Marketing of Organic Heterogeneous Material (OHM): consultation results

Consultation results on the proposed legislative options and scope of marketing organic heterogenous material (OHM) in Scotland.


Respondent comments

Respondents were provided the option to comment on each of their selected multiple choice answers and additionally were given the opportunity to express their thoughts or concerns in general on the marketing of OHM in the UK. This section aims to summarize these contributions.

Table A: Summary of respondent comments to legislation options

Legislation options

Summary of comments supporting choice

Implement permanent change

  • This will provide plant growers legal certainty and protection as well as encourage long-term investment into heterogeneous material
  • Regardless of the size of market demand, small-scale growers need to be able to freely (within the law) choose what crops to buy, sell and propagate
  • Current legislation effectively stops the further development of this promising area
  • More choice on the open market
  • Promotion of in-crop genetic diversity is seen as a component of resilience in agro-ecological systems, often mentioned in the context of climate change and food security
  • Recognition that a temporary experiment has already been carried out within the EU

Maintain the status quo

  • Concerns that the proposed permanent legislative change will have the following negative implications:
    • May lead to a reduction in certified seed sales reducing investment in plant breeding in the UK
    • Creates major issues with the collection of seed royalties with mixtures of different species/cultivars
    • With no official certification, buyers may have no protection from poor germination, weed seeds, contaminants
    • Issues with potential fraud (i.e. mismatch between seed label and bag content, fast tracking of material without DUS and VCU testing)

Implement a temporary experiment

  • No comments provided
Table B: Summary of respondent comments to legislative scope

Legislative scope

Summary of comments supporting choice

Apply the change across all plant types

  • The value of genetic diversity (e.g. adaptability and resilience) should apply to all crops as we move from monocultures to exploring heterogeneous varieties
  • All crops (and the markets for them) would benefit from, and build on, the experience of heterogeneous varieties in a new regulatory framework

Apply changes to selected plant types

  • This is a measured approach that provides for future development of this industry, observing impact on select markets before expanding into others

Key talking points from respondent general thoughts on the marketing of OHM in the UK

  • Basing this legislative change within only the organic sector (a very narrow band of the industry) is extremely helpful in ensuring that any developments in seed material is performed within a well certified and inspected part of the agricultural sector.
  • The consideration of non-organic heterogeneous material to be included in the legislative scope
  • Alignment with the EU Commission delegated regulation 2021/1189 which concerns the production and marketing of OHM of particular genera or species in the EU.
  • There are genuine concerns from the seed production industry regarding reduced security for end users and future investment into UK plant breeding.
  • The traceability process is the most important tool for maintaining integrity within seed marketing and trade. There is a need for a low-cost, reputable traceability system in the interest to all parties engaged in working with heterogeneous populations.
  • Stakeholder networks that are already working with heterogeneous seed are working to create the necessary infrastructure to ensure seed quality, health and appropriate description.
  • Care is required to avoid intra UK divergence of policy and regulation.
  • Requests of additional funding to be allocated to UK heterogeneous research.
  • Further detail on the DEFRA proposals for a 7 year experiment needs to be shared to enable stakeholders to better understand the implications of this specific option.

Contact

Email: sam.filippi@gov.scot

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