Page 100 - Breeding and regulatory opportunities, Renaud

Chapter 3

a restraint to trade, being both cumbersome and long (seed company inter-

view, 2010). Only in 2011 did SAGARPA accept that the approval of new organic

seed treatment options no longer required the prior approval of COFEPRIS.

The option of allowing importation and use of untreated seed if accompanied by

the appropriate certiication was described in Article 89 of the original Mexican

Organic Products Law (COFEMER, 2007). The law provided for an exception

when a seed importer presented technical or scientiic evidence demonstrating

an alternative to the required chemical treatments. In 2009, a biological seed

treatment called T-22 (Trichoderma harzarianum) was approved for organic seed

and the option to import organic untreated seed was removed. Use of T-22

proved problematic from the start because the company that had exclusive

manufacturing rights was unable to meet the initial demand. In addition,

inconsistent enforcement of what counts as acceptable seed continued at

Mexico’s borders. The minimum dosage rates for seed treatment were set at a

high level, not all crops were approved for T-22 treatment, some seed producers

encountered germination problems, and research analyses found only limited

evidence to support the claim that T-22 prevented seed-borne diseases

(Cummings et al., 2009). Since 2009 the number of crops approved for T-22

treatment has expanded from the original list of just six crops (although some

crops remain excluded). In 2012, two new organic seed treatments were approved

by SAGARPA to support the entry of organic seed into Mexico (SAGARPA, 2012ac).

However, these treatments were originally not commercialized for application

on seed in the US and were not permitted on all crops. By the end of 2013,

these seed treatments were allowed on a select group of crops (Actinovate: 14;

Mycostop: 9). In Table 3.5 the key decisions and events in the evolution of the

Mexico organic and phytosanitary regulations are summarized.

In summary, three preliminary comments on the organic regulatory situation

in Mexico can be made. First, Mexican organic growers are burdened with the

costs of multiple organic certiications, additional phytosanitary treatments,

and of securing complex import permissions, that place them at signiicant dis-

advantage compared with US and EU growers, who produce for the same mar-

kets. Secondly, certiiers and sellers in Mexico, if they wish to stay in business,

in practice are forced to break the laws of either or both the seed’s country of

origin and of the destination markets for organic products. This signiicantly

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