Lord de Mauley

Parliamentary Under Secretary of State for Environment, Food and Rural Affairs

Department for Environment, Food & Rural Affairs

Nobel House
17 Smith Square
London SW1P 3JR

REF: ML.N0026.CM.04.02.14

Date: 4^th February 2014

Dear Lord de Mauley,

I wrote to the Secretary of State on 24 June 2013, expressing my concern about the possible implications of EU proposals to regulate the production and market availability of plant reproductive material. In your reply, you answered that existing proposals were still being negotiated, would likely be subject to change, and that, furthermore, greater detail would be needed before the Government can assess the possible impact of the legislation.

I would firstly like to reiterate the concerns I expressed in June; that the proposed regulations threaten biodiversity, consumer choice and sustainable agriculture. Secondly, I would like to draw your attention to amendments to the proposed regulations, published by the EU Agriculture and Environmental committees in October and November last year.[1]

These amendments only seem to have made this regulation worse in that they further threaten biodiversity and competition in the seed market. The concession for microenterprises (employing less than 10 people and with a turnover of less than € 2 million) from registration fees has been altogether removed, with the possibility of fraud cited as an opaque justification.[2] Europe’s seed market is already dominated by a few large companies[3]; this amendment may further concentrate that.

In addition, the exemption of swaps from the proposed regulation that was cited in your reply has been limited to “small quantities” of reproductive material exchanged in kind between persons other than professional operators[4]. That would surely prohibit events like Brighton’s Seedy Sunday, the UK’s largest seed swapping event, with 3000 people exchanging about 10 000 packs of seed.

Whilst the proposals may still lack many of the necessary details that will be added in Delegated Acts, can the Government agree that this is a worrying direction for the proposed regulation to be moving in? And will he assure me that the UK will be fighting hard to protect the rights of all its farmers, consumer, gardeners and seed swappers.

I look forward to your response.

Yours sincerely,