EU Seed reform under scrutiny: Unpacking criticisms and concerns from ECLLD members

On 5 July 2023, the European Commission proposed a comprehensive Seed Law Reform with the aim of updating the legislation on the production and marketing of plant reproductive material (PRM). While this proposal seeks to enhance the regulatory framework and support sustainable agriculture, it has sparked debates and concerns among stakeholders regarding its potential impacts on agrobiodiversity management.

The key point of the reform have been summarised by Réseau Semences Paysannes (RSP) and is available here (in French)

Concerns on the EU Seed reform

Arche Noah, a prominent advocate for crop diversity, recently published a briefing outlining how the proposed EU seed regulation might pose challenges to preserving and exchanging diverse seeds.

The proposed legislation would make it impossible to build a “seed infrastructure” for sustainable agriculture, as it restricts the conservation and further development of diversity, and pushes back local innovation.

Arche Noah Briefing

Below are the key points raised by Arche Noah in their briefing:

1. Restriction on Transfer of Cultivated Plant Diversity: The proposed regulation restricts the free transfer of plant genetic resources for conservation, introducing bureaucratic hurdles that hinder farmers and seed organizations from preserving and selling endangered diversity.
2. Failure to Implement Farmers’ Right to Seed: The proposal introduces arbitrary restrictions on farmers, limiting their ability to exchange and sell their own seeds, contradicting their internationally recognized right to save, use, and exchange seeds.
3. Inadequate Measures for Widening Access to Diverse Varieties: While the proposal removes restrictions on marketing diverse varieties, it introduces impractical requirements that may hinder small producers from making these seeds available.
4. Lack of Focus on Sustainable Agriculture: The proposal’s approach to seed testing falls short in ensuring sustainability, as it does not mandate testing under organic or low-input conditions.
5. Positive Impact on Hobby Gardeners: The proposal includes exemptions for hobby gardeners, allowing private seed exchange and sale without mandatory variety certification, recognizing their unique needs and interests.

The full briefing is available here

Furthermore, the Umbrella Association for Crop and Livestock Diversity in German-speaking countries (Dachverband Kulturpflanzen- und Nutztiervielfalt e.V.) has also expressed in a press release significant concerns about the proposal’s shortcomings and potential negative impacts on biodiversity preservation.

The EU Commission’s aim to conserve agricultural plant diversity with the new seed legislation is
welcome – however, the EU Commission’s proposal contains such significant shortcomings that it is
likely to even lead to the contrary, to a loss of biodiversity

Susanne Gura – Dachverband Kulturpflanzen- und Nutztiervielfalt e.V.

Susanne Gura, representing Dachverband Kulturpflanzen- und Nutztiervielfalt e.V., highlights the following concerns:

1. Limited Exemptions for Diversity Conservation: Exemptions for diversity conservation apply only to formal networks and organizations, overlooking the role of individuals like gardeners and farmers in on-farm conservation.
2. Challenges with Unregistered Varieties and Seed Saving: Requirements for registering as operators may discourage seed-saving practices, impacting conservation efforts in home gardens and small farms.
3. Restriction on Farmers’ Rights to Sell Farm-Saved Seeds: The proposal restricts farmers from selling seeds of diversity varieties, potentially affecting biodiversity conservation.
4. Misalignment with International Objectives: The proposed regulation may not fully align with international objectives for plant genetic resources and peasants’ rights.
5. Call for Adequate Legislation to Encourage Conservation Work: The association urges governments to ensure adequate legislation that encourages farmers and gardeners to continue on-farm conservation work, preserving cultural heritage and supporting agriculture in the face of global warming.

For the full text from Dachverband Kulturpflanzen- und Nutztiervielfalt e.V. have a look here

The European Coordination Let’s Liberate Diversity! (ECLLD) continues to facilitate discussions and exchanges on the new EU seed reform. Stay tuned for ongoing updates.