Thank you for the opportunity to comment on the proposed guidance for Virginia’s invasive plant signage requirements.

Over the past several weeks, I have spoken informally with garden centers, growers, agricultural retailers, landscapers, and other businesses about how they are preparing for the January 1, 2027 requirements. These conversations were not a formal survey, but they did highlight several common issues.

Most businesses I spoke with were not opposed to the purpose of the law. Many said they have already been moving away from invasive plants for years and regularly recommend alternatives to customers.

What stood out more was the need for clearer communication. Some people I spoke with were unaware of the new requirement. Others knew about it but still had questions about who it applies to, how it will be enforced, where signs must be placed, and how exemptions work.

I encourage VDACS to provide a simple FAQ or implementation guide before January 1st that answers these basic questions.

Mixed Displays and Sign Placement

Retail plant displays change constantly. Plants are moved, grouped together, separated, and consolidated as inventory changes.

Plant-specific signs can work well when one species or cultivar is grouped together. It can become more difficult to administer when invasive and non-invasive plants are grouped together or when several plant varieties share a common sales area.

VDACS should allow retailers flexibility in these situations. A single, clearly visible sign for a mixed display may make more sense than requiring several individual signs, as long as customers can clearly understand which invasive plants are present.

The goal should be clear notice to the customer, not unnecessary duplication of signs.

Sign Size

I also encourage VDACS to reconsider the 8.5" x 11" minimum sign size.

Garden centers use many types of bench signs, stakes, clips, and display holders. Smaller sizes such as 7" x 11" or 5" x 7" may work better in some settings and can be easier to move as displays change.

Rather than requiring one minimum paper size in every situation, VDACS should focus on whether the required information is clear, easy to read, and visible to customers.

Hybrids, Cultivars, and Exemptions

Section 4.E is important because not every hybrid, cross, or cultivar presents the same risk as the invasive species it may be related to.

At the same time, retailers should not be expected to research complicated plant lineage on their own.

VDACS should provide clearer guidance on which commonly sold plants qualify for an exemption and, where possible, maintain an approved list or clear process for determining exemption status.

Conclusion

Based on my conversations, the biggest issue does not appear to be resistance to the law. It is making sure businesses understand what is required and can apply the rules in real retail environments.

I encourage VDACS to focus on four areas:

1. clearer industry education and outreach;

2. flexibility for mixed and changing displays;

3. flexibility in sign size when information remains clear and readable; and

4. clearer guidance on hybrids, cultivars, and exemptions.

Thank you for considering these comments and for continuing to work with Virginia’s horticultural industry as the new requirements take effect.

Respectfully submitted,
Ray Magee
BloomCatch