b'BRUSSELS SPROUTSBY: JARED ONSANDOA NEW EU PLANT REPRODUCTIVE MATERIAL LEGISLATION?I n the revision process towards new legis- supply for farmers and growers. In essence,usefulness of specific traits (e.g., herbicide lation on the production and marketingthe proposal maintains the requirementstolerance) and establish cultivation condi-of plant reproductive material (PRM),for proper identification (DUS or officiallytions for varieties carrying such traits. This Euroseeds has continuously underlinedrecognised descriptions) of all PRM, per- would create severe legal and commercial the sectors strong support to maintain theformance assessment (VSCU), seed qualityuncertainty for breeders and run coun-pillars of the existing legal framework forguarantees (Certified Seed/Standard Seed),ter to the need for long-term investments. variety registration and seed marketing,and phytosanitary controls. We also oppose that competent national ensuring the continuous development andWe support the improved process forauthorities may renew a variety registra-marketing of improved varieties throughgranting equivalence status for PRM fromtion on their own initiative, as the provi-dedicated identity (DUS) and performancethird countries, providing subsidiaries ofsion is unspecific and lacks clarity regarding (VCU for agricultural species) assessment,EU-based companies with necessary supplyresponsibility for maintenance and IP status and proper seed quality guarantees throughsafeguards under increasingly challengingof the variety in question.certification or high-quality standards andenvironmental conditions. Euroseedswillproposeseveral respective testing, including phytosanitaryIt is also a positive step that all PRMimprovements to the text to clarify defi-controls.now clearly fall under the relevant specificnitions and ensure that essential practices The Commission placed a specificlegislation, ensuring that any PRM productfor PRM supply are properly specified. focus on the (potential) contribution of seedconforms to appropriate identification, per- Most importantly, it needs to be discussed to the overarching sustainability goals offormance, technical quality standards, andwhether the Commissions approach to the Farm-to-Fork and Biodiversity strate- the absence of pests and diseases. This is ana new compulsory VSCU testing for all gies as well as on seed diversity and accom- important quality and customer assurancespecies is both justified and manageable modating niche market actors and needs.for any user of PRM, regardless of produc- in practice. On the one hand, the exclu-Euroseeds reiterated the contribution oftion or marketing standards.sion from such obligations under some of breeders to sustainability, that this con- Euroseeds acknowledges the needthe derogations clearly lacks logic and/or tribution is successfully supported by thefor derogations and specific standards forconsistency; on the other, it is still unclear current legislation and its opposition to anydefined markets, materials, and users if thehow this new provision could be developed blanket exemption of commercial activitiesprincipal elements of proper identification,across the highly diverse and often rather or seed products from the legislation. quality information and plant health con- small market segments typical for the veg-trol are observed. We consider the generaletable sector. Here, it must be ensured that THE PROPOSAL information and obligation for all marketthe apparent desire for a one size fits all The proposal, published on 5 July 2023 aimssegments as a potentially useful element forapproach is amended in a way that corre-at consolidating existing EU legislationfuture policy initiatives. sponds to the diversity of species and their through a single regulation and enhanc- So, it seems that there are many posi- biology as well as market needs and the ing alignment with other regulations (e.g.,tive elements in the proposal, but. overall objective of broad diversity. plant health and official controls). ButTo ensure that all these elements are it also focuses strongly on sustainabilityTAKING A CLOSER LOOK duly taken into consideration in the politi-goals, and on facilitating the marketing ofStill, there are numerous elements of thecal discussions over the coming weeks and diverse PRM. It maintains variety testing,proposal that require further clarificationmonths, it is imperative that Europes seed registration, and seed certification stand- and/or change to arrive at a text that can beindustry is highly engaged at both the EU ards as principal pillars while providingsupported by the entire seed sector. and national levels. The time to act is now! numerous derogations for specific material,Most importantly, some basic defi-users, and markets. New is the introductionnitions require precision, such as e.g., theEditors Note: Jared Onsando is Technical of the Value for Sustainable Cultivationterm marketing which should be properlyManager Variety Testing and Registration at and Use (VSCU) requirement, which shallre-formulated to assure that movementEuroseedsnow apply to all crops. of pre-commercial PRM for processing and re-export can continue unimpeded. AT FIRST GLANCE Similarly, it must be clarified that the Euroseeds welcomes that the Commissionssupply of trial seed is not aimed at com-proposal maintains the elements of themercial exploitation of that seed and must EUs legal framework for variety regis- not be unnecessarily restricted. This is an abbreviated version of the tration and seed marketing, ensuring theEuroseeds clearly opposes the provi- original column. The full column cancontinuous development and market releasesions that establish an unpredictable cartebe found on our website:of improved varieties and high-quality seedblanche for Member States to decide on thewww.european-seed.com.14ISEED WORLD EUROPEIEUROPEAN-SEED.COM'