ARCHE NOAH report
This May 2025 ARCHE NOAH report analyses the likely impact of the European Commission’s proposed Regulation on the Production and Marketing of Plant Reproductive Material (EU PRM Regulation) on small seed producers and fruit tree nurseries. Based on a late-2024 survey of 188 small producers across 16 EU Member States, the report finds that the proposal’s new administrative, traceability and production obligations (notably Articles 41–42 and Annexes II–III) would disproportionately burden nano- and micro-enterprises that conserve and market diverse, locally adapted varieties. Key findings include that respondents sell on average 152 varieties of 41 species, that 30% would reduce the number of varieties/species offered and 13% could cease operations, and that mandatory external laboratory testing alone could cost tens of thousands of euros per producer annually. The report argues these rules would reduce crop diversity and market access for small producers, and were not properly assessed in the Commission’s impact analysis. It calls for targeted amendments: exemption of nano-enterprises and farmers producing PRM for their own use from new notification and traceability obligations; proportionate production rules that remove mandatory external laboratory testing and avoid costly grading/machinery requirements; adapted rules for traditional fruit varieties (replicating existing CAC-style rules); and protection for non-commercial exchanges for conservation, sustainable use or education.
Key topics: EU PRM Regulation, administrative burden, small seed producers, conservation varieties, traceability, laboratory testing, fruit tree nurseries
