detail in our article on the correct temperature during storage.

6. Sprout Suppression and Plant Protection

Much has changed in recent years regarding sprout suppression. The long-standing standard active substance chlorpropham (CIPC) has lost its EU approval. In Germany, authorisations for corresponding products ended in mid-2019, with the grace period running until October 2020. A legacy issue should be noted: CIPC residues can remain in stores for years and contaminate subsequently stored goods. The competent Federal Office of Consumer Protection and Food Safety (BVL) has therefore published recommendations for thorough store cleaning.

Depending on the approval situation, the following are used as alternatives:

• Maleic hydrazide, applied in the field before harvest
• Ethylene, as a gas in storage
• 1,4-Dimethylnaphthalene (DMN), under various product names
• Mint oil or L-carvone and Orange oil (limonene) as natural active substances

Which products are actually authorised changes constantly and differs depending on the application. The binding reference is always the current BVL authorisation list, not the general enumeration here. Anyone who wants to manage entirely without chemical sprout suppression relies on variety selection and consistent cold storage, with the known limitations regarding sugar content.

Documentation obligations apply to plant protection as a whole. The field record, which documents which lot was grown on which field and how it was treated, is standard for certified businesses and at the same time the basis for any traceability.

7. Private Standards: QS-GAP and GLOBALG.A.P.

Formally voluntary, in practice the key to the retail trade: large buyers as a rule require certification according to QS-GAP or GLOBALG.A.P. Without it, goods hardly make it onto the shelves of the major food retailers.

These standards adopt traceability and documentation from Regulation (EC) 178/2002 and go beyond it. For QS, this includes, among other things:

• documentation of suppliers and customers with delivery quantities, dates and batch numbers
• a clear separation and labelling of QS and non-QS goods, a so-called K.O. criterion where mixing must be ruled out
• a plausible reconciliation of incoming and outgoing quantities, taking storage losses into account, also a K.O. criterion
• tight response times: requested traceability data must be available within 24 hours, and structured in such a way that it can be evaluated within four hours

In practice, this four-hour rule is the real test. Anyone who runs their store from memory or on a chalkboard will struggle to comply in an emergency.

8. What This Means for Documentation in Storage

Summarising the various sets of rules, a clear catalogue of obligations emerges at the level where things become concrete – namely in storage:

• Origin per lot: which field and plot the potatoes come from, and for seed the multiplication stage
• Goods movements: intake, relocation, sorting, packing, dispatch, each recorded by quantity and lot
• Separation of lots: no inadvertent mixing of QS and non-QS goods or of certified and non-certified seed
• Quantity reconciliation: a traceable ratio of input to output including shrinkage
• Treatments: sprout suppression and plant protection with active substance, quantity and date
• Storage conditions: for processing potatoes, proof that the temperature was kept above 6 °C

In many businesses, this is precisely the weak point. Processes are running, but traceability is scattered across slips of paper, Excel sheets or the memory of individuals. As long as nothing happens, this goes unnoticed. When a request comes from QS or a complaint is made, loose documentation quickly becomes a problem.

This is where digital store management comes in. If each lot is recorded at goods receipt with origin, variety and quantity and every movement is logged in the system, the required traceability is created as a by-product of daily work, not as additional effort at the end of the year. Treatments, quantities and – linked to the climate control system – the temperature history can also be assigned to the same lot. The QS four-hour requirement then becomes a query of seconds. How the individual crate can be used as an addressable unit for this is shown in our article on crate types in storage.

Frequently Asked Questions

Are there still commercial classes for table potatoes? No. The statutory commercial classes for table potatoes were abolished on 1 July 2011. “Class” or “commercial class” may no longer be used to suggest a state standard. The Berlin Agreements (Quality I and Extra) and the UNECE Standard FFV-52 are used on a voluntary basis.

What traceability is required by law? Regulation (EC) 178/2002 requires traceability one step back and one step forward: where the goods came from and to whom they went. Private standards such as QS go further and require that data can be evaluated within a few hours.

Is QS or GLOBALG.A.P. certification mandatory? Not by law. In practice, however, large buyers require it almost without exception, so it is virtually indispensable for market access in retail and processing.

May I still treat potatoes with CIPC? No. Chlorpropham (CIPC) has lost its EU approval; in Germany the grace period ended in October 2020. Old CIPC residues in stores are a separate issue; the BVL has issued cleaning recommendations for this. Alternatives include maleic hydrazide, ethylene, DMN and mint and orange oil, depending on current authorisation.

Do I need to observe special rules for potatoes for fries or crisps? Yes. The Acrylamide Regulation (EU) 2017/2158 requires storage above 6 °C and a low sugar content in the raw material. The obligation applies to processors and businesses that store the product and is passed on to growers via supply contracts.

This overview does not constitute legal advice. Responsibilities and deadlines lie with the federal government, the Länder and private scheme owners, and the regulations are subject to change. Binding information is provided by the BVL, BLE, the certification authorities of the Länder and QS and GLOBALG.A.P. Status of the information researched: 2024/2025.