3,569. A Tree Planted for Mitzvah Purposes
Hilchos Maaser Sheini and Neta Revai 10:7
If someone plants a tree for mitzvah purposes, such as an esrog tree for the arbah minim on Succos or an olive tree to produce oil for the Chanukah menorah, the rules of orlah apply. If someone consecrated a tree before planting it, it is exempt from orlah; if after planting, then orlah applies.
Hilchos Maaser Sheini and Neta Revai 10:8
If someone plants in an unperforated flowerpot, the rules of orlah apply. This isn’t considered the ground vis-à-vis plants, but it is vis-à-vis trees.