12 I SEED WORLD EUROPE I SEEDWORLD.COM/EUROPE | OCTOBER 2026 deforestation free, legally produced in the country of production, and covered by a due diligence statement. That includes collecting information such as geolocation data for the plots of land where the relevant commodity has been produced. For large commodity flows, that logic is understandable. For small seed lots, Euroseeds said the practical result would have been very different. Soybean seeds for sowing are produced, handled and traded under seed specific production and marketing rules. Their function is not to supply crushing plants or feed markets, but to enable crop production and breeding. A bag of commodity soybeans and a bag of certified soybean seed for sowing might seem similar in theory, but the value chains arise from different systems and rules, with different economic and environmental implications. WHY SEEDS ARE DIFFERENT FROM COMMODITY SOY Euroseeds pointed to trade data to support its case. According to publicly available EU COM data, zero per cent of soya beans imported into the EU from Brazil and Argentina in 2024 were for sowing purposes. From the United States and Canada, only 0.2% and 0.3% respectively were destined for sowing. The letter also notes that 26% of soybean imports from Serbia were for sowing, reflecting the role of neighbouring European countries with low deforestation risk. The Commission’s Delegated Regulation now reflects that rea soning, stating that soya beans used for sowing present negligible trade volumes and are part of a separate value chain with distinct controls. For seed companies, the issue is also operational. Seed lots already need identity, quality and traceability, principles that are also central to seed certification and global seed trade. Imported seed is subject to controls, including phytosanitary checks and, where relevant, GMO detection testing. Branislava Popov, technical manager variety registration and seed marketing at Euroseeds, says seeds for sowing are not anon ymous bulk commodities. “They move through a regulated system where identity, quality and traceability are essential,” she says. For soybean seed, Popov adds, this means the lot is already handled with “a different control level compared to commodity soybeans used for feed or crushing.” Soybean commodities remain covered by the EUDR. Certified soybean seeds for sowing, however, are now treated according to their actual role and risk profile. A SMALL TRADE FLOW WITH BIG BREEDING CONSEQUENCES The EUDR question also links to a larger European policy objective: strengthening domestic plant protein production. The European Commission’s own Agri Food Data Portal notes that the EU produces around five million tonnes of protein crops per year and remains a traditional net importer of oilseeds. Soybean is therefore part of a wider conversation about protein autonomy, crop diversification and resilience. Seed World Europe has covered this challenge in several recent articles, including the role of high-performance soybean cultivation in Europe, the Legume Generation project, and efforts aimed at boosting European legume breeding for protein and market growth. A common theme runs through all of them: Europe needs better adapted, higher performing legume varieties if it wants farmers to grow more protein crops. Access to germplasm is central to that effort. Breeding depends on genetic diversity. For soybean, Euroseeds warned that European breeding programmes already face a narrow genetic base and lim ited access to diverse material, especially from North America. Additional compliance obligations for importing breeding material could have made that challenge worse. According to Popov, breeders need access to diverse genetic material to develop soybean varieties that perform under European conditions. “If additional administrative barriers make it harder to bring in breeding material, the effect may not be visible immedi ately,” she says, “but over time it can slow gene driven innovation.” Plant breeding is slow, complex and cumulative work. New soybean varieties need to combine yield, maturity, protein content, disease resistance, stability and adaptation to local environments. Europe’s climate conditions are changing, and farmers need varie ties that can cope with heat, drought, shifting disease pressure and different production systems. The Commission’s decision avoids placing an additional admin istrative layer on a seed category that is already highly controlled and strategically important. It also aligns with the Commission’s Vision for Agriculture and Food, which emphasises a competitive, future proof and resilient agri food sector, and with the EU’s wider ambition to strengthen its plant protein base. SMES AND THE COST OF COMPLEXITY The position paper also highlighted the structure of the seed sector. Many European seed and plant breeding companies are SMEs. According to Euroseeds, 58 private and public organisations have listed the 814 soybean varieties registered in the EU Common Catalogue. Of the 45 private operators, 21 are small and medium enterprises, or around 47%. For those companies, EUDR due diligence would not have been a light administrative exercise. It can involve geolocation data collection, risk assessment, documentation and recurring compli ance steps. For a small seed company importing limited amounts of breeding material or certified seed, the burden would have been disproportionate. Soybean breeding relies on access to seed and genetic diversity. Under the amended EUDR, soybean seeds for sowing are treated separately from commodity soybeans.
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