WHAT?
The European Commission is looking to reform the European Union (EU) seed marketing legislation,
with a proposal expected by December 2022.
To assess the policy options that they are studying right now, the EU Commission has launched a
public consultation, which is open to associations and individuals in the EU, and anywhere around the
world, until 27th March 2022.
This consultation aims to gather opinions from breeders and maintainers of plant varieties, producers, growers or multipliers of plant or forest reproductive material, industry associations, farmers’ associations, civil society organisations, national authorities, amateur gardeners, any other interested stakeholders and members of the general public.
HOW?
To respond to the survey, you need to create an ‘EU login’ (you only need an email address to do it,
independent of your nationality or place of residence):
- Go to the EU login page by entering the following address in the
browser: https://webgate.ec.europa.eu/cas/login - Click “Create an account” & provide the information requested (first & last name, email address
& language) - Follow the link provided in the confirmation e-mail from EU login sent to the e-mail account
provided in the registration form (valid for maximum 1,5 hours) & create your password
Link of the EU SEED MARKETING survey:
- IN ENGLISH: https://ec.europa.eu/eusurvey/runner/PRM-FRMSurvey2022?surveylanguage=en
- IN FRENCH: https://ec.europa.eu/eusurvey/runner/PRM-FRMSurvey2022?surveylanguage=fr
POSITION PAPERS FROM EUROPE
AUSTRIA
Arche Noah: We have had a lot of fruitful discussions with many of you during the seed legislation workshop and the following weeks – thanks a lot for that. We are now happy to send you ARCHE NOAH’s position for the ongoing EU consultation.
We have uploaded our documents to this folder, in which you can find:
– “Feedback to the public consultation Annex 1”, which describes all our answers to the survey and includes an explanation why we chose which answer (if you need the short version of this for the short version of the survey, please get back to me directly)
– “Feedback to the public consultation” includes the two pager with our position, which we will attach in the online form of the consultation
– Annex 2 with additional data is currently missing, as we are still collecting them
There is broad agreement in which direction this reform should go, and we are happy so many are part of this vision. As always in the diversity movement, there is some disagreement on details, but we are confident we can articulate our differences in perspectives without harming each other’s positions.
Two aspects of our position were not clear to all, based on some feedback we got, so here our – also legally checked – explanation on these, to avoid misunderstandings in advance:
– What does it mean that farmer’s rights to seeds and conservation activities are “out of scope” of the legislation? Especially if the same/similar material is registered by another player as a diversity or industry/DUS variety? In our position it is clear, that these conservation and exchange activities could still take place, as they are not considered marketing! This is a difference to the current situation in many countries (e.g. Austria), where a registration for industry varieties can prevent farmers from legally exchanging these varieties with financial compensation if they cannot/do not want to fulfill the criteria of the mainstream regime.
– Sale to hobby gardeners: Seed marketing laws are geared towards professional (and mostly “mainstream” agricultural) users, which makes it an unfit regime to regulate the hobby gardener sector with its different needs and goals. But being outside the scope of the seed marketing regulation would still mean that consumer protection laws apply, and it does not prevent further rules, e.g. on labelling, transparency of breeding methods etc. in future.
LUXEMBOURG AND BENELUX
SEED and RMRM: Here is the comune position of RMRM et SEED and here is how they suggest answering.
FRANCE
Reseau Semences Paysannes: here is the document produced by the internal working group of the RSP on the seed marketing reform. This document does not constitute a common position of the RSP. It simply aims to give some ideas to build a framework favorable to the circulation and development of farmers’ seeds. It results from collective work: a workshop organized during the 2021 GA of the RSP, shaped and deepened by the reflections of an internal Working Group. It is unfortunately only available in French, but fortunately, for the translation, there is always Deepl.
SPAIN
Fundación Entretantos and Red de Semillas: Here is the document elaborated by those 2 organization in Spain.
Here you can find the Spanish document
GERMANY
Dreschflegel e.V.: Here is the document elaborated by the german organization (text only in german).
SWEDEN
Free Seed Sweden: It’s important to show the Commission that people are on our side! A Swedish seed company put a link to this campain in their newsletter and now over 1000 have “voted” in Sweden – only 300 from other countries across the whole union. To help you with sharing, here is a document translated to nine languages, this letter, and events on facebook. But it’s a hurry, only four days left!
https://docs.google.com/document/d/1VDU99frZO6hQj-6aXo_j0VXCcrGF5PAT4NKVYg-Zs4I/
DENMARK
Danish Seed Savers: Here is the contribution to the Open Public Consultation on the Reform of EU Seed Marketing Rules
EUROPE
ECVC: contribution to the public consultation on the revision of the European seed marketing legislation. Here you can see the answers on ECVC website.
Bread4all: Attached you will find the position on the European seed marketing reform of Brot für die Welt, an international organisation that is rather internationally oriented. It expresses its reservations about the impact of the EU seed legislation on the “countries of the South”. Here the survey
Geneva Academy: Geneva Academy sent contributions to the European Commission consultation on the reform of seed marketing rules. Here you can find the responses to the survey and here the 2 pages explanation on the need for the EU to recognize peasant seed systems, in line with the UN Declaration on the rights of peasants.
