Page 89 - Breeding and regulatory opportunities, Renaud

Seed Regulation in the US, EU and Mexico

are not available in organic form. While data contained in the plans have

the potential to inform the organization of organic seed supply, procedural

diferences among certiiers with respect to the review and enforcement of

the plans has led to signiicant inconsistencies (Renaud et al. 2014). A residual

level of regulatory enforcement responsibility has been allocated to organic

food buyers, who are supposed to monitor the seed usage of their suppliers,

particularly if the buyer’s contract speciies a particular variety. According to

our interviews, in practice such monitoring is considered by the buyers to be

a costly administrative expense that is often avoided. In addition, food buyers

may face a conlict of interest based on the varieties they want and the quality,

characteristics, price or volume of the organic seed available to produce the

variety (Dillon and Hubbard, 2011).

The lack of a comprehensive organic seed database lies at the heart of many

of the tensions that have emerged. NOSB’s guidance documents indicate that

a database should list the availability of varieties aligned to certiied organic

growers’ trait preferences, and the equivalent conventional seed options (in the

case that an organic seed variety is not yet commercially available). At least

eight organizations have created, or attempted to create, a database to ensure

transparency in the claims made about organic seed varietal availability. To date

(end 2013), none of the databases have achieved comprehensive coverage

and none has been oicially endorsed by the NOP. The Organic Material

Review Institute’s (OMRI) attempt was the most ambitious, aiming to provide

a comprehensive national database for all growers and certiiers in the US.

However, a lack of clarity about who should bear the cost of registering and

organizing the information and, in the opinion of many stakeholders, because

the initial fee for using the database was set too high, from the beginning

OMRI’s ability to mobilize long-term funding for the initiative was undermined.

In 2012, drawing on OMRI’s experience, a multi-stakeholder initiative to re-

launch the database was coordinated by the Organic Seed Alliance (OSA) in

collaboration with the database host organization Association of Oicial Seed

Certifying Agencies (AOSCA) that emphasizes the importance of attaining NOP

endorsement to ensure its success (Hubbard, 2012). All our respondents have

recognized that without a fully endorsed and populated database requests for

exceptions to the organic seed rule will persist and will discourage organic seed

producers from meeting the demand, thereby sustaining the pressure to grant

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