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Plantum

Plantum is the Dutch association representing companies in the plant reproduction material sector.

Lobbying Activity

Meeting with Auke Zijlstra (Member of the European Parliament)

16 Oct 2025 · Innovation in agriculture

Meeting with Gijs Schilthuis (Director Agriculture and Rural Development)

16 Oct 2025 · Sustainability agenda and new CAP

Meeting with Jessika Van Leeuwen (Member of the European Parliament)

15 Oct 2025 · Uitdagingen sector

Meeting with Christophe Hansen (Commissioner) and

15 Oct 2025 · Discussion on the role of breeding in ensuring a competitive and sustainable food system, with a focus on the relevance of new genomic techniques (NGTs) and sector challenges.

Meeting with Jeannette Baljeu (Member of the European Parliament)

15 Oct 2025 · NGTs

Plantum urges faster EU authorisations for treated seeds

13 Oct 2025
Topic — This consultation addresses the simplification of EU food safety and marketing authorisations.
Message — Plantum requests automatic mutual recognition of products authorised in one Member State. They also want to accelerate authorisation for green active ingredients and low-risk products.12
Why — Harmonisation and automatic recognition would provide faster market entry and regulatory certainty.34
Impact — National regulators would lose the ability to conduct independent safety assessments locally.5
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Meeting with Sylvain Giraud (Head of Unit Health and Food Safety) and Euroseeds

2 Jul 2025 · New developments in the breeding of potato varieties

Response to Amendment of protective measures against pests of plants

17 Jun 2025

Plantum, the Dutch association representing companies active in breeding, propagation, cultivation, and marketing of seeds and young plants, welcomes the opportunity to contribute to the public consultation on the targeted amendment of protective measures against pests of plants regarding Annexes IV and V of the Implementing Regulation (EU)2019/2072. Plantum supports the practical amendment of Annexes IV and V of Implementing Regulation (EU) 2019/2072 by adding numbering to the tables, allowing references to be made in the additional declarations. Plantum expects that full wording remains necessary for re-export. Plantum is deeply concerned about the scope for the additional declarations, especially material/seeds that are currently exempt from the RNQP-requirements. Plantum therefore requests a solution for such material. To clarify Plantums concerns about the scope, Plantum would like to once again draw the European Commissions attention to the input previously submitted by Plantum via the Have Your Say on the targeted amendment of the Plant Health Regulation (EU) 2016/2031 in December 2023. Please see the attached document.
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Meeting with Auke Zijlstra (Member of the European Parliament)

6 May 2025 · Innovation

Meeting with Auke Zijlstra (Member of the European Parliament)

2 Apr 2025 · Moldova

Response to Measures related to specific plant pests - Curtobacterium flaccumfaciens

27 Mar 2025

Plantum is the trade association for 300 companies in the breeding, propagation and cultivation of seeds and young plants in The Netherlands. Plantum would like to thank the European Commission for the opportunity to provide feedback on the draft Implementing Regulation (EU) on temporary measures to prevent the introduction into, establishment and spread within the Union territory of Curtobacterium flaccumfaciens pv. flaccumfaciens (Cff) (Hedges) Collins and Jones, and amending Implementing Regulation (EU) 2019/2072. Plantum would like to bring the following points to your attention and would like to make some suggestions to enhance clarity and ease of implementation. Plantum supports that if Cff would cause serious (economic) damage in seed production or bean cultivation, stronger mitigation measures should be taken. To our knowledge, Cff has not caused any serious issues in bean cultivation in recent years. The current approach is effective, and as far as Plantum is aware, only three reports of symptoms have been made in Europe in bean cultivation in the past 20 years1. Therefore, the sudden attention to the issue, the fact that tests are now detecting infections in crops that showed no symptoms1 2 while yielded excellent production, and the implementation of new measures, have taken the sector by surprise. Plantum would like to understand how the European Commission assesses whether these proposed measures comply with the principle of proportionality as stated in Annex II, Section II of the PHR. Companies producing bean seeds rigorously and continuously monitor the production fields for symptoms of pests. In addition, official field inspections are being carried out. These mitigation measures have shown to be effective, as no serious (economic) damage has been reported to our knowledge. We are also not aware of data showing that symptomless presence of Cff during bean seed production was transmitted by seed and led to serious damage, and thus economic impact, in bean cultivation. If it will be required to test plants for planting before export, sufficient time is needed for implementation. It involves a significant capacity demand. The EURL does not prescribe a molecular test for CFF as a detection test. Therefore, Plantum requests that the text be adjusted to align with the EURL's description. Suggestions 1. Plantum suggests amending Annex Amendment of Implementing Regulation (EU) 2019/2072, 74.1 and to add the following in the official statement under (c), point (iii): "Only in the case of symptoms of the specific pest, prior to export a representative sample of the plants for planting has been tested using appropriate methods and found free." 2. Plantum suggests amending Annex Amendment of Implementing Regulation (EU) 2019/2072, 74.1. In the official statement under (c), point (iii) and under (d), A molecular test does not need to be prescribed. "Molecular" can be replaced with "appropriate methods." 3. Plantum suggests amending Annex Amendment of Implementing Regulation (EU) 2019/2072, 74.1. To clarify that options a-c also refer to seed, In the official statement under (d), add : Only for seeds or ; Additionally for seeds instead of In case of seeds 4. Plantum suggest for article 4: Article 4 shall apply from six months after the date of entry into force of this Regulation. 5. Plantum kindly requests examples of the full additional declaration that third countries need to state on the phytosanitary certificates. In this way, the risks of having delays due to misunderstanding of the expected declarations for exports into the EU are minimized. We thank, in advance, the European Commission and its Member States for taking these suggestions into account. 1 https://gd.eppo.int/taxon/CORBFL/distribution 2 https://apsjournals.apsnet.org/doi/abs/10.1094/PDIS-01-25-0172-PDN
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Plantum urges EU to strengthen plant variety rights protections

13 Mar 2025
Topic — The European Commission is evaluating current intellectual property rules for new plant varieties.
Message — Plantum calls for stricter enforcement of farm-saved seed rules and a clearer framework for determining essentially derived varieties. They also suggest extending protection durations and establishing specialized courts to harmonize the system.123
Why — Stronger intellectual property rules would help breeders recover high costs and protect biotechnology innovations.45
Impact — Farmers using saved seeds would face tougher enforcement and stricter reporting obligations.6
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Plantum urges practical labelling for small vegetable seed packages

31 Jan 2025
Topic — EU consultation on updating labelling requirements for plant protection products.
Message — The organization requests the option to provide safety phrases on accompanying documents rather than labels for small seed packages. They also suggest removing technical dust measurements that farmers cannot practically monitor or verify.12
Why — This would reduce technical burdens and simplify labelling for small packages.3
Impact — Environmental interests are harmed if specific safety and weather restrictions are removed.4
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Meeting with Bert-Jan Ruissen (Member of the European Parliament)

9 Dec 2024 · Diner meeting

Meeting with Jeannette Baljeu (Member of the European Parliament)

23 Oct 2024 · EU legislation relevant for plant breeders

Meeting with Ton Diepeveen (Member of the European Parliament)

23 Oct 2024 · Prioriteiten Plantum mandaat 2024-2029

Meeting with Ingeborg Ter Laak (Member of the European Parliament)

22 Oct 2024 · Plantum Dinner

Meeting with Ton Diepeveen (Member of the European Parliament)

15 Oct 2024 · Kennismakingsgesprek

Meeting with Auke Zijlstra (Member of the European Parliament)

18 Jul 2024 · Innovatie

Response to Targeted amendment of the Plant Health Regulation

29 Dec 2023

Plantum, the Dutch association representing companies active in breeding, propagation, cultivation, and marketing of seeds and young plants, welcomes the opportunity to contribute to the public consultation on the targeted amendment of the Plant Health Regulation (EU) 2016/2031. Plantum represents over 300 companies involved in seeds and young plants, boasting an export volume of 4 billion euros in 2022. A significant part of this volume includes the (re)-export of seeds produced by subsidiaries or professional seed producers both within and outside the EU. These seeds undergo processing, quality control, and packaging in the Netherlands before being marketed worldwide to professional operators. This process involves importing 'raw' seeds into the EU, where they undergo processing (cleaning, treatment), quality control (including testing), and packaging in a central hub in the Netherlands prior to sale to professional operators both within and outside the EU. These 'raw' seeds, when imported or moved within the EU, fulfill the requirements for quarantine organisms as stated on the phytosanitary certificate. One of the amendments concerns regulated non-quarantine pests (RNQPs). RNQPs, present in the EU territory, were previously regulated under the marketing directives. The requirements for RNQPs are intended to protect the professional operator from unacceptable economic impact during the cultivation of crops. And feasible and effective measures available to prevent RNQPs on plants for planting, including seeds. Often, (some of) these measures are applied in the central hub in the Netherlands. We understand the proposed amendment regarding the declaration on the phytosanitary certificate for RNQPs for seeds ready to be marketed to the professional operator. However, we have concerns regarding 'raw' seeds, in other words, seeds that do not yet fulfill all the requirements for pre-basic, basic, or certified material, seed or seed potatoes, or standard or CAC material or seed. Processing, cleaning, treatment, etc., which can be measures to prevent the presence of RNQPs on the seeds, often take place in the central hubs in the Netherlands. This method has been fit for purpose for decades, and changing it would fundamentally alter the regulation. Currently, according to Article 37, paragraph 4 of the PHR, and in conjunction with Article 6 of (EU) 2019/2072, there is an exception for meeting the requirements for RNQPs if, according to one of the Marketing Directives, the marketing requirements do not have to be met. The plants for planting then do not have to meet the requirements for RNQPs, but they must meet the requirements for quarantine pests. The marketing directives are also currently under revision to become a regulation. In the draft regulations on the production and marketing of plant reproductive material (PRM), Article 79 proposes to amend Article 37(4) of the PHR and delete all references to the marketing directives. This would mean that all exceptions currently existing for meeting the RNQP requirements would no longer apply (with the exception of ornamental plants, which are not part of the revision of the marketing directives). We see this as a major change and disagree with it. We request that exceptions for meeting the requirements for RNQPs for plants for planting not ready to be sold to professional operators remain as currently in Article 6.3 of (EU) 2019/2072. It is very unclear what the consequences of the proposed changes will be because the PHR is being changed simultaneously in two places (in this amendment and in the Regulation on Plant Reproductive material). And the question arises as to what the (legal) consequences will be if one of the proposed changes is not implemented or if they do not take place simultaneously. We further object to an implementation period of 6 months. This will be too short for third country NPPOs to implement the proposed changes. We request a period of 2 years.
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Response to Revision of the plant and forest reproductive material legislation

6 Dec 2023

Plantum is the Dutch association for companies in the breeding, propagation and cultivation of seeds and young plants. The membership consists of over 200 companies, the majority SMEs. With an export value of 4 billion euros in 2022 and more than 18,000 employees in the Netherlands alone, the seeds and young plants sector is very important the European economy and crucial for food security. Seeds and young plants form the basis of every harvest. The experience of our members is that the current PRM Marketing Directives generally work well for the goals for which they were developed: monitoring the identity, quality and plant health of Plant Reproductive Material that is made commercially available on the European market. Overall, the proposed changes by the Commission are far reaching and quite drastic. We urge that the Commision carefully considers sustainability goals and the appropriate means to achieve these goals in order to not harm to the availability and diversity of varieties and quality PRM on the market. There are no 'quick wins' without serious drawbacks. Atttached you will find a more elaborate reaction to the proposal.
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Meeting with Annie Schreijer-Pierik (Member of the European Parliament) and Land- en Tuinbouw Organisatie Nederland and Glastuinbouw Nederland

21 Nov 2023 · Dutch agriculture sector

Plantum Urges Scientific Flexibility For New Genomic Plant Techniques

27 Oct 2023
Topic — The European Commission is proposing a new legal framework for plants produced using genomic techniques.
Message — Plantum requests modification limits be based on science rather than arbitrary numbers. They advocate counting modifications based on the monoploid genome and excluding off-targets. They also suggest moving products without detection methods into Category 1.123
Why — This would lower compliance costs and ensure polyploid crops remain commercially viable.45
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Meeting with Annie Schreijer-Pierik (Member of the European Parliament)

7 Mar 2023 · Dutch agriculture sector

Meeting with Annie Schreijer-Pierik (Member of the European Parliament) and Glastuinbouw Nederland and Coöperatieve Vereniging Bionext UA

22 Jun 2022 · Event on organic horticulture

Response to Amendment of Annex II of Regulation (EC) No 1107/2009 to specify approval criteria for microbial active substances

23 Nov 2021

Geachte heer/mevrouw, Plantum, de Nederlandse branchevereniging voor bedrijven in plantenveredeling en opkweek van jonge planten, dankt uw voor de mogelijkheid om feedback te geven op de publieke consultatie ‘gewasbeschermingsmiddelen – Goedkeuringscriteria voor werkzame stoffen in (toelatings)verordening EC 1107/2009’. Onze leden zijn dag in dag uit bezig met kruisen en selecteren om nieuwe plantenrassen te vinden die oplossingen bieden voor voedselzekerheid, gezondheid, duurzaamheid, vergroening en klimaatsverandering. In de zaadproductie en –behandeling wordt gezorgd voor kwaliteit van het zaad en een goede start voor de zaailingen en jonge planten. Nederland is groot in groentezaden maar ook bij voorbeeld in veredeling van sierteeltproducten, (poot-) aardappelen en grassen. Plantum vindt het positief dat de Europese Commissie erkent dat gewasbeschermingsmiddelen op basis van microbiële werkzame stoffen anders zijn dan middelen op basis van chemische stoffen; dat ze daarom een andere (betere, specifiekere) beoordeling behoeven; en dat de EC de wetgeving wil aanpassen om toelating van de microbiële middelen te versnellen en te vereenvoudigen. We hebben namelijk met spoed meer van deze middelen nodig, in de overschakeling naar weerbare teelten (Uitvoeringsprogramma Gewasbescherming 2030) en nu meer en meer chemische oplossingen wegvallen, waardoor het steeds moeilijker wordt voldoende en hoogwaardig plantaardig uitgangsmateriaal (zaden, knollen, stekken, jonge planten etc) te produceren. Het bedrijfsleven actief in de ontwikkeling en het op de markt brengen van microbiële middelen heeft sterke behoefte aan duidelijke regelgeving, zodat lange termijn investeringen op dit vlak meer zekerheid voor de toekomst zullen geven. Nu staat deze onzekerheid de behoefte/durf om er in te investeren vaak nog sterk in de weg. Vereenvoudiging (weglaten van onnodige eisen) kan er voor zorgen dat deze bereidheid toe zal nemen en zal het juist ook voor kleinere bedrijven, waar wij veel nieuwe ontwikkelingen zien, eerder haalbaar maken om in toelatingen en markttoegang te investeren. Uiteraard moeten ook de microbiële middelen wel zorgvuldig getoetst blijven worden op eventuele risico’s voor mens, dier en milieu. De aanpassing van de wetgeving moet dit ondersteunen, waarbij oog moet zijn voor het wezenlijk anders zijn van microbiële middelen en hun functioneren in een agro-ecosysteem, waardoor een aantal aspecten die regulier bij de beoordeling van chemische middelen aan de orde zijn, mogelijk minder relevant zijn. Deze aanpassing van de criteria zou mede tot doel moeten hebben om voldoende microbiële opties beschikbaar te krijgen om weerbare teeltsystemen voor de productie van plantaardige uitgangsmateriaal te ondersteunen. Het ligt niet direct in onze expertise om te beoordelen of de huidige voorstellen het doel ‘vereenvoudiging en versnelling’ bereiken. Het lijkt er echter op dat door het specifieker maken van de eisen voor microbiële middelen soms juist weer sprake kan zijn van verzwaring van de eisen. Daarbij is voor ons ook de vraag of de extra datavereisten, die sterk op die van de chemische beoordeling gebaseerd lijken, uit oogpunt van risico’s allemaal echt nodig zijn. We pleiten daarom voor een aanpassing van de regels die echt rekening houdt met het essentieel andere, biologische i.p.v. chemische, karakter van microbiële middelen. Plantum heeft zich gecommitteerd aan de doelstellingen van de Farm-to-Fork Strategie en het Nederlandse Uitvoeringsprogramma Gewasbescherming 2030, met doelen voor weerbare rassen en weerbare productie van uitgangsmateriaal, ten behoeve van weerbare teelten. We hebben daarbij de ondersteuning van gewasbeschermingsmiddelen op basis van microbiële werkzame stoffen dan ook hard nodig. In dat kader wil Plantum benadrukken dat voor het behalen van die doelen in 2030, het zaak is vaart te maken met aanpassing van de regelgeving voor de toelating van zulke middelen.
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Response to Organic food: production and use of non-organic, in-conversion and organic seedlings

15 Sept 2021

Gouda, 15 September 2021 Subject: Plantum input – Organic food production and use of non-organic in-conversion and organic seedlings Dear sir/madam, Plantum, the Dutch sector organisation for seeds and young plants, represents circa 350 companies among which breeding companies and plant nurseries that are producing organic seeds and young plants. Plantum is reluctant of the proposal to ensure the integrity of organic products by prohibiting derogations for using non-organic seedlings in organic crops that have one growing season. Organic certification is a certification of practises and products that are produced under organic conditions so that they can be sold with a certificate that declares conformity to standards of working. All plants start from seed, for organic preferably certified organic seeds, produced under organic conditions. The only reason for a derogation is lack of availability of certified organic seed. The use of conventional seed in the organic sector is never the preferred choice and only possible with a derogation. Currently, growing young plants from seed is the first step in the cultivation chain and by producing them under organic conditions the young plants can be certified as organic. In the vegetable and fruit sector often the production of young plants is done by specialized companies (plant nurseries/young plant growers) but this can also be done by the grower of the end-products directly. The new proposal leads to an unfair disadvantage for young plant growers: The grower that produces fruit or vegetables under organic conditions will have his end-products certified even if the plants these products are grown on are originating from non-organic seeds as long as the grower has the appropriate derogation and has grown the young plants from the non-organic seeds him/herself under organic conditions. The same non-organic seeds with the same derogation grown by the plant nursery will lead to a product to be marketed: the young plant that cannot be certified as organic. Therefore the young plant grower is the only party in the entire production chain that suffers a heavy consequence from the current proposal; the seller of the non-organic seed can still sell the same seed, the grower can still grow an organically certified vegetable etc., but the young plant grower cannot. No matter his effort and conformity to organic standards in his company practise, his product will not be certifiable. It is like taking away his licence to produce. Although it is a good idea to keep working towards the use of only certified organic seeds and young plants in organic production, this delegated act will not contribute to that goal and will introduce an unfair disadvantage to a highly specialized and often necessary step in the entire organic production chain. It will disincentive the plant nurseries/ young plant producing companies to engage in organic production. We remain at your disposal should you have any further questions. Kind regards, Niels Louwaars Managing director
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Response to Revision of the plant and forest reproductive material legislation

8 Jul 2021

Plantum is the Dutch association for companies in the breeding, propagation and cultivation of seeds and young plants. We represent 350 members who work in agriculture, horticulture, propagation and floriculture both conventional and organic. With an export value of 3.6 billion in 2020 and more than 18,000 employees in the Netherlands alone, the seeds and young plants sector means a lot for the European economy and for food security. Seeds and young plants form the basis of every harvest. In the attached file you will find the full feedback document. Here is an overview of some of the highlights: 1 The current marketing directives work well even when not harmonized. They are tailored to the unique needs of the crops and markets they are for. Changes to rules must respect these vital differences between crops and markets. 2 Thresholds to market, even when based on sustainability goals, limit biodiversity availability. To counter this; a. only regulate strictly necessary thresholds to market(quality, identity, plant health) and not sustainability goals that are better achieved by stimulating good practice and cultivation b. VCU trials for agricultural crops only, no VCU for vegetable and ornamental crops to maximize biodiversity c. no mandatory additional sustainability properties testing in VCU in agriculture; 3 Preserve current exemptions to market agricultural/ vegetable crops for ornamental use as well as preservation of registration based on officially recognized descriptions for ornamentals. 4 It should be made easier to market novelty PRM or PRM in different forms from traditional (like TPS or strawberry from seeds). This does not mean lower standards, but is aimed at being able to start somewhere creating new protocols for market access where this is now often extremely difficult. 5 We disagree with the statement that varieties for organic cultivation have to be characterized by high levels of genetic and phonotypical diversity. 6 Limiting cost for authorities and operators and striving to coherence in implementation is a good thing, but we don’t think the OCR is the tool to achieve these goals.
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Response to Extension of the duration of Community Plant Variety Rights for certain species

1 Apr 2021

Plantum is the Dutch association for companies active in breeding, cultivation and trade of plant propagation material in all crop sectors; agriculture, vegetables, ornamentals and fruits. Among our members are breeders of flower bulb species, asparagus, woody small fruits and woody ornamentals as well as young plant raisers of asparagus, woody small fruits and woody ornamentals. Plantum fully supports the proposal to extend the period of Community plant variety rights with 5 additional years for flower bulb species, Asparagus officinalis L. woody small fruits and woody ornamentals. Developing a new plant variety demands long-term and high investments. Plant variety rights (PVR’s) enable breeders to earn back these investments and to continue development of new varieties. Some species need a longer period to earn back their breeding investments than others. The specific nature of the indicated crops results in more time that is needed to build up commercial volumes of propagation material and as a result the holders of a plant variety right are unable to profit from the protection period as of from the beginning. The PVR-system rightfully acknowledges differences in earn-back period between crops as already an extended period of Community plant variety right protection is in place for trees, vines and potatoes for the same reasons. And due to the breeder’s exemption new varieties can be freely used for further breeding by others already during the course of the protection period. Breeders face great challenges to develop more sustainable and robust varieties which is a clear demand from growers and society. Breeding in most staple food crops has become highly advanced. In other species the technological developments are also gaining speed and breeding is becoming more targeted (e.g. with the help of marker-assisted-breeding and selection), but this is certainly not yet the case in all species. Especially in vegetatively propagated crops the plant genomes are complex and the introgression of characteristics such as disease resistances or drought tolerances demands long-term and high investments. A five-year longer protection period will be an important incentive for breeders that are active in species with a longer earn-back period to make the necessary investments. This proposal will certainly help to maintain the diverse breeding sector we have now in the EU and it will increase the delivery of better varieties to the European market for the benefit of everyone.
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Response to Contingency plan for ensuring food supply and food security

8 Jan 2021

Plantum, the Netherlands sector organisation for seeds and young plants, is very much in favor of formalizing a crisis response mechanism to minimize impact of crises on food security in the EU. Such a mechanism needs to take into account the various types and depths of possible crises causing stress to food security and should involve the basic structures that European food security is currently built upon. You will find the our comments in our letter in the attachment.
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Response to Action plan for the development of EU organic production

23 Oct 2020

Dear sir/madam, The Dutch sector for seeds and planting materials welcomes the goals set out in the Green Deal and in the Farm to Fork strategy. The sector is aware of the key role of plant breeding to provide robust varieties for sustainable farming systems, and guaranteed disease free planting materials as a healthy start of crop production. Plantum is the Dutch association for companies in this sector. We represent over 300 companies involved in plant breeding and production and trade in crop reproductive materials for agriculture and horticulture. A large share of those materials are traded internationally, including to other EU members states. We are pleased to have the opportunity to give our views on the consultation regarding the roadmap “Action Plan for the development of EU organic production”. The roadmap states the following: ..”An unbalanced development of organic production could hamper its profitability. The action plan must work as a lever to stimulate both the supply and the demand side. In this context, it is primordial to engage public administrations to lead the change and better use instruments at their disposal to promote a higher uptake and consumption of organic production”.. In this context we would like to stress that it is not just about supply to and demand for the end consumer, but also the supply of the necessary tools for the producer, notably the right seeds. Organic producers need high quality seeds of the varieties that are adapted to their production methods and their markets. Breeders may have to step up their efforts to develop more varieties that are fit for purpose for organic producers and in the seed production phase challenges may have to be overcome to have sufficient quantities of high quality organic seeds available in time. This indeed requires in our view support by the public administration in the following areas: Investment in innovation The production of healthy and high-quality seeds and planting materials under organic conditions is a challenge and so is the rapid expansion of such production to serve the Farm-to-Fork objectives. At the same time, the quality requirements of organic producers, particularly with regard to seed health, are very high. For a number of crops further public research towards seed transmitted diseases and organic seed production and treatment methods would be important. For example, breeding and seed research such as the research program ”Green Breeding” that operates since 2010, which was initiated by Plantum together with the organic sector, needs to be stepped up in order to better serve the needs for robust plant varieties that the organic sector needs. The European Commission may want to play a role in this. The program has proven to benefit organic cultivation but it also contributes to breeding towards the sustainability of conventional agriculture. Furthermore, when the Commission would consider varieties derived from breeding methods such as gene editing and cis-genesis as non-regulated GMO’s, this could pave the way for the organic sector to embrace such techniques that have a great potential to contribute to robustness of varieties, including under organic cultivation. Seed quality standards Quality standards assure farmers that the seeds they buy are of the right variety and of the quality that will yield a good harvest. This is valid for all farmers, irrespective of their cultivation method. The regulator has taken responsibility to make sure that the identity and quality of a seed lot can be trusted by the farmer. The goal to achieve 25% of agricultural lands to be certified organic should not lead to the use of low quality plant reproductive materials. The policy goal that sufficient organic produce is available on the European consumer market logically means that the public responsibility in conventional agriculture that seed quality and varietal identity are assured should also serve organic producers. Stimulating supply o
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Response to Intellectual Property Action Plan

13 Aug 2020

Plantum is the Dutch organisation for the plant breeding and plant reproductive material sector representing 350 companies, mainly SME’s. We are an official observer at the Community Plant Variety Rights Office (CPVO). Although plant variety rights (PVRs) are mentioned in the IP Roadmap under part A. there is no concrete mentioning under part B, the action plan. Nonetheless these IP-rights fit in perfectly with the aims of this IP roadmap. The increasingly robust varieties that EU breeders develop, contribute to a stronger and greener EU economy; our exports contributes significantly to the global production of food and flowers, which amounts to a considerable contribution of the EU to the UN Sustainable Development Goals. We therefore believe that also PVRs need to be included in initiatives of the IP road map. In particular we see the need for a specific action point regarding PVR’s as follows: “upgrade the system for IP protection” : to consider a revision and proper implementation of the Community Plant Variety Rights Regulation (2100/94/EC). The CPVR-Regulation provides for a very effective protection for plant varieties EU-wide and was therefore positively assessed by stakeholders during the evaluation of the CPVR Acquis in 2009. See: https://ec.europa.eu/food/sites/food/files/plant/docs/plant_variety_cpvr_eval_2008-9_report.pdf Nonetheless the report mentions several weaknesses and proposals for improvement. Especially the enforceability of the ‘agricultural exemption’ the need for improvement is reported. Unfortunately the CPVR Regulation was not amended accordingly. Efforts have been made by breeders to improve the FSS-royalty collection in several EU member states but the legal position of the CPVR-holder is still weak. It is our firm belief that commercial farmers that choose to replant seed of protected varieties and thus profit from the work of the breeder should be required to provide information and pay a remuneration. More recently a ruling by the ECJ in the Nadorcott case (19/12/2019) negatively affects the enforceability of the CPVR Regulation by limiting breeders to act against unauthorised use of their variety during the period of provisional protection, and to enforce rights against the unauthorised use of harvested material. Plantum therefore urges the Commission to reassess the effectiveness of the CPVR Regulation. A matter of implementation of the Regulation concerns the extension of the protection period from 25 to 30 years for specific species that require a longer development. This is already the case for trees, vines and potatoes. A proposal to add woody crops, flower bulb species and Asparagus to this category is under consideration of DG Santé. We hope this action point can be positively concluded in the near future. Finally, the concept of essential derivation requires further clarification, and the interface between PVR’s and patent rights needs improvement, for instance an alignment between the Unified Patent Court Agreement and national patent laws concerning the inclusion of the limited breeder’s exemption. We also like to bring forward another more general action point: - discover existing hurdles preventing effective IP enforcement litigation, especially by SME’s, and ways to reduce or overcome said obstacles. Which fits with two of the current action points; “Fight IP-theft” ii) by further clarifying how right holders, intermediaries and law enforcement authorities at national and EU level should act, co-operate and share data; “promote a Global fair play” - ii) take further steps to ensure that our businesses can effectively use their IP when operating world-wide We trust that the above issues warrant the inclusion of plant varieties rights in the IP roadmap.
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Response to Specific rules to release plants, plant products and other objects from quarantine stations

5 Nov 2019

Hereby the comments of Plantum, the Dutch association of companies active in breeding, propagation and sales of seeds and young plants. Thank you for giving the opportunity to give feedback on this draft regulation. We welcome this implementing regulation, but we have one comment on Article 4.2: The current description ' plants for planting shall be kept under the official supervision of the competent authorities for one or more complete cycles of vegetation, depending on the biology of the plant, ...' is too strict and an unnecessary burden. The time for these plants kept under official supervision of the competent authorities should depend on the phytosanitary risk. Therefor we recommend to change the text as follows: ' plants for planting shall be kept under official supervision of the competent authorities for an appropriate time, depending on the biology of the plant, ...." With kind regards, Marian de Beuze Plantum
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Response to Listing regulated pests, plants, plant products and other objects

9 Sept 2019

Please find the comments of Plantum, the Dutch association for seeds and young plants, in the attachement.
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Response to Listing high risk plants & plants for which a phytosanitary certificate is not required for introduction into the Union

31 Jul 2018

Plantum, the Dutch association for seeds and young plants represents about 350 companies active in breeding, tissue culture, production and trade of seeds and young plants in horticulture and agriculture. Plantum welcomes the opportunity to share its views about the Draft implementing act Listing High Risk Plants (Article 42 of Regulation (EU) 2016/2013. It is in the interest of the Plantum membership and the whole plant industry to reduce phytosanitary risks at import. However, we are of the opinion that the proposed list of high risk plants, lacks a proper technical justification for potential risks of an unacceptable level as required in the regulation (article 42 (3) EU 2016/2031) for seeds, in-vitro plants and unrooted cuttings of all the proposed genera and for the genera Ficus and Cycas. First, in all discussions about the creation of the text of the Plant Health Regulation and in particular article 42, it was a common understanding amongst the Commission and stakeholders that this article would mainly be applicable for plants for planting excluding seeds of shrubs or trees, grown outdoors or in the wild or plants that are known to host and provide a significant pathway for pests known to have a major impact. These criteria are described in Annex III part I and are applicable for plants for planting excluding seeds. Therefor we are very surprised that in the draft implementing act, seeds are not excluded. Seeds of the proposed genera do not fulfil the criteria set out in Annex III. We request to exempt seeds from all proposed genera. Some of the proposed plant genera are imported as in-vitro plants or as unrooted cuttings. ISPM 36 considers in vitro culture and unrooted cuttings as types of plant material with a low pest risk. In our view in-vitro and unrooted cuttings do not fulfill the criteria of Annex III. Therefor we request to exempt in-vitro plants and unrooted cuttings from all proposed genera. Second, we ask the Commission to reduce the list to genera with a known, major phytosanitary impact on plant species which are of major economic, social or environmental importance of the EU. In our view an import prohibition of plants that are produced under controlled circumstances and that have been regularly imported in large quantities for many years cannot be put on the list without strong evidence of their phytosanitary risk. Ficus and Cycas both have an important trade import volume for many years and until now, almost no interceptions or problems are known (see EUROPHYT). Can the Commission give a technical justification of the major phytosanitary impact of these two genera? Furthermore several companies (SME) with many employees within the EU and in third countries depend on the production and trade of these two genera. Putting these two genera on the list will have bankruptcy and unemployment of many employees within EU and in third countries as a result. For these reasons we request to exempt Ficus and Cycas from the list. The phytosanitary principles for the protection of plants and the application of phytosanitary measures in international trade (IPPC, ISPM 1) describes that contracting parties of the IPPC shall only apply the least restrictive phytosanitary measures that are consistent with the pest risk involved, with minimal impact and that are technically justified. We ask the Commission to review the provisional list of high risk plants and take our comments into account.
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Response to Commission Delegated Regulation on the methodology for risk assessments of invasive alien species

21 Dec 2017

To whom it may concern. Please find enclosed the comments of Plantum, the Dutch association for the plant reproduction material sector. Our comment is on the requirement for assessment on habitat level of the hazard and risk an invasive alien species poses Art. 10 of the Recital to the Regulation states an invasive alien species should be considered to be of Union concern if the damage that it causes in affected Member States is so significant that it justifies the adoption of dedicated measures applicable across the Union, including in the Member States that are not yet affected or are even unlikely to be affected Art. 16 of the Recital to the Regulation states regional cooperation should be explored between Member States concerned with the same species that are not able to establish a viable population in a large part of the Union. The Framework for the identification of invasive alien species of EU concern point out a critical issue exists in the simplification of extrapolating national or regional assessments to the total area of the EU. It further specifies the EU is rich in biodiversity and is a highly heterogeneous and large territory and so risk assessments of IAS may differ substantially when different regions are considered. Assessing the risk of an alien species on a biogeographical region level does not take this heterogeneous character sufficiently into account. The assessment whether or not a species can enter a certain habitat and form a viable population cannot be in compliance with the duty of diligence if assed on the level of biogeographical regions. Therefore, to fulfil the duty of diligence the risk assessment must describe not only the biogeographical region in which a species can enter and form a viable population, it must specify the specific habitat in which the species concern can enter and form a viable population. The identification and characterisation of the hazard, the assessment of exposure to the hazard and the characterisation of the risk a species poses must be assessed specifying the habitats relevant to this hazard and risk. Only if, after the risk assessment of a species on habitats level, it is clear the species can enter, form viable populations and spread in a large part of the Union, and the spread is not limited by the isolated characteristics of the habitats concerned, the species can be concerned to be of Union concern. 1 Framework for the identification of invasive alien species of EU concern (ENV.B.2/ETU/2013/0026)
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Response to Commission Implementing Regulation laying down rules on plant passports

24 Oct 2017

Dear all, Thank you for giving the opportunity to provide feedback on the Commission Implementing Regulation on the format specifications of the plant passport. Please see the comments of Plantum (the Dutch association for the plant reproduction material sector) below: Comments on the Implementing regulation Article 2. Requirements for the elements of the plant passport The implementing regulation prescribes that the flag of the Union shall be printed in blue with yellow stars or in black with white stars.  We request to allow also the option ‘white with black stars’. The reason for this request is a practical one: on small packages the little white stars will fill with ink and only a black block will remain. Article 4. Date of application Plant passports issued before 14 December 2019 shall remain valid until 14 December 2021.  We request a longer transition period for botanical seeds, namely that plant passports that are issued before 14 December 2019 shall remain valid until 14 December 2023. Motivation: botanical seeds can be sold for many years. Comment on the Annex Legend 7. We request to delete the foloowing part: “and, in the case of replacement of the plant passport, the registration number of the professional operator concerned who issued the initial plant passport or for whom the initail plant passport was issued by the competent authority as referred to in Article 93(1) and (2) of that Regulation” Motivation: This creates an unnecessary burden for industry, and will not help in tracing because there can be more operators prior to final sale. And there is no legal basis for this provision. With kind regards, Marian de Beuze Plantum
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Response to Establishment of new phytosanitary requirements for the movement of potato seed in the EU

4 Aug 2017

Dear all, Thank you for giving the possibility for feedback on this draft implementing directive. I would like to request to amend the title of this Implementing Directive and the title of Article 18.3.1. to " Seeds of stolon or tuber-forming species of Solanum L., or their hybrids ....." in stead of "Seeds of Solanum tuberosum L.,". This change will increase the possibilities for breeding. With kind regards, Marian de Beuze Plantum
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