tag:blogger.com,1999:blog-1443219641217444712.post5492640894885842540..comments2023-11-02T02:57:39.035-07:00Comments on Rebecca Taylor LibDem: European Commission NOT seeking to restrict seeds; another Euromyth busted! Rebecca Taylor LibDemhttp://www.blogger.com/profile/03302598487045319831noreply@blogger.comBlogger2125tag:blogger.com,1999:blog-1443219641217444712.post-65712673980392718322013-05-15T04:45:54.299-07:002013-05-15T04:45:54.299-07:00@MATT: <10 employes and "annual turnover o...@MATT: <10 employes and "annual turnover or balance sheet total does not exceed EUR 2 million" seems like a very reasonable cutoff for 'small-scale' seed growers, IMHO. That is not to say that I like the proposal, but I think this specific criticism doesn't hold water, really...DisplayNamehttps://www.blogger.com/profile/15758486251457494734noreply@blogger.comtag:blogger.com,1999:blog-1443219641217444712.post-24809593379162170702013-05-14T03:41:05.162-07:002013-05-14T03:41:05.162-07:00Firstly, it is worth noting that the commission /h...Firstly, it is worth noting that the commission /has/ changed it's position on this legislation, with several of the exemptions and exceptions you have mentioned not being present in the first draft. Whether or not this is due to public pressure or not, I can't comment.<br /><br />I am still concerned about some parts of this legislation. While it is now clear that private growers who are not selling material will be unaffected, it will affect a number of growers who sell seed on a small scale - any who have more than 10 employees. If this has an impact on the cost of seeds or the number of businesses continuing, this can only be detrimental to heritage seed variety availability. Seedbanks will also not be allowed to sell seeds without registration, making such groups who sell seed to cover costs more unviable.<br /><br />Article 14(1):<br />"Plant reproductive material may be produced and made available on the market only<br />if it belongs to a variety registered in a national variety register referred to in Article<br />51 or in the Union variety register referred to in Article 52."<br /><br />Article 36(1):<br />"Article 14(1) shall not apply to plant reproductive material where all of the following<br />conditions are fulfilled:<br />(a) it is made available on the market in small quantities by persons other than professional operators, or by professional operators employing no more than ten persons and whose annual turnover or balance sheet total does not exceed EUR 2 million."<br /><br /><br />For all other cases, registration and payment of a fee is required ('small' organisations as defined above are exempt). I am uncertain as to how many traders across Europe fall below this cut-off in terms of employee numbers.<br /><br />While there is a general clause that 'the fee level shall be set so as to not unduly hinder registration' there will still be a cost and administration associated with this process, which will be passed on to consumers, and potentially reduce seed availability.<br /><br />I look forward to seeing whether or not any of the groups, businesses and organisations affected by this draft have any comments.Matthttps://www.blogger.com/profile/07696466249926635792noreply@blogger.com