Plants don't generally add a lot of crud to the water column, but when they do contribute, they can do so in substantial amounts.
I'd "round up" to be on the safe side. For example - if you were setting up a 46g bowfront and looking at Eheim classics, you could go with a 2213 or a 2215. For a FO tank, a 2213 would be fine as long as you keep a reasonable bioload. For a planted tank, you would benefit from having the 2215. Its stronger pump will help maintain circulation despite the presence of plants and it can filter junk out faster than the 2213 (nice to know if you have a greenwater outbreak or a crypt meltdown).
One other consideration - many planted tank owners use CO2. Keeping CO2 levels up in hte 15-30ppm range requires that there be only modest surface agitation (you want to introduce some O2 w/o driving off the CO2). This pretty well eliminates most HOB and bio-wheel equipped canister filters from serious consideration for many of those planning a planted tank.