Political Hotspot June 2019
Boosting the availability of organic seeds with the new organic regulation?
After several months of discussion, IFOAM EU adopted a position paper on Plant Reproductive Material in the new Organic Regulation (EU) 2018/848. This paper highlights the areas of the basic text of the new Organic Regulation that require more attention and possible actions by the Commission. And action is indeed needed on several fronts.
Organic seed use in Europe
Increasing the availability and use of organic seeds across Europe is one of the priorities of the European organic movement. In all European Member States, there is a lack of organic seed, therefore organic farmers can apply for a derogation to use non-treated conventional seeds. According to the new Organic Regulation 2018/848 that will enter into force in 2021, derogations should be phased out and only organic seed should be used by 1 January 2036. This is only a limited improvement on the derogation process on the use of organic seed, and additional rules are needed to ensure the phasing out of the use of conventional untreated seed.
How to phase out derogations on organic seed use
Individual applications for such derogations can help raising awareness about the fact that farmers should ‘in principle’ use organic seed. Of course, this is only effective if there is at least some organic seed available. Strict derogation rules in a situation where there is no organic seed on the market might be counter-productive. On the other hand, where a substantial offer of organic seed from suitable cultivars available already exists, stricter derogation rules can be an effective policy measure to reduce the amount of derogations and increase the use of the available organic seeds. A desirable outcome from such a regime, would be that farmers start asking for more organic seeds of their cultivars of choice, motivating seed producers to increase organic seed production.
The LIVESEED research project, coordinated by IFOAM EU and FiBL, was precisely developed with the intent of exploring ways to expand the production and use of organic seeds. It already published policy recommendations for national and regional authorities, such as developing and implementing a National Annex listing species or subspecies for which sufficient organic seed is available in their territory and thus no derogation can be granted anymore, like it is already done in some countries (the Netherlands, France, Germany, Luxembourg, Sweden, Belgium, and Switzerland).
Adjusting DUS criteria for organic organic varieties suitable for organic production
Aside from conventional varieties multiplied under organic conditions (“organic seeds”) and farm saved seed for own use multiplied under organic condition, the future organic regulation mentions two new possibilities: organic varieties suitable for organic production, and organic heterogenous material (both multiplied under organic condition).
IFOAM EU is looking forward to the planned seven-year temporary experiment that the Directorate-General for Health and Food Safety (DG SANTE) will conduct. This experiment should foster research and development of organic varieties. Those open pollinated organic varieties are less homogenous and often do not comply with the criteria set out in the current EU horizontal legislation on the marketing of seeds, in particular with the uniformity criteria of the DUS registration (Distinctness, Uniformity and Stability).
For arable crops the cultivar also needs to pass the national thresholds defined for the value for cultivation and use (VCU). Here the organically bred cultivars are discriminated, as these VCU tests are in most cases performed under conventional farming systems. Adjusted DUS and VCU criteria are therefore needed for organic varieties suitable for organic production.
‘Organic Heterogenous Materials’: good for (bio)diversity
The recognition that organic heterogeneous material (OHM) can be marketed and used by organic farmers is also a good step forward, as it will increase the availability of plant genetic resources suited to organic farming. According to IFOAM EU, OHM should be defined broadly and should include Organic Farmers selections, Organic Dynamic populations and Organic Composite Cross populations.
The diversity in different types of OHM is important. Many of these have long traditions (farmers’ selections and heirloom cultivars) and are of great value for dynamic utilization and conservation of biodiversity. Dynamic populations, outcrossing, as well as composite cross populations, are of great importance for breeding organic crops. Several new and highly innovative breeding approaches offer great potential for the development of resilient OHM particularly suitable for organic growing conditions.
The process of notification for OHM should be kept simple and easy and be accessible also for smaller breeders. The description of OHM should be based on traceability, breeding history and seed production processes and performance characteristics, rather than on the usual DUS parameters.
According to IFOAM EU’s seed experts, OHM should have to be developed for at least 3 to 5 years (for annual and biennial/perennial crops respectively) under conditions subject to the organic control system. This is a minimum duration to have material adapted to organic agriculture and tools for traceability.
The definition of ‘Organic Heterogenous Materials’ should be broad to give farmers choice
The Commission is expected to come up with delegated acts on OHM, and seems to consider for now that only Composite Cross populations should be included. IFOAM EU also discussed OHM with like-minded movements, such as Arche Noah, and agreed with them on a broader definition of OHM, which should include farmers’ selections, heirloom cultivars, outcrossing populations, and evolutionary populations. We also agreed that OHM “must be developed (by human or natural selection) for at least 3 years under organic certified conditions, and origin (parent cultivars/lines) and process of OHM development must be disclosed”. A common letter from 41 organisations on OHM was sent to the Commission on 29 May.
New genetic engineering techniques are GMOs!
Last but not least, the position paper underlines once again that the use of all genetic engineering techniques, old and new, is excluded from organic plant production and from organic plant breeding activities. Therefore, such techniques are also forbidden in the development of OHM and Organic varieties suited for organic production. IFOAM EU asks the Commission to urgently take the necessary steps to ensure that the European Court of Justice decision of 25 July 2018 is effectively and properly implemented, so that all these new genetic engineering techniques are subjected to a risk assessment and to mandatory traceability and labelling requirements. Making sure that the new Commission will maintain the current GMO legal framework, rather than revising it - to exempt the new genetic engineering techniques from it - is currently one of hot topics for discussion in the European Parliament, as political groups are trying to agree on a list of priorities for the Commission’s work programme.
For more information about organic seed, please contact eric.gall [at] ifoam-eu.org (eric.gall [at] ifoam-eu.org). For more information about the LIVESEED project, please contact agnes.bruszik [at] ifoam-eu.org (agnes.bruszik [at] ifoam-eu.org).