European Consortium for Organic Plant Breeding
ECO-PB
The European Consortium for Organic Plant Breeding (ECO-PB) was founded in 2001 with the aim of promoting organic plant breeding and building up an independent expertise.
ID: 329523333979-86
Lobbying Activity
Response to Revision of the plant and forest reproductive material legislation
5 Dec 2023
We welcome the improved flexibility with regard to easier registration of new cultivar types (heterogeneous material, traditionally grown and newly bred conservation varieties and organic varieties), the exclusion of direct marketing to non-professional end-users, allowance of in-kind seed exchange among farmers. However the proposal should be improved in following aspects: Commercialization of PRM of heterogeneous material should be possible for all crop species as was layed out in the Organic Regulation 2018/848. We do not agree to amendment (11) to exclude open pollinated out-crossing species and amendment (29 and 54) to exclude fodder crops as suggested by the rapporteur. Heterogeneous Material are not the same as Synthetic varieties or open pollinated varieties which fulfil DUS testing. Heterogeneous material is characterised by its high level of phenotypic and genetic diversity, and its dynamic nature to evolve and adapt to certain growing conditions. We are asking not to change of the EU Organic Regulation 2018/848. We risk to lose the granted right to commercialize the OHM of any crops species, and risk that the definition of the organic breeding is changed without the consultation of organic breeders. The mandatory VSCU testing of all crops, including vegetables and fruits will cause additional burden and costs for breeders. Therefore we are rather voting for the option of a voluntary post-registration VSCU testing in the different geographic regions under sustainable on-farm conditions. Sustainability can only be assessed in a system level and not be based on an individual trait or gene. This systems approach can be achieved in VSCU testing if the value for sustainable cultivation and use is actually tested under sustainable farming systems, e.g. organic farming or agroecological farming with low external inputs (low fertilizer, little irrigation, no pesticides, no seed treatment, etc.). Under such testing system the varieties will differentiate for disease and pest resistance, water and nutrient use efficiency. For organic varieties suitable for organic production bred in organic breeding programs the VSCU testing must be conducted under organic farming conditions according to EU organic regulation 2018/848 and not on conventional fields without pesticide or less fertilizer. Organic farmers and farmer organisations can support national authorities in finding suitable fields for conduction of organic VSCU trial or even conduct such trials under official supervision. It should be included in the definition of conservation varieties, organic varieties, heterogeneous material that these cultivar types should not be derived by genetic engineering (as defined Directive 2001/18/EC) nor through novel genomic techniques (NGT1, NGT2, as defined in the NGT legislation 2023) and must not be covered by patent protection which would restrict breeders exemption and farmers privilege.. Work of in situ and ex situ conservation of genebanks should be out of the scope of the regulation. In kind exchange of farmers should be allowed for all types of PRM not only for seed Administrative burden for actors should be minimized. Multi actor stakeholders (breeders, seed producers, farmers, examination offices, researchers etc.) should be involved in the development of secondary regulations to make sure that the delegated and implementing acts are precise, broad-based and feasible and meeting the needs of the sector. All cultivar types (varieties, conservation varieties, organic varieties, heterogeneous material) shall be made electronically available on the EU Plant variety portal to increase transparency of the available PRM. To increase transparency for farmers and consumers it shall be added in Annex VII all patents that are related to released varieties in the EU as well as the applied breeding methods and technologies (e.g. cell fusion, gene editing, random mutagenesis, etc.)
Read full response27 Nov 2020
on behalf of the European Consortium for Organic Plant Breeding (ECO-PB):
We very much appreciate the open consultation procedure during the development of the delegated act on production and marketing of organic heterogeneous material and the present opportunity to comment on it. We very much appreciate the present state of the delegated act and especially the exclusion of field inspection requirements for the propagation of OHM under Art. 6 (12). However, we want to raise 2 important points that still need some improvements:
1) terminology: throughout the whole text and the Annex “organic propagation material of organic heterogeneous material ” is used to avoid any confusion. This term “organic propagation material of OHM” is fully in line with the organic regulation 2018/848 Articles 6, 13, and 26 and the title of the present delegated act.
If the term is too long we propose “organic propagation material of OHM”
2. 2.) Clear definition of organic heterogeneous material:
The present draft of the delegated act misses a clear definition of organic heterogeneous material as it does not clearly explain the organic nature of organic heterogeneous material compared to organic reproductive material of non-organic heterogeneous material. The latter can be produced in just one year, if conventionally developed OHM is multiplied on a certified organic farm. Therefore, it is important to stress this in the description on the development or OHM. This unclear definition can be easily misused by producing and putting on the European market organic plant reproductive material of unfinished conventional breeding material. This could result that organic propagation material of non-organic heterogeneous material enters the market pretending that it is adapted to organic, which is not the case, it is just organic seed. The promise that OHM would be better adapted to organic farming systems and have a better capacity to adjust to climate change would be undermined.
Therefore it should be added under Art. 4 (2) :
“The material referred to in paragraph 1(b) may be generated for at least three years for annual crops and five years for biennial/perennial crops under organic production rules by one of the following techniques:”
Moreover it is important that no organic heterogeneous material is entering the market when breeding techniques are applied that do not comply with organic principles. This ensures the integrity and the traceability of the organic sector which is value and process based. For the development of organic heterogeneous material the same rules must apply as for defined for organic varieties suited for organic production in the Regulation (EU) 2018/848
Therefore, it need to be added under Art. 4(2)
“(c) any other technique used for breeding or production of organic heterogeneous material which complies with organic principles, and specifically respect the natural reproductive ability and the natural crossing barriers, and excluding technical interventions directly into the genome or an isolated cell, producing similarly diverse heterogeneous material as in (a) and (b). “
More detailed explanation you find in the attached file.
sincerely yours
Monika
Read full responseResponse to Action plan for the development of EU organic production
3 Oct 2020
The European Consortium for Organic Plant Breeding very much welcomes the ambition of the EU to reach 25% of organic farm land by 2030. To reach that goal we need to increase the production of organic seed of suited cultivars at least 6 fold. Therefore sufficient resources need be be made available to boost organic seed and plant breeding in Europe. This needs research and implementing actions, novel busines models and political and financial incentives for farmers and seed companies to produce organic seed and promote organic cultivar testing. Organic plant and animal breeding initiatives need to be promoted that refrain from genetic engineering tools to maintain integrity of the organic sector. Moreover, full transparency and traceability must be mandatory for all products derived from novel genomic techniques, independend of the changes of present GMO regulation which is presently under discussion.
Read full response