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ARCHE NOAH, Gesellschaft für die Erhaltung der Kulturpflanzenvielfalt und ihre Entwicklung

ARCHE NOAH

Arche Noah is an association dedicated to the conservation and development of crop diversity.

Lobbying Activity

Meeting with Pietro Fiocchi (Member of the European Parliament)

5 Dec 2025 · Omnibus VI

Meeting with Silvia Sardone (Member of the European Parliament, Shadow rapporteur)

15 Oct 2025 · ENVI COMMITTEE

ARCHE NOAH demands stronger rights for farmers to save seeds

14 Mar 2025
Topic — The EU is evaluating legislation that grants intellectual property rights for plant varieties.
Message — The organization calls for the full implementation of farmers' rights to save, exchange, and sell seeds of all species. They demand explicit exemptions for conservation activities and strong safeguards against the misappropriation of traditional varieties.123
Why — This would allow their conservation networks to operate without intellectual property barriers.4
Impact — Large seed companies would lose revenue from mandatory royalties on farm-saved seeds.56
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Meeting with Herbert Dorfmann (Member of the European Parliament, Rapporteur)

9 Apr 2024 · PRM

Meeting with Herbert Dorfmann (Member of the European Parliament, Rapporteur)

15 Mar 2024 · PRM

Meeting with Herbert Dorfmann (Member of the European Parliament, Rapporteur)

27 Feb 2024 · PRM

Meeting with Martin Häusling (Member of the European Parliament)

21 Feb 2024 · Saatgutübergabe

Meeting with Isabel Carvalhais (Member of the European Parliament, Shadow rapporteur) and Fundación Entretantos

19 Feb 2024 · Proposta de regulamento relativo à produção e comercialização de material de reprodução vegetal na União

Response to Targeted amendment of the Plant Health Regulation

19 Dec 2023

As Arche Noah, we have been conserving and dynamically managing crop diversity since 1990. Today we have the responsibility to manage one of Europes biggest private collections of cultivated plants, maintaining about 5,500 accessions of mostly crops and crop wild relatives. As our primary aim is to conserve plant genetic resources, plant health is in our utmost interest. Diseases and pests can critically endanger our conservation work as they can lead to the eradication of varieties. Therefore, we see plant and seed health as a basis of our work and critical for our success. Nevertheless, in its current form, Regulation 2016/2031 endangers our conservation work as well as the work of many other community seed banks and seed saver organisations. We have therefore read the revision of the regulation with great interest. Unfortunately, we are missing important changes that are important for people and organisations involved in the conservation of plant genetic resources. Conservation organisations are regional networks based on the decentralized propagation and exchange of seeds and plants between network participants (private individuals and farmers), at times coupled with a central ex-situ collection. Propagation and conservation of plant genetic resources are, hereby, not geared towards profit; seeds are exchanged for free or on a cost-recovery basis. The exchanges are often organised via an online directory (a simple database of sources of supply and identification) and postal services. These activities could fall under the requirements of Regulation 2016/2031 as it stands today, even though its provisions are primarily geared towards intra-EU trade of seeds and plants. The current plant passport requirements hinder the conservation work and are not proportionate to the risks entailed by these local or regional activities that provide public goods, and are not akin to the commercial exploitation of seeds and plants. The increased obligations with regards to traceability push for the centralisation of the production in the hands of the association itself, instead of conserving plant material in different agroecological and climatic conditions. Furthermore, the Regulation creates further barriers for participatory plant breeding and limits farmer access to germplasm. We want to urge you to think of a regime that is fit for purpose to protect plant health while safeguarding the conservation of plant genetic resources. This could, for example, be built on an exemption for the aim of conserving plant genetic resources, similar to the one in Switzerland (https://www.fedlex.admin.ch/eli/cc/2018/682/de#art_62), which is granted to individuals or organisations. The Regulation could thereby allow national authorities to issue, upon request, an exemption (or an authorisation to be excluded) from the plant passport requirements for conservation organisations or individuals engaged in conservation work that are active in their territory. For this purpose, those engaged in conservation work should submit an action plan to the national authorities explaining how they will ensure seed and plant health in a proportional and adequate manner. Based on trust to be built between authorised entities or individuals and national authorities, this solution would attenuate the detrimental effects of the Regulation 2016/2031 on crop diversity conservation, but still protect seed and plant health. It would further raise ownership of seed and plant health issues in the crop diversity conservation community. For many small farmers and conservation organisations the enforcement of the provisions of Art 81(1)(a) (Regulation 2016/2031), in respect of means of sales through distance contracts causes challenges. Associations or operators engaged in electronic commerce would currently evidently fall within the realm of the Regulation, but its scope should not extend further. We believe that, for the supply of seeds and plants to final users, there sh
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Response to Revision of the plant and forest reproductive material legislation

7 Dec 2023

The proposed regulation on the production and marketing of plant reproductive material endangers both the conservation and utilisation of cultivated plant diversity, and its production and marketing by smaller operators who produce diverse PRM adapted to the needs of farmers in different local growing conditions. Problematically, the proposal significantly extends the scope of regulation, both in terms of the types of transfers of PRM and the range of actors that are affected. For the smallest operators, the regulatory burden is so high that it would push many to cease their work with diversity or move into illegality. Positive derogations are foreseen for the marketing of PRM to home gardeners and of conservation varieties to farmers. It is particularly welcome that seeds can be sold to home gardeners without compulsory variety registration and production standards, and newly developed varieties can be sold under the conservation variety regime without quantity or regional limits. However, the provisions for gene banks and seed saver networks are too restrictive, failing to take account of the fundamental differences between conservation on the one hand and commercial activities on the other. Thus, the proposal goes against the obligations of the EU and its member states under the Convention on Biological Diversity and the International Treaty on Plant Genetic Resources for Food and Agriculture. It also fails to implement the human right to exchange and sell farm-saved seeds and other PRM, which was enshrined in the 2018 United Nations Declaration on the Rights of Peasants and Other People Working in Rural Areas (UNDROP). We call for an exemption from scope for the transfer of PRM for the purpose of its conservation and sustainable use, full implementation of the right to seeds under UNDROP, and proportionate regulatory cost for the smallest operators through an exemption to Articles 41 and 42. The proposal should also include measures to prevent the misappropriation of traditional varieties, and not make any changes to the EU Organic Regulation 2018/848 to provide legal certainty for organic breeders. It also should also allow the import of PRM from derogatory regimes, and provide transparency on seed packets and in the variety register on intellectual property rights, especially patents, and breeding methods, to enable farmers and gardeners to make an informed choice.
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Meeting with Bert-Jan Ruissen (Member of the European Parliament, Shadow rapporteur)

4 Dec 2023 · Plant reproductive material

Meeting with Herbert Dorfmann (Member of the European Parliament, Rapporteur)

1 Dec 2023 · PRM

Meeting with Martin Häusling (Member of the European Parliament) and European Coordination Via Campesina and ARTEMISIA

28 Nov 2023 · Filmvorstellung "Seeds of Europe"

Meeting with Alexander Bernhuber (Member of the European Parliament)

14 Nov 2023 · NGT

Meeting with Norbert Lins (Member of the European Parliament, Committee chair)

7 Nov 2023 · PRM and FRM, NGTs

Meeting with Günther Sidl (Member of the European Parliament)

25 Oct 2023 · EU-Saatgutrecht

Meeting with Irène Tolleret (Member of the European Parliament)

20 Oct 2023 · Semences

Meeting with Herbert Dorfmann (Member of the European Parliament, Rapporteur)

21 Sept 2023 · PRM

Meeting with Isabel Carvalhais (Member of the European Parliament, Shadow rapporteur)

19 Jul 2023 · Production and marketing of plant reproductive material in the Union

Meeting with Martin Häusling (Member of the European Parliament) and European Coordination Via Campesina and

6 Jul 2023 · Teilnahme Veranstaltung zu Patenten und Neuer Gentechnik

Meeting with Sarah Wiener (Member of the European Parliament)

29 Jun 2023 · staff-only: Saatgut

Meeting with Martin Häusling (Member of the European Parliament) and European Coordination Via Campesina

8 Feb 2023 · Veranstaltung EU-Reform der Vermarktungsregeln für Saatgut: Welches Saatgut für einen gerechten Übergang zu agrarökologischen und nachhaltigen Lebensmittelsystemen?

Meeting with Anja Hazekamp (Member of the European Parliament)

22 Jun 2022 · Conference seed marketing reform

Response to Organic food: production and use of non-organic, in-conversion and organic seedlings

15 Sept 2021

ARCHE NOAH, association for the conservation and development of crop diversity, welcomes the goal of increasing the use or organic seeds in organic production. A step-by-step approach to phase out the wide-spread use of conventional plant reproductive material is a reasonable strategy to achieve this. The possibility for propagating non-organic plant reproductive material of rare and traditional varieties has to be maintained also in such a scenario, as they often come from e.g. private gardens to organic gardens and have to “become part of” organic production. For a full transition towards organic seeds more public funding for organic breeding activities is direly needed. In this context, we believe that the current proposal about seedlings ignites significant changes at a very short-notice, three months before the entry into force of the Regulation and would create too many practical problems to allow the transition in parts of the seedlings sector, potentially leading to less organic production. Since rare and locally adapted varieties are generally less available as certified organic seeds, let alone for the production of seedlings, this stringency might also threaten crop diversity in the short term, instead of creating the desired incentive to raise organic seed production, which we very much welcome. In the long-term, more organic seeds and heterogeneous material will definitely contribute greatly to the goals of this draft Delegated Act, along with the Farm to Fork and EU-Biodiversity strategy. Specific comments to the draft: - For annual crops, we generally welcome the notion that seedlings have to be produced at least one generation in organic conditions if they are to be sold as organic. However, this requires time, and seeds and seedlings for the next season have already been produced, and in many cases also labelled. The entry into force of the proposed Delegated Act should therefore be postponed for a year. - We are critical of yet another label, concretely the one proposed “may be used in organic production”, especially because end consumers are already confused with the varieties of labels on the market. If there are clear rules for derogations and a mid-term strategy for a transition to 100% organic seeds, we do not see the necessity for a new label, which adds bureaucracy. - The EU Commission and Member States should have the power to grant derogations in case of non-availability of organically produced seeds, at least for a transition period of five years, without losing the organic qualifier for all species and without the new label. Right now, rare and traditional varieties are indeed often not available with organic certification in larger quantities. A too quick transition could therefore reduce genetic diversity on EU fields and gardens. - Regarding trees: There is no definition of seedlings and cuttings there, and additionally no definition of growing season. Thus it is not clear, when the plant reproductive material and plant become organic as non-organic materials (especially scions) were used in the beginning. In the case of perennial crops, especially fruit trees, there are major problems with the availability of organic propagation material, as it is a highly specialized sector, but also because EU Plant Health rules make organic production of seedlings unfeasible. There is not a single producer of organic scions. Also seedlings/rootstocks are very rarely available from organic production. Due to the special challenges in this sector and the long life span of the material, products and the scion of trees should be considered organic after a maximum of one to two growing seasons grown in organic conditions, including the scions, as for them a mid-term transition to organic production is not realistic. Overall, we welcome the goal of the act. However, the current proposal might bring EU organic production further away rather than closer to achieving a transition toward organic seeds.
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Response to Rules governing the production and marketing of plant reproductive material of organic heterogeneous material

26 Nov 2020

As an organization dedicated to the saving, selection, production, breeding and distribution of a wide diversity of seeds and plant reproductive material of traditional or local landraces, heirloom cultivars, farmers’ selections, open pollinated populations, etc., we are directly concerned by the new concept of “Organic Heterogeneous Material” (OHM) in Regulation 2018/848. The draft delegated regulation has been substantially improved, both regarding its conformity to both the spirit and the letter of Regulation 2018/848 and its potential impact on the availability of seeds suitable for a diversified organic production and agro-biodiversity. As it does not impose excessive constraints anymore, we expect it will help many small entities like us to find a place on the seed market. In particular, we welcome the changes to the description of OHM and the various options left open for the generation of OHM. The removal of arbitrary numbers of generations under organic certification is in line with the provisions of Regulation 2018/848. These new provisions will allow us to produce and market plant reproductive material of OHM in a reasonable timeframe, provided that the incompressible organic production period under Annex II part I - point 1.8.1 is respected. Concerning quality of seeds lots, we are very satisfied that placing PRM with a lower germination rate on the market will be possible, provided that the effective germination rate is indicated on the label. Packaging and labelling rules have also been positively softened, by making a sound distinction between small packages and others, as it is the case in the horizontal legislation. The possibility to print the mandatory information directly on the package and to sell OHM in unmarked and/or unsealed small packages also recognises the limited resources of small operators. As regards traceability, the obligation to keep records on upstream suppliers only is much more realistic than previous drafts. Finally, maintenance requirements are now adapted to the evolutionary nature of heterogenous material. Apart from these complimentary comments, we also have a few additional remarks, where we have identified some errors or a lack of clarity: (i) in Article 2 (3) and the definition of ‘parental material’, the term ‘crossing’ should be removed as crossing activities are not mandatory and parental material can also serve for reproduction of OHM; (ii) in Article 4 (2) (a) and (b): the references made to the definition of OHM in Regulation 2018/848 should be Article 3 (18) and not Article 4 (18); (iii) in Article 5 (2), we should have the choice of either retracing the parental material, or the history of the material, especially for OHM falling under 4.2.C (“any other technique used for breeding or production”) In addition, it is not clear if controls are to be undertaken by seed competent authorities or by organic competent authorities nor if controls will be systematic or only random or risk-based, as the risk-based nature of controls is only mentioned in Whereas (7), and not in Articles 3 and 9. Finally, concerning Article 4 (2) (b), there is no legal basis for excluding the material eventually falling under the scope of Directives 2008/62/EC and 2009/145/EC, as nothing in Regulation 2018/848 is aimed at excluding conservation varieties and varieties with no intrinsic value for commercial crop production from also being capable of meeting OHM criteria. The decision to place a material under such or such regime, as could be the case with medicaments and the different legal regimes applicable to them, should be left with the operator.
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Response to Farm to Fork Strategy

16 Mar 2020

We welcome the approach to develop a coherent farm to fork strategy. Especially in the context of the current biodiversity and climate crises, but also in light of the need to produce healthier food for healthier diets, we need immediate ambitious policy changes. The strategy must deliver a strong vision for a fundamental transformation of the European food system, including legally binding goals, concrete measures and sufficient budget. This concerns most importantly the Common Agriculture Policy. But research & innovation, health, and trade policies also have to shift towards fundamentally sustainable models. The overall strategy should lead to ambitious goals in relevant policy processes, such as the European Biodiversity strategy. This strategy presents a unique opportunity for a shift towards an ecological, socially just and more democratic system. It should also support farmers in the necessary transition towards the new, knowledge-intensive model. The roadmap strongly emphasizes the climate crisis, which undoubtedly is one of the largest threats to our ecosystem and for future generations. However, at the same time, the biodiversity crisis has major ramifications for European society and therefore has to a focal point of the strategy. Moreover, the climate and biodiversity crises are linked: biodiversity loss contributes to the climate crisis, but strong action on biodiversity can also mitigate the climate crisis. Thus, agrobiodiversity and seed diversity have to be at the core of the new food system: - Diverse, organic and locally adapted seeds and plant propagating material have the potential to contribute significantly to halting the dramatic biodiversity loss which threatens food systems - Locally adapted seeds and organic heterogeneous material are less dependent on external inputs, more resilient in the face of climate changes, and not dependent on mineral fertilizer and synthetic pesticides. We do not know what pests, diseases, climatic changes and other challenges agriculture will face; it is therefore imperative to conserve and develop the full breadth of genetic diversity of agricultural plants to ensure we have the tools to ensure our future food security and reach ambitious reduction targets for pesticides and fertilizers - Crop diversity forms the basis of a healthy, sustainable and primarily plant-based diet, and can facilitate the development of regional supply chains and direct marketing, thus contributing both to climate, health and regional development goals Proposed goals and measures - The explicit goal to stop genetic impoverishment in European agriculture. Moreover, ambitious and measurable biodiversity and climate goals, as well as pesticide and fertilizer reduction targets. This includes stopping all policy measures which run contrary to those goals - A radically transformed CAP with clear biodiversity and climate goals at its core, while supporting farmers’ incomes in the transition and for the additional service such a farming model provides to societies - A significant research & innovation focus on organic breeding activities - The (potential) reform of European seed marketing laws has to contribute significantly to more biodiversity, by liberating seeds from overregulation, making it easier to market locally adapted and historic seeds as well as innovative populations, and promoting free exchange of seeds. The policy framework urgently needs to make space for smaller actors to deliver locally adapted solutions on the currently very concentrated seed market - Patents on conventionally bred seeds threaten breeding activities and crop diversity – they finally have to be stopped - A clear goal to increase the organic area in Europe - Current food and biodiversity safety standards must not be weakened by the strategy or trade agreements, including the laws for genetically modified organisms A more detailed version of our comments, including references, is attached.
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Response to EU 2030 Biodiversity Strategy

20 Jan 2020

ARCHE NOAH setzt sich für die Erhaltung und Entwicklung der Kulturpflanzenvielfalt ein. Wir begrüßen die Entwicklung einer EU-Biodiversitätsstrategie 2030. Gleichzeitig weisen wir darauf hin, dass die Ziele der Strategie 2020 deutlich verfehlt wurden, der Biodiversitätsverlust ist immer noch dramatisch. Daher ist es sowohl für den Erhalt der Biodiversität als auch für die Glaubwürdigkeit der EU-Biodiversitätspolitik zentral, für den zukünftigen Zeitraum nicht nur ambitionierte Biodiversitätsziele vorzulegen, sondern diese auch mit starken und ausreichend finanzierten Maßnahmen zu verbinden und die Ziele auch zu erreichen. Diese müssen in allen relevanten Politikbereichen verankert und biodiversitätsgefährdende Entwicklungen gestoppt werden. A) - Die Problemdefinition sollte nicht nur die „Natur“, die „aufgrund menschlicher Aktivitäten stark unter Druck gerät“ erwähnen, sondern auch Kulturpflanzenvielfalt, die seit jeher auf menschliche Aktivitäten angewiesen ist und sich aufgrund einer immer stärker industrialisierten Landwirtschaft drastisch verringert hat B) - Berücksichtigung aller Ebenen für Biodiversität in der Strategie (genetische, Arten-, Ökosystem-Ebene) - Das Zusammenspiel der Biodiversitäts- und der Klimakrise muss besonders berücksichtigt werden. Kulturpflanzenvielfalt leistet durch lokale Anpassung und Resilienz einen wichtigen Beitrag zur Abmilderung beider Krisen. Die Erhaltung, nachhaltige Nutzung und Entwicklung genetischer Ressourcen (durch Community Seed Banks, partizipative Züchtung, aber auch durch Züchtungsunternehmen), und die Diversifizierung von landwirtschaftlichen Produktionssystemen sind zentrale Bestandteile resilienter Agrar- und Ernährungssysteme in Zeiten der Klimakrise - Ambitionierte Maßnahmen gegen das Bestäubersterben sind notwendig für den Wiederaufbau von Ökosystemen und zentral für die Ernährungssicherheit - Die Erhaltung und nachhaltige Nutzung von genetischen Ressourcen und Agrobiodiversität ist zentral, inklusive seltener Kulturpflanzen und Nutztierrassen. Agrobiodiversität bezieht sich bei Nutzpflanzen insbesondere auch auf die genetische Variabilität bzw. Varianz und deren Vielfalt, was sowohl Unterschiede zwischen verschiedenen Arten als auch variierende Ausprägungen innerhalb einer Art betrifft. Daher kommt der Förderung von samenfesten Sorten eine besondere Bedeutung zu - Eine Ökologisierung der Gemeinsamen Agrarpolitik ist notwendig, aber auch andere Politikfelder (u.a. Klima, Gesundheit, Wirtschaft) müssen in Bezug auf ihre Auswirkungen auf Biodiversität überprüft und angepasst werden - Eine etwaige Reform des Europäischen Saatgutrechts muss einen signifikanten Beitrag für mehr Biodiversität leisten, indem seltenen Sorten der Marktzugang erleichtert wird. Ebenso bedrohen Patente auf konventionelles Saatgut die Züchtungsarbeit und damit die Kulturpflanzenvielfalt C) - Erfolgreiche Strategien zur Erhaltung der Biodiversität werden stark auch auf lokaler/regionaler Ebene entwickelt, eine offene Konsultation (statt einer die nur auf europäische/nationale Stakeholder fokussiert) ist daher wichtig - Zusätzliche Informationsgrundlagen: Bestäuber- und Agrobiodiversitätsindikatoren sollten erhoben und ihre deutliche Verbesserung als Ziele integriert werden. Ein Agrobiodiversitäts-Index ist ein wichtiger Indikator für biologische Vielfalt und seine Verbesserung ein wichtiger Beitrag zur Abmilderung der Biodiversitätskrise. Gemessen werden sollen die Vielfalt auf Betriebsebene und zwar sowohl die inter- als auch die intraspezifische Diversität. Indikatoren (z.B. Last et al.[1]), inkludieren die Anzahl der tatsächlich auf landwirtschaftlichen Betrieben verwendeten Nutzpflanzenarten, Kulturpflanzensorten, der Art des verwendeten Sortentyps (z.B. Land-, Populationssorten), und der Nutztierarten und -rassen [1] Last, L. et al. Indicators for the on-farm assessment of crop cultivar and livestock breed diversity. Biodivers Conserv 23, 3051–3071 (2014)
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Response to Rules on plant passports and criteria for professional operators issuing plant passports

19 Dec 2018

ARCHE NOAH welcomes the mandatory development and publication of electronic guidance document for future authorised professional operators, containing notably information on the biology of pests, the signs of presence, available treatments and content of emergency plans. We would however stress that, in order to ensure a more sustainable vision of plant health, it could also be useful to include known preventive measures and good practices that can be adopted by operators before any outbreak. In the summary of the delegated act, it is mentionned that it will determine the modalities of the exception to issue plant passports for small quantities to final users. However, there is no provision in the draft text addressing this issue. We deeply regret such omission and reiterate that protective measures ought to be proportionate to the danger posed by given movements and transactions, especially when faced with non quarantine regulated pests. We would welcome any explanation on the absence of provisions on this issue in this particular delegated act, and the future course that will be taken in this regard.
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Response to Evaluation of the CAP measures applicable to the wine sector

7 Dec 2017

As Arche Noah, a seed savers association dedicated to the conservation and sustainable crop genetic diversity, including in wine grape varieties, we very much welcome the evaluation of CAP measures applicable to the wine sector, especially with regards to its environmental performance. We eagerly await the in-depth assessment of the effectiveness, efficiency, coherence, relevance and EU added value of certain specific rules regarding wine production. We think that the specific policy instruments outlined in the roadmap should also be assessed in view of the general sustainability goals pursued by the CAP. As noted by the Commission services in the analysis of the roadmap’s context, rules pertaining to the authorized vine varieties are considered to contribute to a “wine regime that preserves the best traditions of the EU wine production”. We believe that the current prohibition to cultivate direct producer wines and associated wine grape varieties, in the likes of Noah, Herbemont, Clinton, Isabella, Uhudler, Vino Barrantes or Fragolino (amongst others), is disproportionate vis-à-vis other goals pursued by the CAP. It does not preserve the best traditions of EU wine production, but in essence destroys a great number of local and regional traditions. This particular measure should therefore also be assessed in light of other objectives pursued by the policy, namely rural development, the promotion of rural life and “balanced territorial development”, but also the improvement of European agriculture’s environmental performance. It should be checked whether such variety authorisation and the parallel wine classification system contribute to the sustainable management of natural resources. Indeed, the current classification system, which is considered to be an instrument contributing to the quality and traceability of wine products, should also be assessed in view of the CAP’s environmental performance. As direct producers and associated hybrids bear higher levels of disease resistance compared to other varieties widely in use, they are primordial tools to achieve the CAP’s ambitious sustainability goals, especially in a sector that remains one of the biggest consumers of plant protection products, which are known to harm people, animals and the environment. The current wine classification system unfortunately does not allow these promising hybrids to be marketed as quality wines, thereby severely undermining the chances of a pesticide-free and therefore more sustainable future for European viticulture. We therefore ask the Commission services to assess the coherence of these specific instruments with the territorial and environmental aspects of the CAP. Last but not least, with regards to the consultation strategy, we would like to see the Commission services reach out directly to a wider range of civil society actors, in addition to the online consultation that will be launched, and the discussions that will surely be held within the appropriate civil dialogue group.
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Meeting with Ladislav Miko (acting Director-General Health and Food Safety)

15 Apr 2015 · Seeds

Meeting with Vytenis Andriukaitis (Commissioner) and

30 Jan 2015 · The Food Chain, Innovation and Challenges, Food Information to Consumers, Nutrition, and Food Waste, Animal Health, Animal Welfare and Plant Health

Meeting with Vytenis Andriukaitis (Commissioner) and

6 Jan 2015 · Plant Reproductive Material Proposal