Page 217 - Breeding and regulatory opportunities, Renaud

General Discussion

sector to comply with organic seed regulations. Self-organisation has been only

partially achieved, and sector development is evolving too slowly to optimally

support organic seed market growth. While other on-farm organic inputs are

rigorously regulated (e.g. compost, manure), seed is seemingly not recognized

by the regulators as an input (although it could be considered a foundational

input). Regulators appear unsympathetic to the dilemma created for certiiers,

growers and seed companies by the lack of clear regulatory language and failure

to establish a clear process, procedures and timeline for achieving closure on

interpretation, implementation and enforcement. At the same time the state of

the US regulation has put the organic sector at risk of violating organic integrity.

The regulatory ambiguity contributes to potential violations in the use of non-

acceptable seed and seed treatment inputs, and perpetuates inconsistency in

certiier seed regulatory interpretation and enforcement. It has failed (so far)

to establish a level playing ield among stakeholders. The organic regulation

has perpetuated a concern amongst the diverse stakeholder groups that

strict enforcement would limit the varietal assortment (genetic diversity and

farmers’ choice) available, increase grower costs and require seed companies

to invest in a market that they consider relatively small or that they do not have

the skills or resources to support (in regards to seed production or breeding).

Simultaneously, however, the dynamic relationships that have evolved in the

various networks that have emerged in response to the seed regulation, have

shaped the unfolding process of regulatory governance. In spite of regulatory

ambiguity, the seed sector is developing, and a broader variety assortment

and larger quantities available of higher quality have become available. These

developments however, are too slow to meet the growth in the organic sector

and seed shortages and lack of a broad range of appropriate varieties continue

to afect the sector. Conversely, the lack of an appropriate assortment is shown

to be one of the root causes of stakeholders’ reluctance to push for 100%

compliance with the US seed regulation. To enable to regulators to improve the

regulatory guidance documents, the seed sector should communicate better

the changes in organic seed availability and quality.

In the second study (Chapter 3), when the US organic seed regulatory

environment was compared to that of the EU and Mexico, delays in seed sector

growth caused by regulatory ambiguity was found with each jurisdiction

studied. The analysis identiied important risks of non-tarif trade barriers in

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