Rete Semi Rurali
RSR
Rete Semi Rurali (literally “rural seeds network”) is the Italian Farmers’ Seeds Network.
ID: 575023745025-39
Lobbying Activity
Response to Revision of the plant and forest reproductive material legislation
4 Dec 2023
Rete Semi Rurali is appreciating the proposal of the Commission, even though we strongly believe that are things that needed to be improved. 1. VSCU. We dont think that is worthwhile enlarging VCU to all the crops. VCU is an old concept, that is not able anymore to cope with the diversity of varieties requested by farmers and the diversity of markets of these produce. Moreover, there is the risk that, if not correctly implemented, this provision will limit that registration of varieties for organic or low-input agriculture. It is really complex to evaluate the Sustainability of a varieties, and of course it cannot be done in small plots replicated in experimental stations. The risk is that the only criteria that will be assessed will be the presence of genes of resistance to pathogens. 2. Access to PGRFA out of the scope. In accordance with the International Treaty on Plant Genetic Resources for Food and Agriculture (ITPGRFA), EU countries commit to provide facilitated access to PGRFA in line with the multilateral system for access and benefit-sharing of the ITPGRFA. Moreover, all countries of the EU, as part of the FAO Commission on Plant Genetic Resources for Food and Agriculture and the FAO Council, approved the Second Global Plan of Action (GPA) for PGRFA in 2011. Under the GPA, countries commit to promote and facilitate access to PGRFA stored ex situ for their use by a wide range of actors. Recognizing the importance of guaranteeing facilitated access to PGRFA, from public and private collections, we would like to remind the European Union and its Member states that the rules for sharing these resources are already set up by the ITPGRFA and they are not related to seed marketing. By confusing the transfer of PGRFA with seed marketing, the proposed EU Regulation introduces a number of obligations that will prevent genebanks and collection holders from continuing their activity of conservation and making PGRFA available to users such as other genebanks, breeders or farmers. For this reason, RSR is asking to consider the transfer of PGRFA outside the scope of the regulation, under article 2.4. At this end, we provide this amendment to the text for consideration by the EU Parliament, Council and Commission: Article 2.4.f The transfer of samples of Plant Genetic Resources for Food and Agriculture, including for breeding, training, conservation and repatriation. Accordingly, to be coherent with this approach, Article 29 needs to be changed and limited to activities not excluded by this amendment to art. 2.4. 3. Conservation varieties. The definition of CV is not so clear and maybe too close to HM. Maybe it could be better to allow some diversity within CV but not to say high level because it is too similar to HM. We have to consider that a lot of CVs of agricultural species are less uniform than varieties but not so diverse. Moreover in the case of clonal crop species, they could be accepted as conservation varieties even if they are uniform (e.g. old fruit tree species). For the definition of landrace, already included in the directives on Conservation varieties, we refer to Khoury et al 2021 Crop genetic erosion: understanding and responding to loss of crop diversity. So we provide the following new definition: (a) a traditionally grown landrace, (b) a newly bred variety (modern landrace) derived from on-farm selection and bred for adaptation to local conditions in the context of the sustainable use of PGRFA, including participatory plant breeding (c) characterised by a certain level of genetic and phenotypic diversity between individual reproductive units, except in the case of clonal crop species. 4. Heterogeneous Materials. It is important the this regulation will apply the provisions already defined by the Organic Regulation without downgrading what we have now. For instance, HM should be open to all the species and notified for free. We are attaching the list of RSR amendments.
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