b'The commission then outlines four possible policy choices. Considering the severe environmental crisis which we face, the only constructive and future-oriented option is option 2: Alignment of defini-tions and structure of the legislation while matching needs of professional sector, seed conservation networks and users.This option would exempt seed conservation networks and marketing to amateur gardeners from the scope of application of the legislation. According to the Commission this would promote diversity and boost the marketing of more local and traditional products. This is cru-cial to stop the further decline of agrobio-diversity in the fields and gardens. Option 2 also foresees the creation of a frame-work for the exchange in kind between farmers of plant reproductive material. The exchange between farmers is crucialDiversity in tomato variety Paradeiser.for the sustainable use of plant genetic resources. Therefore, farmers need to be allowed to exchange and sell seeds theythe marketing of "diversity varieties" sowill be out of the scope of the seed have produced themselves directly tothe increasing consumer demand for tra- legislation other farmers without having to complyditional and local varieties is no longer A segment of diversity and organic with the seed marketing legislation. Asrestricted. Furthermore, changing cli- farmers which benefit from signifi-such an adaptation of the seed legislationmatic conditions and with it, the neededcantly simplified rules for production has no influence on the restrictions thatadaptation to climate change makeand marketing of PRMapply to seed protected by Plant Breedersit clear, that there should be no more A segment of farmers who are Rights, it would therefore be limited torestriction to a region of origin, which ininvolved in industrial production and the exchange and sale of PRMs not pro- the long run would mean endangering theattach great importance to the cur-tected by intellectual property rights.conservation of many varieties. rent standards of homogeneity and Nevertheless, we see this as an importantuniformity.step towards the implementation of theOPPORTUNITY The goal of the reform must be that UN Declaration on the Rights of PeasantsThe upcoming seed law reform is THEthe new legislation is tailored to the (UNDROP) and the right to seed con- opportunity to implement agreed goalsneeds of the different actors that are an tained therein. on agrobiodiversity and sustainable agro- integral part of the EU seed landscape. Asageneralobjectivetheecosystems. In its impact assessment, theWhen accessing PRM, individual actors, Commission proposes to introduceCommission mentions important buildingwhether professional or non-professional, lighter requirements for conservationblocks to do this, which are supported bymust always know what kind of seed they varieties for all PRM sectors and, whereProSpecieRara and Arche Noah: are dealing with. For this, transparency appropriate, for amateur varieties. For1. seed conservation networks andis crucial. In essence, we should no longer Arche Noah and ProSpecieRara this ismarketing to amateur gardeners outprohibit or restrict the exchange and a crucial amendment. Lighter require- of the scope,trade of diverse PRM - but rather clearly ments are indeed needed, like it is the2.frameworkfortheexchangedisclose the nature of them. We believe case today in Switzerland through nichebetween farmers,that such a system will serve everyone. To varieties. The existing directive on ama- 3. adapted DUS and VCU tests forprevent the reform from failing as it did teur and conservation varieties shall beorganic varieties,in 2013, and to develop a future-oriented replaced by a new uniform derogatory4. better, lighter regime for diversitysystem we are prepared to engage in regime for "diversity varieties" whichvarieties. dialogue with the industry and all other shall apply to all types of crops. The noti- The structure of the future willstakeholders.fication of "diversity varieties" should betherefore have three important segments:based only on a description of the variety. A segment of seed conservation net- Editors Note: Magdalena Prieler is There should be no DUS/VCU testing andworks (including farmers and garden- Seed Policy Officer at Arche Noah and no certification for "diversity varieties".ers being part of these networks) andFranois Meienberg is Project Manager There should be no production limits forthe sales to amateur gardeners whichPolitics at ProSpecieRara.1Treaty for Plant Genetic Resources for Food and Agriculture2https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1590574123338&uri=CELEX:52020DC03803https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1590404602495&uri=CELEX%3A52020DC03814 https://www.arche-noah.at/files/joint_letter_to_the_europaen_commision.pdf5https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13083-Revision-of-the-plant-and-forest-reproductive-materi-al-legislation_enEUROPEAN-SEED.COMIEUROPEAN SEED I 19'