Is it still allowed to sell mulch films without the CE marking?

Yes, “contrary to most other products harmonisation measures in Union law, the FPR does not replace national legislations and does not prevent non-harmonised fertilising products from being available on the single market in accordance with national legislations. Compliance with the harmonised rules as laid down in the FPR remains optional.”14 However, the biodegradable mulch films which are not certified according to FPR or national legislations on fertilisers are not to be considered fertilisers.