EU authorities should recognize that seed savers are important for the conservation of varieties and exempt them from plant health registration. Some seed savers in Europe have already given up saving seeds. They can no longer continue to make seeds or other plant reproductive material available in a legal manner, and they do not want to do it illegally.
However, the conservation of cultivated plant diversity in most European countries depends on such individual seed savers.
With its Plant Health Regulation, the EU intends to control the spread of plant pests by enabling Plant Health Offices to search everywhere for viruses, bacteria, fungi or insects, even in gardens and on the premises of seed savers who share rare plant propagation material with interested people via web shops. The EU put in force an elaborate control system a few years ago. They are are currently re-evaluating their provisions regarding web shops. This is the opportunity for seed savers to ring alarm bells.
General control of those who are hobby gardeners is not the intention of this regulation. However, persons who are conserving cultivated plant biodiversity and are using web shops to reach out to like-minded people, now have to register. This is likely to affect the majority of seed savers in most EU countries. Registered persons and organisations have to fulfill certain obligations such as: knowing EU regulations, ensuring traceability, and allowing for eradication of plants found to carry pests. They can also pay an authorized operator to do it for them. For some plants particularly susceptible to certain pests, among them tomatoes and beans, plant passports have to be issued for each web shop sale.
Due to the tiny size of the lots, extra administration costs would increase the price of diversity seeds, considerably more than for mass commercial seed varieties. A cost recovery scheme would not help, because even this means extra administration. Also, any “lighter regulation” as proposed by some would not help, as it would still require the registration of people engaged in the conservation of diversity. Seed savers have neither the time nor the money for extra administration. They already have plants and possible pests under close scrutiny, since they don’t want to lose any plant from which they have chosen to harvest seed. Only operators with paid staff have so far been able to cope with just some of the legal requirements.
However, it would cut cultivated plant diversity from its roots, if throughout Europe it was conserved by only a handful of organisations with paid staff. The local engagement of many people in cultivating plant diversity must remain movement in society. It requires many gardens and many people to love, care for and develop the living cultural heritage adapted to local conditions and then hand it over to the next generation. Who would get engaged if expensive seed and official registration were needed from the start?
The seed saving community prevents rather than eradicates pests. They care for healthy soils, with mixed cultivation, crop rotation, an environment that strengthens naturally occurring beneficial predators and therefore also increases the vitality and adaptability of the plants. With their broad genetic base, diverse varieties are able to withstand stress. A good example is the German apple variety “Edelborsdorfer” which for 600 years has been free of any damage from scab, the most important disease in European commercial apple cultivation.
The fact that old varieties lack modern “resistance genes”, is hardly a disadvantage. Such resistance genes are single genes that can be broken by pests or diseases adapting to them. Monocultures encourage pests to multiply and sometimes develop and spread new variants. Even diversity varieties can be affected.
Diversity varieties, however are often not affected by the presence of a virus or other pest. To eradicate these healthy plants would be a serious mistake if the EU Regulation truly aims at better plant health.
Some of the seed savers have not only cancelled their web shops, but also ceased their activity. Without web shops, the sale of tomato and bean seed in particular, dubbed as „diversity diplomats“ due to their importance and attractiveness, the cultivation of numerous varieties and many other species would be reduced to a fraction of what is grown today in gardens and fields. More damage to diversity is likely if seed savers are not immediately and completely exempted from the official registration obligation under Plant Health Regulation EU 2016/2031.
Diversity varieties are a necessity, not a risk, as some are claiming. Imposing the registration obligation on seed savers using web shops could deeply damage diversity conservation and does little to help to avoid plant health problems in the EU.
Thank you for your support, Dachverband Kulturpflanzen- und Nutztiervielfalt e.V. from Bonn