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The Plant Variety Development Office CLG

PVDO

PVDO is the body authorised under Statutory Instrument (SI) No.273/2007 to administer the collection of royalties on farm saved seed (FSS), sometimes called home saved seed, in Ireland.

Lobbying Activity

Response to Food and Feed Safety Simplification Omnibus

14 Oct 2025

The simplification process should make EU regulations and procedures clearer, easier to implement and they should allow us to meet our own standards in a timely fashion that does not impede competitiveness. Processes and regulations must be evidence based / based on science. Simplification should not lead to poorer regulation or standards but it must implement those standards fairly to all products on the market. We support the Euroseeds position on specific actions attached. Two specific issues have considerable impact in the Irish context and will affect other states also. Our Irish Seed Trade Association has highlighted the value of seed treatments in our meetings with the Department of Agriculture and Food. We have also asked for the recognition of Seed Treatment as an integral part of IPM in our National Action Plan. We believe the retention of the current list of seed treatments on the Irish Market is vital until a well proven substitute product is available. As the cereal seed trade now has its Winter 2025 results back the results show some varieties would not meet minimum EU germination requirements for certification by DAFM without seed treatments for fungal diseases. That would be entire crops not an occasional seed lot. In a relatively good year regarding conditions at harvest the value of treatments in making seed viable shows in the stark differences in germination results (up to 30% in some samples) available between dressed and undressed samples in the Department Seed laboratory. As actives in the key products are delisted we need to ensure the industry is not left without key actives such as fludioxinil. These actives provide targeted protection at sowing for commercial feed and food crops. Varieties are being bred with numerous characteristics in mind; to tolerate varying climate and disease pressures but seed treatment for fungal diseases has no replacement. Our climate can produce high yielding high quality crops but is also one with high disease pressure. The loss of plant protection products due to non-renewals has seen fewer effective options for disease and weed control in many crops in the past few years. One vital point of application of product in cereal crops is Seed Treatment. Seed treatment with conventional plant protection products and/or biological products is a targeted, one-time, precision application technique that has a low environmental footprint and can contribute towards the EU Green Deal and Farm to Fork objectives. The second issue is seed equivalence with third countries. The United Kingdom is our nearest neighbour. Plant Breeding in the UK is very relevant to countries like ourselves with similar growing conditions. Currently border controls and requirements are affecting seed movements whether commercial or for crop evaluation programmes, both which undermine competitiveness. The lack of DUS equivalence also means Plant breeders rights are at risk of infringement more widely.
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Response to Evaluation of the EU legislation on plant variety rights

11 Mar 2025

PVDO CLG is very happy to see this review take place - it will mean the EU will protect and promote developments in plant breeding through their support of PBR. It is obvious on a practical ground level that strong enforceable PBR legislation deters the infringement of PBR and so protects the investment of those developing new traits and varieties in the sector. This is also supprtted by the breeders exemption so new varieties can be further used for breeding. While the current legislation has been very useful in enforcing IP, it must meet current and future needs. In Ireland we see stregthning of the FSS element as important to ensure widespread obligation to provide required information voluntarily. It is also our view that the royalties on FSS need to reflect the investment of breeders to take them to market, they need to be higher. There is already a significant cost differential between certified and FSS due to the costs of multiplication, certification, research and trialing. It is vital trading of uncertified seed is seen as unattractive. High penalties must be enforceable. The CPVO is central to the PBR system. On the edge of the EU we see it as important that DUS equivalence with third countries where beneficial be allowed for. DUS equivalence for EU varieties in the UK and vice versa would mean access to varieties in both regions while also decreasing the potential for illegal seed crossing the borders.
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Response to Revision of the plant and forest reproductive material legislation

16 Nov 2023

We acknowledge the Commission proposal keeps central the main pillars of the EUs well-established legal framework for variety registration and seed marketing which sees the continuous development and route to market of a significant number of improved varieties and guarantees high-quality seed supply for farmers /growers of all different species. Maintaining these elements also means the EU system is well-aligned with international standards. It safeguards the position of EU companies who export seed to third countries and any necessary movement of PRM into the EU. This vitally includes the elements of proper identification of all PRM Plant Reproductive Material (official DUS test or officially recognised descriptions), performance assessment (Value for sustainable Cultivation and Use) under practical field conditions, seed quality guarantees by certification and high-level standards, as well as phytosanitary controls that help avoid the spread of pests and diseases. Thus we also support the principal objectives of alignment with the Plant Health and Official Controls legislation to improve clarity and consistency. We also in the main support the modernisation / streamlining of processes, such as involving the sector in the execution of specific tasks under official supervision, which should lead to efficiency / cost savings at both private and official level. Similarly, PVDO supports the improved process for the granting of equivalence status for PRM from third countries (Art. 39) based on the proper assessment of their respective systems and standards as it provides subsidiaries of EU-based companies with much needed supply safeguards under increasingly challenging environmental conditions. This is of particular importance to Ireland who shares a land border with the UK via Northern Ireland, where currently varieties on the common catalogue can be multiplied without PBR in the UK. PVDO is of the opinion that all PRM must fall under the relevant legislation. All users of seed must be guaranteed that the PRM product they use conforms to the appropriate identification, performance, technical quality standards and absence of pests and diseases. While ensuring competition in a transparent Common Market, we acknowledge the usefulness of derogations and specific standards for defined markets, materials and users (v. Art. 26-30) and consider the general information and obligation for all market segments and subsequent reporting by the Commission (Art. 77) a potentially useful element for future policy initiatives. We recognise the Commissions plan to maintain the necessary differentiation of the legislation as regards applicability of individual standards or measures to individual (groups of) species or markets. This is based on the biological differences of species and products as well as on the specific needs and differences of certain market segments. Still, some provisions require further differentiation and/or restrictions (e.g. for heterogeneous material in forages and grasses, Art. 27 and Annex VI; limitation of volumes and uses allowed for pre-authorisation trials of vegetable seed, Art. 32; etc.). PVDO would like to highlight the proven contribution of plant breeding and innovative varieties to sustainability and considers the well-developed system of VCU testing for agricultural species to be already well suited for this purpose and adaptable to the further differentiation in future. PVDO underlines its opposition to the provisions of Art. 47.1 f and g which establish an unpredictable carte blanche for Member States to decide on the usefulness of specific traits and establish cultivation conditions for varieties carrying such traits which creates unacceptable uncertainty for the long-term investments that breeders must make to develop new varieties. Similarly, we oppose that competent authorities may, on their own initiative, renew variety authorisations.
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