There are very interesting parallels between these proposals
and the EASA regulation of European Airways regulations.
I have been keeping a watchful eye /on the sidelines/ on
the progress of some aspects of the EASA regulations;
people may or may not find the parallels illuminating.

The EASA regulations were drafted by people that understood
Commercial Air Transport (CAT i.e. airliners et al), but who
have very little understanding of General Aviation (GA i.e.
light aircraft, hot air balloons, gliders et al). The
resulting heavyweight cumbersome regulations were fine
for CAT, but disastrous for GA.

It took a /lot/ of hard work by /many/ people knowledgable
about GA over maybe 5 /years/ to mitigate /some/ of the worst
effects of the regulations. Standing on the sidelines and
moaning is useless. What succeeded was working within the
system plus individuals making /formal/ comments when
invited to do so. In this context "formal" means in the
comment forms on the EU website. Be prepared to read the
regulations and individually make comments; multiple
identically worded comments are treated as a single
comment.

Nonetheless, the regulations are now enacted, and will be
fully implemented in 2015. In the meantime various
organisations are having to decide how they will interpret
the regulations.

In the past couple of weeks the government and CAA have
announced they are trying to get rid of red tape; the
latest statements about how the regs will be interpreted
are specific and positive and useful. Having a private
pilot (Grant Schapps) in the centre of government has
apparently been useful.

Summary:
- the new regs will happen
- there is a chance to shape them, but it requires
long dedicated hard work by individuals
- the new government attitude might help, particularly
if you can get DEFRA onside


On 16/11/13 14:10, Ophelia wrote:
Apologies if you have already seen this.

This was posted in a political group. I hope it can be of use to some.
Best
O
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Deadline for consultation on this important Seed Law is 4th December !

All ABOUT THE New EU Seed Law

Updated November 2013
[] WHAT IS THIS NEW LAW?
The European Commision is currently drawing up a new law to regulate the sale of all seeds, plants and plant material. The latest draft of the law is even more restrictive than the regulations that
we have at the moment.
Every single variety of vegetable will have to be registered on an EU list, otherwise it will be illegal to sell it. To be registered on the list, seed varieties have to pass a series of tests
demonstrating what is called DUS 'Distinctiveness, Uniformity and Stability'. It costs nearly £3000 to test & register just one single variety of seed for sale.
Although we have had a system like this for many years, there have been much simpler and cheaper options for what are considered 'amateur varieties' for home gardeners, and the rules have never been
strictly enforced in the UK.
The EU wants to get rid of these simpler and cheaper rules for 'amateur' seed, and make sure that every country enforces the rules 100%.
Although they say there will be exceptions, in current drafts of the law these are very, very limited.

WHY ARE THESE NEW LAWS A BAD THING?
The effect of this new legislation will be to massively limit the choice of vegetable varieties available to home gardeners.
This is because if you are selling seed to farmers, you can expect to sell hundreds of tonnes of seed every year, so it is worth the cost of registering the variety. But if you are selling to
gardeners, even the biggest seed companies will be selling a few kilos of seed at most, sometimes just a few hundred grammes of more unusual varieties. It just doesn't work if they have to pay
thousands of pounds to register that variety! So only seed designed for farmers will get registered and be legally sellable.
Unfortunately, varieties suitable for farmers often aren't appropriate for home gardeners and allotment growers. For example: farmers usually want all of their produce to come ready at the same time,
so that they can harvest and sell a whole fields worth. Home gardeners usually want their crops to mature over a longer period - we don't want to eat all our vegetables on one day!
Another example: farmers generally don't want to grow climbing peas, as they need supports and can't be harvested mechanically. Lots of home gardeners prefer tall pea varieties, as they are more
productive in a small space. There are hundreds of examples like this - the needs of gardeners and farmers are very different.
The problem is very simple: If these new laws are passed, there will be fewer and fewer varieties developed for gardeners and small growers. Everybody will have to grow varieties that have been
designed for commercial large-scale farming, whether they like it or not.


BUT AREN'T THERE EXCEPTIONS & ALLOWANCES FOR HOME GARDENERS?
We've discussed this at length with DEFRA. They have confirmed that the European Commission is trying its best to make sure thatall seed is covered by their legislation. There are a few exceptions
to the new laws, but these are very, very limited.
And the exceptions will only apply to non-commercial operations selling locally - for example individuals people selling a few packets of a local variety on a market stall. So seed companies - who
are the only people with the experience and skills to develop what home growers need - will be very restricted in what they can offer to gardeners.
Remember, even the big seed companies often only sell a few hundred packets of their more unusual and specialist varieties - and these simply are not economical to test and register, especially if
there is an annual fee of several hundred pounds to keep them on the register!
I THINK THIS IS A BAD THING - WHAT CAN I DO?
Earlier in 2013, as the first draft of the law was being made, hundreds of thousands of people emailed and wrote to their MEPs and the EU, pushing for changes to this new law. The initial draft of the
law was so badly drafted that it even outlawed seed swaps between individuals with no money taking place! The EU did concede some last minute changes which looked workable. BUT, they are now watering
down nearly all of these concessions, or making them so restrictive as to be useless, as the law progresses through the system.
The fact that they made changes to start with shows that pressure can work! We must fight for major improvements to the law as it goes through the EU, and then is translated into UK laws.
So, if you think that this law is a bad idea, there are two things that you can do, right now!


1) WRITE TO THE 3 KEY MEPs ON THE EU COMMITTEE


They a Sergio Silvestris, George Lyon, and Julie Girling
PLEASE DO WRITE! It has a huge effect if you write, and don't be shy about it,
they don't expect a masterpiece and are quite used to getting random informal letters from normal people.
You can find their contact details and a suggested draft letter here
The deadline for amendments is December the 4th, 2013, so if you can, write soon!
Tell them that:
You are worried by the new EU Seed Law
You think gardeners should be able to choose any vegetables they wish to grow in their own gardens, rather than just from a list of 'EU-approved' varieties.
You want to be able to buy seed suitable for gardeners, not seed for big scale agriculture, which is not the same.
The new EU Seed Law should ONLY cover seed sold to farmers.
The new EU Seed Law should NOT cover seed sold in small packets for home gardeners and allotment growers.
Ask them:
to change the draft law so that Home Garden seed and plants are not covered by it.

2) respond to the uk government consultation


It just happens that the UK government have started a consultation asking people what things should be covered by EU laws, and what should be decided at national level, as there is concern that EU
legislation may be interfering too much with some parts of our way of life.

The consultation about agriculture is happening now. We are asking as many people as possible to respond, and say that garden plants and garden seeds should NOT be covered by EU regulation, but
instead controlled by UK laws. You can find details of how to fill in the consultation here.
Please do this! DEFRA - who regulate seeds in the UK - understand the problem completely,
and have very sensible views on how the home garden seed industry should be regulated.
If the law is brought back in to UK control, they will be given the task of drawing up sensible new UK laws & the problem will be sorted.


3) CHECK OUT OUR FACEBOOK PAGE


We will post occasional updates on our Facebook Page as we get more information.

EVEN MORE INFORMATION - and a warning

The law itself is linked below if you want to wade through it. But before you start, a very important warning:
You cannot just read the first 5 pages or so that are an 'executive summary', and think you know what this law is about. The executive summary is NOT what will become the law. It is the actual
Articles themselves that become law, the Summary has no legal standing and is just tacked on as an aid to the public and legislators, it is supposed to give background information and set the proposed
legislation in context so people know what is going on and why.
The problem with this law has always been that the Summary says lots of nice fluffy things about preserving biodiversity, simplifying legislation, making things easier etc etc - things we all would
love - but the Articles of the law don't really have the promised effects. And the Summary is not what becomes the law.
So, be warned. By all means, read it yourself. But you have to pretty much ignore the Summary as that is not the Law, and does not reflect what is in the Law. The actual meat of it starts around about
Page 25. Some of the more important articles are 2, 3, 14, and 36 but you do need to read all the rest as well to see how they fit together.
Official version of the Law as of May 6th 2013 is Here
Draft report from 28th October 2013 with proposed changes, removing and limiting the concessions is here
NOTES TO EDITORS
"Proposal for a Plant Reproductive Material Law" was released on May 6th 2013
Law drafted by DG SANCO (consumer affairs), apparently some debate by DG AGRI & ENVI (agriculture & environment)
Executive Summary of Law does not truly reflect stricter reality of the actual articles in the law
Law as currently proposed will effectively kill off professional development of home-garden seeds in the EU
Huge public opposition: over 270,000 signatures to the Arche Noah petition
Media contact: Ben Gabel, The Real Seed Catalogue:
ABOUT THE REAL SEED CATALOGUE:
The Real Seed Catalogue ( www.realseeds.co.uk ) is a well-known DEFRA-registered seed supplier, based in Wales, that specialises in breeding and supplying vegetable seed specially suited to the needs
of home gardeners. As a not-for-profit company dedicated to the needs of home gardeners, it is also one of the UK's premier seed-saving organisations, educating the public about seed saving and how to
preserve their own heritage varieties of vegetables at home.

The Real Seed Catalogue is produced by The Real Seed Collection Ltd , a not-for-profit company limited by guarantee.
~ Company No 5924934 ~ VAT No 841181938 ~ DEFRA