Updated and improved roadmap/decision tree to reach 100% organic seed
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Deliverable 4.1 Funded by the European Union (grant no. 101059872), the Swiss State Secretariat for Education, Research and Innovation (Contract no. 22.0412) and UK Research and Innovation (UKRI). Views and opinions expressed are however those of the author(s) only and do not necessarily reflect those of the European Union or REA, nor SERI or UKRI. Updated and improved roadmap/decision tree to reach 100% organic seed Authors: Kaja Gutzen (FiBL Germany) Freya Schäfer (FiBL Germany) Ilsa Phillips (IFOAM Organics Europe) Caroline Formont (IFOAM Organics Europe) Deliverable Number D4.1 Work Package WP4 Deliverable type Report Dissemination level Public Deliverable Lead partner IFOAM Organics Europe Due date 30 July 2025 Submission date 24 July 2025 Version V1.4 Reviewers Ana-Marija Spicnagel, Maria Carrascosa, Monika Messmer Contact [email protected]
D4.1, Updated and improved roadmap 1 History of changes Version Date Author Comments V1 12/02/2025 Kaja Gutzen (FiBL-DE) Proposal for the structure V1.1 10/03/2025 Kaja Gutzen, Freya Schäfer (FiBLDE), Ilsa Phillips (IFOAM Organics Europe) Consolidated draft V1.2 19/03/2025 Antoine Robert, Tove Mariegaard Pedersen, Ilze Skrabule, AnaMarija Spicnagel, Maria Carrascosa, Monika Messmer Revised version with comments V1.3 21/03/2025 Kaja Gutzen, Freya Schäfer, Ilsa Phillips Revised version V1.4 11/07/2025 Caroline Formont (IFOAM Organics Europe) Addition of the Swedish and Italian examples V1.5 16/07/2025 Matti Leino (Stockholm University and Agroax association), Riccardo Bocci (RSR) Revised version with comments V1.6 22/07/2025 Kaja Gutzen, Freya Schäfer (FiBLDE), Caroline Formont (IFOAM Organics Europe) Revised final version V1.6 24/07/2025 Mariano Iossa (FiBL Europe) Final quality check
D4.1, Updated and improved roadmap 2 LiveSeeding - Organic seed and plant breeding to accelerate sustainable and diverse food systems in Europe is a 4-year Innovation Action funded by the European Union, the Swiss State Secretariat for Education, Research and Innovation (SERI) and UK Research and Innovation (UKRI). The project started in October 2022 and brings together 37 organisations operating in 1 6 European countries. LiveSeeding provides science-based evidence and best practice solutions to help achieve 100 % organic seed. LiveSeeding contributes to the transition towards environmentally friendly, climate-neutral, healthy and fair food systems through a PUSH-PULL-ENABLE strategy to: Enhance the availability and adequacy of organic seeds of cultivars appropriate to organic farming (PUSH), Increase and stabilise the market demand for organic seeds of cultivars appropriate to organic farming (PULL), Foster an enabling policy and regulatory environment where both demand and supply can harmoniously and productively negotiate without irrelevant constraints due to legal restrictions and/or regulatory fragmentation (ENABLE). LiveSeeding addresses the topics in a holistic multi-actor, multi-stakeholder, participatory approach involving stakeholders along the value chain in 17 local Living Labs (LLs) and 3 established networks of organic breeders (ECO-PB), seed savers (ECLLD) and Milan Urban Food Policy Pact (MUFPP). 16 European countries cover the different pedoclimatic zones and socio-economic contexts, including countries with a low level of development in organic seed and breeding in East and South Europe.
D4.1, Updated and improved roadmap 2 Table of Contents 1. SUMMARY ...................................................................................................... 5 2. INTRODUCTION AND BACKGROUND ............................................................. 6 3. METHODOLOGY ............................................................................................ 10 4. BEST PRACTICE EXAMPLES FROM SIX COUNTRIES ...................................... 12 4.1 DENMARK: “FUTURE-PROOF ORGANIC VEGETABLE SEEDS” ............................................... 12 Project background and objectives ............................................................................ 12 Stakeholder involvement and expert groups ............................................................ 14 Success factors and innovations.................................................................................. 15 Challenges encountered ............................................................................................... 15 Outcomes and impact ................................................................................................... 16 4.2 FRANCE: SPECIES CATEGORISATION SYSTEM ..................................................................... 18 Project background and objectives ............................................................................ 18 Stakeholder involvement and expert groups ............................................................ 19 Success factors and innovations.................................................................................. 20 Challenges encountered ............................................................................................... 22 Outcomes and impact ................................................................................................... 22 4.3 GERMANY: ROADMAPS TO INCREASE SUPPLY AND DEMAND OF ORGANIC PLANT REPRODUCTIVE MATERIAL ....................................................................................................... 24 Project background and objectives ............................................................................ 24 Stakeholder involvement and expert groups ............................................................ 24 Success factors and innovations.................................................................................. 25 Challenges encountered ............................................................................................... 26 Outcome and impact ..................................................................................................... 27 4.4 LATVIA: DEVELOPING THE NECESSARY MEASURES TO BOOST THE USE OF ORGANIC SEED ... 28 Project background and objectives ............................................................................ 28 Stakeholder involvement and expert groups ............................................................ 29 Success factors and innovations.................................................................................. 29 Challenges encountered ............................................................................................... 30 Outcomes and impact ................................................................................................... 30 4.5 SWEDEN: INCREASING DOMESTIC ORGANIC VEGETABLE SEED PRODUCTION BY 2036......... 32 Project background and objective .............................................................................. 32 Stakeholder involvement and expert groups ............................................................ 33 Success factors and innovations.................................................................................. 33
D4.1, Updated and improved roadmap 3 Challenges encountered ............................................................................................... 34 Outcomes and impact ................................................................................................... 34 4.6 ITALY: NATIONAL PLAN FOR ORGANIC SEEDS.................................................................... 36 Project background and objective .............................................................................. 36 Stakeholder involvement and expert groups ............................................................ 37 Success factors and innovations.................................................................................. 38 Challenges encountered ............................................................................................... 40 Outcomes and impact ................................................................................................... 41 5. KEY TAKEAWAYS AND LESSONS LEARNED .................................................. 42 Multi-actor approach .................................................................................................... 42 Baseline data collection and monitoring progress ................................................... 43 Institutional embeddedness ......................................................................................... 43 6. KEY POLICY RECOMMENDATIONS ............................................................... 45 REFERENCES AND FURTHER READING ................................................................ 47 ANNEXES ............................................................................................................. 49 ANNEX 1: LIST OF CROP SPECIES IN CATEGORY 1 (NO DEROGATIONS) FOR DENMARK, FRANCE, GERMANY, LATVIA, ITALY AND SWEDEN (JULY 2024) ............................................................. 49 ANNEX 2: QUESTIONNAIRE..................................................................................................... 52
D4.1, Updated and improved roadmap 4 List of abbreviations AMK German Conference of Agriculture Ministers (Agrarministerkonferenz) AREI Latvian Institute of Agricultural Resources and Economics (Agroresursu un Ekonomikas Institūts) E.C. European Commission CMS Cytoplasmic Male Sterility CNAB French National Committee on Organic Agriculture (Comité national de l’agriculture biologique) CREA Italian Council for Agricultural Research and Economics (Consiglio per la ricerca in agricoltura e l'analisi dell’economia agraria) EG. Expert Group EU European Union F1 Filial 1 hybrid FiBL Research Institute for Organic Agriculture ICOEL Danish Innovation Centre for Organic Farming (Innovationscenter for Økologisk Landbrug) IFOAM Organics Europe International Federation of Organic Agriculture Movements - Europe INAO French National Institute of Origin and Quality (Institut national de l'origine et de la qualité) LÖK German State Working Group on Organic Farming (Landwirtschaftliche Ökologische Kooperation) OP Open Pollination OHM Organic Heterogeneous Material PRM Plant Reproductive Material RSR Rete Semi Rurali SEMAE French Interprofessional Organisation for Seeds and Plants SGAV Danish Agency for Green Transition and Aquatic Environment (Styrelsen for Grøn Arealomlægning og Vandmiljø) StA Standing Committee of LÖK in Germany V.Ö.P Network for organic practice research
D4.1, Updated and improved roadmap 5 1. Summary This deliverable is part of LiveSeeding’s work aimed to enhance transparency in the European organic seed market, harmonize the implementation of European Union (EU) regulations, and support national authorities in building capacity to achieve the goal of phasing out exemptions for the use of non-organic seeds. At the European Union level, there are plans to eliminate all exemptions for the use of non-organic seeds in organic agriculture by the end of 2036. It will be essential to take the necessary strategic steps at the national level to reach this goal. This report examines six national strategies aimed at increasing the production and use of organic seeds (chapter 4). It is based on semi-structured interviews and an analysis of the success factors and challenges faced. The strategies studied are: • Denmark: "Future-Proof Organic Vegetable Seeds" project (2022-2026) • France: "Species Categorization System" • Germany: "Roadmaps to Increase Supply and Demand for Organic Plant Reproductive Material" (2023-2026) • Latvia: "Developing the Necessary Measures to Boost the Use of Organic Seed" project (2023-2025) • Sweden: “Increasing domestic vegetable seed production by 2036” (2022-2028) • Italy: National Plan for organic seed (2025-2028) These initiatives can serve as inspiration and guidelines for implementing similar projects in other European countries. Chapters 5 and 6 provide key take aways/lessons learned and key policy recommendations respectively. The main lessons learned from this report are: the importance of a multi-actor approach and strong stakeholder collaboration; maintaining a comprehensive overview of the current situation (including data on organic seed production, needs, and usage); and ensuring institutional support (such as integration within a National Organic Action Plan).
D4.1, Updated and improved roadmap 6 2. Introduction and background The transition to 100% use of organic plant reproductive material (PRM) is a critical step toward fostering sustainable and resilient agricultural systems. Furthermore, in the EU, derogations allowing the use of non-organic PRM in organic farming will be phased out by 2036. To support a smooth transition, the LiveSeeding project aims to establish a transparent organic seed market across Europe and ensure the harmonised implementation of the regulations for granting derogations. As shown in the LIVESEED project, the organic seed supply, including organic farm-saved seed, is covering on average less than 50% of the organic farm area, with great differences between crops and countries (Solfanelli et al. 2021. 2022). Also, the perception of farmers towards organic seed use varies among countries, marketing strategy and farm size (Orsini et al. 2020). A lack of information about availability and price for organic seed is likely to act as barrier to investment (Padel et al. 2020). With the EU Regulation 2018/848, which came into force on 1 January 2022, the term “plant reproductive material” (PRM) was introduced into legislation for the first time. The regulation defines PRM as “plants and all parts of plants, including seeds, at any stage of growth that are capable of, and intended for, producing entire plants” (EU Regulation 2018/848, Article 3 (17)). As a result, organic farms must use organic PRM or apply for a derogation for non-organic PRM - at least until 2036. The derogation procedure, as outlined in the regulation, is implemented at the national level and is dependent on the availability of organic PRM in their territory and its classification within three derogation categories (see Table 1). National authorities are responsible for assessing the availability of organic PRM in their territories, determining the categorisation of species, subspecies, cultivar groups or cultivars 1 , and then managing the entire derogation process accordingly. 1 The term “cultivar” is used throughout this report, as defined by the LIVESEED project, as a generic reference for any crop, including varieties, breeding lines, populations and organic heterogenous material. The more specific term of “variety” is primarily used when referring to official variety testing.
D4.1, Updated and improved roadmap 7 Table 1: Derogation categories according to EU Regulation 2018/848 The LiveSeeding project examined which countries maintain a Category I list (see example of Category I list in Annex 1). The analysis covered 15 countries, 9 of which have a category I list. When comparing the situation within the different sectors, progress is most advanced in the arable species compared to vegetable species, aromatic plants, fruit and vines. This may be due to the fact that arable species are easier to multiply and often propagated by farmers within their own countries, whereas it is more challenging to produce high quality vegetable seeds especially under organic production (Padel et al. 2021). Moreover, most vegetables cultivars are 2 As of July 2024, the 9 European Union Member States are: Belgium, Denmark, France, Germany, Luxembourg, the Netherlands, Spain and Sweden and Italy. Source: Category1_July2024.pdf and Organic Seeds - Organic Seeds - Plant Protection and Certification - CREA Derogation category Regulatory reference (EU) 2018/848 Availability of organic PRM Description Category I (also called National Annex) Annex II Part I point 1.8.5.6 High Sufficient organic PRM is available from a sufficiently wide range of cultivars. Organic farms cannot obtain derogations for non-organic PRM, even if the preferred cultivar is unavailable - another cultivar must be used. Exceptions apply for research, field trials, cultivar preservation, or product innovation. To our knowledge, only 9 countries work with such a no-derogation list (as of July 2024).2 Category II Annex II Part I point 1.8.5.1 Medium Organic PRM of a cultivar has priority, but if no organic PRM of the preferred cultivar is available, a derogation request can be submitted by selecting a reason specified in the regulation: a) No cultivar of the species is listed in the national database; b) No supplier can deliver the requested PRM on time; c) The requested cultivar is not listed in the database and no suitable alternative is available; or d) It is required for research, field trials, cultivar conservation, or product innovation. Category III Annex II Part I point 1.8.5.7 Low to none Organic PRM of a cultivar has priority. If none is available, general derogations are possible, meaning only the quantity of non-organic PRM used must be documented – no further justification is required.
D4.1, Updated and improved roadmap 14 b. Stakeholder involvement and expert groups In the past, expert groups in Denmark met irregularly, with little follow-up and no concrete actions. This lack of continuity risks lower stakeholder engagement, as participants did not see tangible progress and benefits from their voluntary contributions. With a boost provided by the project, the Danish Agency has renewed its efforts to revitalise expert group meetings. A full-day online meeting was organised with four major crop groups (vegetables, fruit and berries, agricultural crops, and grass and grass mixtures). Unfortunately, the invited seed companies did not attend in the vegetable group meeting, leaving a notable gap in practical expertise on seed supply. According to the project coordinators, it is crucial for seed companies, growers, consultants, and other stakeholders to contribute their practical knowledge on requested cultivars, upcoming seed offers, and specific production challenges. Equally important is ensuring follow-up after each meeting, so that participants recognise the value of their involvement, especially since the expert group can only offer advice. Indeed, the Danish Agency retains the mandate to change derogation categories or implement other actions to boost the organic seed sector. As the organisation of these meetings requires significant time and resources and as authorities may lack insight into the complexity of organic vegetable seed production, the project will support the Danish Agency in coordinating these meetings and in conducting preparatory data collection to enrich discussions. A key component of the project is to extend its scope beyond Denmark by building a European network that connects authorities, seed companies, breeders, and organic farmer organisations across borders. This platform is intended to facilitate exchange and improve the level playing field by sharing successful implementations of expert group models, comparing Category I species, and disseminating knowledge about obstacles in seed production. Quote Tove Mariegaard Pedersen We would be much stronger, if we joined forces with other EU countries, both for increasing demand, and also to show seed companies that we are serious about transitioning to organic seed and moving towards Category I if the supply is available.
D4.1, Updated and improved roadmap 15 c. Success factors and innovations One focal point of the project is to define clear criteria for transitioning species to Category I (no derogations). This includes utilising information from neighbouring countries on their Category I species lists and analysing derogation requests over the past few years in Denmark to assess the availability of organic seeds for various vegetable species. The current Danish categorisation system follows the following rules: • Category I (no derogations): At least 90% of growers must be able to use the available organic seeds. • Category II (individual derogations possible): 10-90% of growers can use organic seed. • Category III (general derogations): Less than 10% organic seed availability. If an entire species cannot be moved to Category I, expert groups, supported by the project, try to redefine the cultivar groups so that specific cultivar groups within that species may still be transitioned. To ensure a smooth adjustment, the project also proposes a warning period before moving species under derogation to Category I, allowing seed companies and growers time to adapt. Key innovation in the expert groups is the development of equivalent cultivar lists to simply the derogation process. These lists are being created in close cooperation with consultants and seed companies, who provide the necessary specialised knowledge. It would enable the Danish Agency to quickly determine whether derogation request for a specific cultivar could be substituted with an equivalent cultivar that possesses similar qualities and is available in organic. For some crops – especially those with less specialised production – these equivalent lists could be shared at the EU level, while still accounting for regional pedo-climatic and farmspecific conditions. d. Challenges encountered Analysis of the Danish market has revealed a significant gap between the supply of organic seed and the required quality and product properties that align with market demand. The current availability of organic seeds in Denmark is too low to meet the needs of professional organic vegetable producers, who must compete with foreign growers in the wholesale market. Unlike agricultural crops, where Denmark has many local breeders and seed producers and a large supply of organic seed,
D4.1, Updated and improved roadmap 16 vegetable seed production is highly dependent on foreign companies. These companies often do not prioritise producing organic seeds for the specific cultivars needed by Danish organic growers due to Denmark’s small production area. Furthermore, organic seed production is often perceived as costly, due to various factors. In particular, the organic vegetable sector – especially for biennial plants – faces a shortage of robust plants that can withstand long growing seasons required for seed production. Thus, suppliers are hesitant to invest in producing sufficient quantities of the demanded cultivars. This reluctance is further reinforced by the continued availability of derogations, which allow the use of non-organic seeds when organic alternatives are not available in sufficient quantity. Effective communication about these specific challenges has proven to be a key aspect of the project, helping to prevent misunderstandings and mistrust among stakeholders, including policy makers and authorities. Raising awareness of the complexities of vegetable seed production and to understand different markets for open-pollinated cultivars and hybrid cultivars is essential to encourage engagement of all stakeholders in finding common solutions. One crucial way to facilitate this dialogue is through local field demonstrations. These demonstrations would allow Danish growers to test cultivars with available organic seed and explore alternative options. However, efforts to secure funding for such initiatives have so far been unsuccessful in the project. e. Outcomes and impact The Danish authorities are implementing the roadmap as proposed by the project, making it a valuable case study for assessing its feasibility, effectiveness, and potential adaptability in other contexts. One of the key takeaways from the Danish project has been the crucial role of communication. The first part of the project focused on national and international dialogue, networking with stakeholders, and ensuring that everyone is aware of the challenges and goals of phasing out non-organic seed. Solutions must be developed collaboratively, involving all stakeholders in the process. The establishment of regular expert group meetings has proven vital for strengthening communication.
D4.1, Updated and improved roadmap 17 The next steps of the project are to further reinforce international networks, focusing on specific crops to highlight demand across borders and provide seed companies with a clearer picture of market potential for organic seed production in key cultivars.
D4.1, Updated and improved roadmap 18 4.2 France: Species categorisation system a. Project background and objectives EU Regulation 2018/848 defines three derogation procedures based on the availability of organic PRM. France has adopted a progressive approach by introducing a fourth derogation category – the Alert Screen – allowing for a more structured transition of species up the ladder, ultimately transitioning them to Category I, which represents full compliance with organic seed use. France’s unique categorisation system functions as an ongoing mechanism to systematically assess and update the category of species within the derogation framework. Table 3 outlines the evaluation process within the derogation framework of the EU regulation. Derogation category Regulatory reference (EU) 2018/848 Description (adapted and translated from this official webpage) Evaluation process in France Category I (no derogations) Annex II Part I point 1.8.5.6 Organic PRM of the species is available in sufficient quantity and cultivar, meaning no derogations are granted (except for exceptional cases). Strict use of organic PRM is required. Assess whether the current status remains justified or if availability issues have arisen. Updates occur swiftly as Category I species are generally well-established. Alert Screen (individual derogations subject to conditions) Annex II Part I point 1.8.5.1 Transitional phase between Category I and II, signaling upcoming changes to suppliers and users. Used when availability is sufficient, but the market needs time to adapt. Evaluate whether the transition timeline remains appropriate. Typically set for two to four years to allow seed companies to scale up production. Oneyear transitions are avoided to ensure supply stability. Category II (individual derogations possible) General case where derogations are permitted if organic PRM is unavailable, and users provide justification. Identify species where organic seed production is expanding. If progress is observed, move the species to the Alert Screen and define a transition timeline to Category I. Category III (general derogations) Annex II Part I point 1.8.5.7 Applied when the supply of organic PRM is considered nonexistent or inadequate. Farmers must declare the quantity of non-organic PRM used. Assess whether any species can be moved to Category II as availability improves. Table 3: Derogation categories and evaluation process in France
D4.1, Updated and improved roadmap 19 The evaluation process is carried out by five multi-actor expert groups in France, each specialising in different crop groups. These groups, coordinated by the National Institute of Origin and Quality (INAO), meet twice a year to review and adjust categorisations based on both expert market knowledge and detailed derogation request data. Experts receive comprehensive data on the number of derogations granted annually, including requested cultivars, plant material types (e.g., tray plants, bare-root plants), and the justification for each derogation. Additionally, they assess stock availability and supply challenges within their sector. This allows them to evaluate whether their production can meet the demand for organic PRM. For instance, if they determine that production can sufficiently cover the needs currently met by derogations, they may propose an upgrade in derogation category. When a species transitions to Category I, three to four consultants are assigned to monitor the availability of organic seed. In case of unforeseen shortages e.g. due to extreme weather events, they receive alerts from users, distributors, or seed producers, allowing for a swift reaction to potential shortages. Only if the organic stock is depleted or critically low, a temporary derogation for the specified cultivar group may be granted for a season or a defined period. While temporary derogations are generally avoided to maintain stability, they are not seen as failures but rather as part of the normal progression towards full compliance. The possibility to react in emergencies and when there is a real need, plays an important role to reach a consensus on the classification of crop species in category 1 (no derogation). b. Stakeholder involvement and expert groups The National Institute of Origin and Quality (INAO) is a public administrative institution with legal personality, under the French Ministry of Agriculture, Food and Forestry. The National Committee on Organic Agriculture (CNAB) is the core of the organic agriculture division within INAO. Its members are appointed by the Ministry and oversee various sector-specific commissions, including the Seeds and Plants Commission, led by President Alban Le Mao. This commission consists of five specialised expert groups focusing on: arable crops, fruit trees, forage crops, vegetables and vine plants (see Figure 3). Each of these expert groups includes one or two CNAB members alongside sector specialists from industry, inter-professional organisations, seed companies, producers, distributors, and farmers. Expert groups, coordinated by INOA, typically meet twice per year to review the status of species one by one. They provide advisory opinions on potential changes in
D4.1, Updated and improved roadmap 20 derogation category, but they do not have decision-making authority. Their recommendations are passed on to the Seeds and Plants Commission responsible for making final decisions. While expert groups focus on technical aspects of organic seed production, the Seeds and Plants Commission considers both technical and policy perspectives. This ensures alignment with the broader principles of organic farming. Although uncertainties may arise, the system avoids lengthy debates within the expert groups, as they are advisory bodies rather than decision-making bodies. The expert groups operate with minimal costs since most participants volunteer their time. Many have a commercial involvement in the sector, while others, such as professionals from organic associations, producer groups, and advisory services, contribute their expertise without direct financial ties to seed sales. Figure 3: Overview of INAO and CNAB Structure, its Commissions (C.), and Expert Groups (EG.). c. Success factors and innovations The composition and diversity of the expert groups plays a key role in the success of the French species categorisation system. Many members of the expert groups have commercial implication in using organic seeds and plants. This leads to a push for stronger regulatory constraints. For instance, producers expressed dissatisfaction when they had to dispose of organic strawberry and raspberry plants, despite numerous derogations for the use of non-organic PRM being granted. PRM users are also well represented, playing a key role in ensuring that the supply aligns with their needs. INAO CNAB C. Transformation C. Vegetal production C. Seeds and Plants EG. Arable crops EG. Fruit trees EG. Forrage crops EG. Vegetables EG. Vine plants C. Livestock C. Beekeeping C. Algae/ aquaculture C. Organic wine
D4.1, Updated and improved roadmap 21 The shared goal of all parties involved is to meet the 2036 target of zero derogations. The objective is well-understood and agreed upon by all expert group members. Rather than debating this objective, discussions are centred on the next steps, i.e. which species should be moved to Category I next and how to achieve that transition. The Seeds and Plants Commission relies heavily on these experts for their decisionmaking, as it would be impossible for them to have in-depth knowledge of the entire sector. Quote Alban Le Mao The key is to manage the diversity of interests and ensure that everyone is brought to the table. The objective must be clear – aiming for 2036 – and the transition to Category I. It should be as smooth and harmonious as possible. To achieve this, it’s essential to involve all relevant stakeholders, including farmers, seed producers, users, and the competent authorities. It can work if we manage to get everyone to move in the same direction. Another key factor is the strong interprofessional representation within the expert groups, particularly through SEMAE, the French Interprofessional Organisation for Seeds and Plants. As a well-established private body, SEMAE unites all unions of stakeholders involved in seeds, including consumers, and is responsible for seed quality control. Its funding primarily comes from operator membership contributions. Its broad and structured network across various industries facilitates effective information sharing and collaboration, ultimately accelerating the transition to organic seed production and supporting regulatory processes. SEMAE helps lay the groundwork, enabling prior reflection before expert group discussions. As a result, experts enter the meetings with well-formed ideas based on earlier preparatory work. Additionally, SEMAE is the main developer and manager of the French national database for organic PRM, which provide precise data on organic seed production and the organic seed requirements. This database serves several purposes: it facilitates derogation requests, showcases the organic seed offers, and acts as an economic tool for data collection and organisation.
D4.1, Updated and improved roadmap 22 d. Challenges encountered Several factors can hinder the transition of species within the categorisation system. While the system has been successful in addressing easier-to-manage species, the focus is now shifting to more difficult-to-multiply species with smaller production volumes. This presents a challenge for the next decade, as bringing these niche species into the Alert Screen category and ultimately achieving Category I will be more complex. Some stakeholders have already expressed concerns that reaching Category I for certain species may be nearly impossible due to unpredictable production patterns. This is the case especially in the vegetable seed sector, which has seen limited progress, with many derogations still in place. A growing concern comes from higher production costs associated with using organic seeds, especially for certain cultivars produced in small quantities, making it challenging for seed companies to invest in both organic and non-organic production. Additionally, organic seeds from other countries may be cheaper, because of less strict rules or lower wages, which poses another challenge as these prices are difficult to match. In response, France is increasingly seeking to coordinate derogation categories across European countries to ensure a more harmonised approach in the future. Additionally, more fundamental issues have emerged. For instance, the existing national database requires improvements to better accommodate perennial plants, which would enhance data quality on availability and the number of derogations. Vine plants and fruit trees are currently classified under Category III mainly due to technical and sanitary challenges in the production of organic PRM. Producers are reluctant to shift to organic due to concerns about quality and economics. Producers are even more reluctant, because they do not understand why organic plants should be imposed on them when the first harvest will often take place more than three years after planting. Many of them consider that a conversion period could be preferable. e. Outcomes and impact The species categorisation system, including the Alert Screen, has been in place in France for over ten years. Several species and subspecies could be moved to Category I and the Alert Screen category, although some challenges remain (see Pogreška! Izvor reference nije pronađen.). An essential part in the species categorisation system is bringing together people form diverse backgrounds, all of whom share a common goal and a clear understanding of the overall objective. Providing stakeholders with early notice of significant upcoming changes has proven crucial in generating
D4.1, Updated and improved roadmap 23 trust and minimising resistance to the transition toward organic seeds. This approach allows them the time to adjust, plan, and begin organic production, ensuring that seed multiplication businesses are not abruptly disrupted by new requirements. Expert group Species Subspecies Derogation category, year of transition to Category I Vegetables Aubergine Long black Category I, 2022 Parsnip OP Category I, 2025 Chinese cabbage Pak Choi / Alert Screen, 2028 Parsnip F1 Alert Screen, 2030 Arable crops Soja Group 1 and 2 Category I, 2022 Potatoes / Category I, 2020 Camelina / Alert Screen, 2026 Chickpeas / Alert Screen, 2028 Forage crops Lucerne / Category I, 2024 Alexandrian clover Multi-cut Category I, 2024 Alexandrian clover Single-cut Alert Screen, 2026 Meadow fescue / Alert Screen, 2026 Table 4: Excerpt from species categorisation system in France (as of January 2025), highlighting a selection of species. The complete document is available here.
D4.1, Updated and improved roadmap 30 d. Challenges encountered From the investigation into the current state of play of organic seed in Latvia, it became clear that a major issue is still the low availability of organic seeds. The organic seed database shows insufficient offers and a low number of cultivars per crop. As it is currently not very user-friendly, options are being explored to change to another approach and platform (e.g., organicXseeds). At the moment, the database also does not facilitate well the inclusion of offers from outside Latvia, which hampers the transition to more organic (vegetable) seed use. Quote Ilze Skrabule There is a general lack of data and data exchange on crop-specific organic agricultural area, organic seed use, seed multiplication area, volume of farm-saved seed and who produces or sells organic seed. Our project aims to bring a clearer picture of the status quo and move forward from there. Additionally, there is a lack of data and lack of data exchange among actors. Data on seed use (untreated conventional, organic or farm-saved) and who sells it is incomplete and needs of organic seed in terms of the organic agricultural land/crop is lacking. It seems that several organisations have a piece of the puzzle of information, but they do not exchange. The Ministry of Agriculture, together with this project tries to connect these stakeholders to bring this information together. e. Outcomes and impact The Latvian national project on organic seed use led to a deeper understanding of challenges, such as the ease of obtaining derogations and the lack of local organic seed production and distribution. It resulted in key recommendations, including a list of equivalent crop cultivars and proposals to improve testing requirements. The project created a recommended cultivar list based on field trials and assessed the organic seed database, identifying the need for better functionality and mandatory reporting. Stakeholder engagement through seminars and workshops fostered collaboration among farmers, seed producers, and policymakers. International
D4.1, Updated and improved roadmap 31 studies provided insights from other countries and the project influences policy discussions on reducing derogations and improving database transparency.
D4.1, Updated and improved roadmap 32 4.5 Sweden: Increasing domestic organic vegetable seed production by 2036 a. Project background and objective Since 2022, several projects, managed by Agroax Association, were initiated in Sweden to increase the domestic production of organic vegetable seeds. While historically, the Swedish seed production allowed to fill domestic needs, the current situation is the opposite: seed production –both conventional and organic– is very limited. As a result, Swedish professional vegetable cultivation has been entirely dependent on foreign varieties and imported seeds. Therefore, the project aimed at reaching 100% organic vegetable seed by 2037, in line with EU requirements. Given the relatively limited demand for organic vegetable seed in Sweden, such objective was identified as feasible. The first project started in 2022 and focused on participatory trials with farmers to test organic seed cultivation. It was funded by the Swedish Board of Agriculture (Jordbruksverket), which shows a true interest for organic seed production. It resulted in an important interest in these questions and led to another project starting in 2024 and running until 2025/6. It is financed by the Ekhaga Foundation and aims to follow participatory research work with farmers and experiment with the production of vegetable seeds. A third longer-term project (2024-2027/8) was initiated to build a national network of seed actors to support sustainable organic seed production in Sweden. Figure 4: Seed cultivation of leeks, “Starozagorski Kamus”, at Martin Fellkvist and and Frida Thörn's Skilleby Garden, Järna. Photo from Elisabeth Ögren. From the organic seed production handbook. Agroax, 2024.
D4.1, Updated and improved roadmap 33 b. Stakeholder involvement and expert groups One of the particularities and strength of the project is that it is farmer-driven, meaning it started with the demands and desires of farmers who are included in all steps of the project. The project began with 8 certified organic farms, mostly small scale, each choosing one or several vegetable cultivars that they would multiply. During the years 2022-2023, they cultivated 17 vegetables species and tested different techniques for cultivation, harvesting, cleaning and carried out analysis of the seeds produced in terms of germination and purity (see Table 5). This hand-on approach allowed to give power and autonomy to farmers in their choice of variety and approach to seed production, as well as mutual learning between farms' experimentation and dissemination of knowledge. Annual Self-Pollinating Species Lettuce, tomato, garden pea Annual Cross-Pollinating Species Broad bean, dill, open-field cucumber, radish, sweet corn, spinach Biennial Cross-Pollinating Species Rutabaga, onion, carrot, parsnip, leek, beet, white cabbage Table 5: Species included in the project on seed cultivation in 2022-2023. Translated from Swedish to English from the organic seed production handbook, Agroax, 2024. Swedish farmers are particularly interested in circular approaches –producing and sharing their own seedsand the project was built on this cultural asset. This also gives rise to the desire to create a vegetable seed exchange network, as is already the case for arable seeds. In parallel, a national stakeholder network has been developed to foster cooperation and alignment of research programmes and policy developments to farmers’ needs. The network brings together farmers, public authorities, gene banks, seed companies and research institute, among others. While this network is promising, it does not serve as an official seed expert group and is not involved in the derogation procedure. c. Success factors and innovations The unique farmers-driven approach enabled several successes. By giving farmers both the choice and responsibility for variety selection and seed production, the project fostered strong engagement, peer learning, and practical results. This approach constituted a solid basis for the creation of the national seed network and the alignment of farmers’ needs with research and policy.
D4.1, Updated and improved roadmap 34 Quote Matti Leino I think if we should be able to restore any kind of seed production in Sweden, we need to do it in a completely different way, starting from the farmers themselves and working from downwards. d. Challenges encountered Working on organic seed production often leads to other reflections and areas of work: organic breeding, advocacy or creating a seed database. In the case of Sweden, the choice was made not to disperse and rather to remain focused on organic vegetable production, which is already in itself a challenge. Several other technical and economic challenges remain. Climatic limitations are an important technical challenge. While several species are well adapted to Nordic conditions, some species remain difficult to produce in Sweden. This therefore raises concerns about the supply of organic seeds. As in other national contexts, the dependence on hybrids for some species is high, and farmers may struggle to switch to open-pollinated varieties. This is particularly the case for species like tomatoes and cucumber, although some open-pollinated varieties are becoming increasingly interesting. The economic feasibility is another area of concern as seed production is not economically competitive with imported seeds. Some positive steps were made by successfully selling small seed packages, but the economic viability remains a concern. e. Outcomes and impact One of the key takeaways from the project is that restoring vegetable seed production in Sweden is possible, even if not for all crops. Initial concerns about the difficulty of producing high-quality seeds under Nordic conditions have been partly overcome, with encouraging results demonstrating that high-quality organic seed can be produced locally by farmers. The project also showed that small-scale seed production is viable in Sweden— something that was previously considered unrealistic. Unlike vegetable farming, seed production requires relatively little space, which is well-suited to Sweden’s scale of
D4.1, Updated and improved roadmap 35 demand. This shift has been supported by the development of modern equipment tailored to small-scale organic farming, making the work more accessible and efficient. Finally, this project allowed to develop and publish a handbook which summarize the lessons and experience from the project financed by the Swedish Board of Agriculture. The handbook is divided into several sections, outlining the importance of reintroducing seed production in Sweden, the trials and techniques tested during the project, and practical guidance for organic seed cultivation. It also addresses regulatory frameworks, economic aspects, seed-borne pests, and best practices for ensuring seed quality and resilience.
D4.1, Updated and improved roadmap 36 4.6 Italy: National Plan for organic seeds a. Project background and objective In September 2023, after more than two years of stakeholder negotiations, the Italian Ministry of Agriculture adopted a National Plan for organic seeds (Piano Nazionale delle Sementi Biologiche - PNSB), as part of broader efforts to promote the protection, development and competitiveness of organic agriculture in Italy. The overarching objective is not only to increase the availability of organic seeds but also to improve their quality —genetic, phytosanitary, and technical— with a specific focus on varieties adapted to organic systems and diverse environmental conditions. With a budget of €2 million over three years of implementation, the implementation phase is planned to start in September 2025. Unlike the two previous plans on organic seeds, which mainly focused on research, this new plan takes a broader and more integrated approach. It is divided into six “macro areas” and involves a diverse range of partners, including researchers, farmers and value chain actors: • State of the art, aims at analyzing the organic seed sector and its evolution over time, to address the current lack of data. Targeted surveys and estimation of the market value of the sector will be conducted. • Supporting value chain in organic seeds. This macro-area aims at identifying actions to support the production, dissemination, and use of organic seeds. The creation of technical committees for the main supply chain is foreseen (cereals and fodder, horticulture, fruit, nurseries). • Innovation, which will conduct participatory and decentralized plant breeding through collaboration with farmers, technicians, and researchers. The objective is to select plants and develop evolutionary populations that meet the needs of organic farmers and to distribute them. Additionally, networks to test varieties under organic conditions will be created. • Quality of seeds and plant propagation material. This macro-area seeks to manage the organic seed database and implement European measures for the registration of organic varieties and for the marketing of organic heterogeneous material (OHM). Planned actions include identifying issues in the nursery supply chain for the production of certified organic plants and proposing technical and scientific solutions. Guidelines for protocols for the production of organic propagation material will be developed. • Dissemination, communication and training, to promote information on the plan. Articles and publications will be published, and conferences and open days will be organised.
D4.1, Updated and improved roadmap 37 • Coordination, to ensure consistency with the overall objectives and between the different macro-areas and to promote synergies. Meetings with project participants will be arranged, and progress reports will be published. The plan is not directly managed by the Ministry, but by the Council for Agricultural Research and Economics (CREA). CREA DC (Plant Protection and Certification) serves as the overall coordinator, with different CREA research centers responsible for each macro-area (see Figure 5). Figure 5: The six macro-areas of the National Plan for organic seed and their coordinators. Acronyms are: CREA-PB: CREA’s Policy and Bioeconomy Research Center; CREA-CI: CREA’s Centre for Cereal and Industrial Crops; CREA OF: CREA’s Centre for Vegetable & Ornamental Crops, CREA DC: CREA’s Centre for Plant Protection & Certification, CREA OFA: CREA’s Centre for Olive, Fruit & Citrus Crops, CREA VE: CREA’s Centre for Viticulture & Enology. Source: CREA-DC. b. Stakeholder involvement and expert groups Stakeholders were actively involved in the plan’s design phase. This collaborative phase allowed for the definition of macro-areas and inclusion of innovative activities, such as participatory breeding with farmers, which otherwise might have been overlooked. This co-creation approach opens the door to the inclusion of various stakeholders during its implementation, from researchers and farmers to value chain actors.
D4.1, Updated and improved roadmap 38 The expert group on organic seeds was set up in 2017 by the ministerial decree n. 15130 and is supporting the Ministry of Agriculture for the definition of the red (Category I), yellow (Category II), and green lists (Category III) related to the derogation process. In 2021, alfalfa and Trifolium alexandrinum were added in the red list, and in 2023, durum and soft wheat, barley, common and Byzantine oat, emmer and monococcum. 4 In 2025, although 9 species are in the red list, the number of derogations remains high and stable, around 90.000 per year (see Figure 6). The group is composed of 12 experts (3 from the Ministry, 3 from the Regions and 6 from farmers’ trade unions) plus 5 experts from the seed sector, which includes Rete Semi Rurali and Assosementi. Usually, the expert group meets three or four times per year, and its advice is validated by a ministerial decree. Figure 6: Trend of derogations in Italy from 2004. Source: CREA-DC. c. Success factors and innovations In general, an increase of the surface dedicated to the production of organic seeds is observed. In 2024, 31,567 hectares were dedicated to organic seeds, with an increase of around 20% (see Figure 7). It means that more organic seeds are produced in Italy, although it is impossible to know if the seeds are produced for export or for Italian 4 Organic seeds, CREA [consulted the 22/07/2025]. Organic Seeds - Organic Seeds - Plant Protection and Certification - CREA
D4.1, Updated and improved roadmap 39 organic farmers. In 2024 the surface dedicated to organic seeds was 13,6% of the total surface dedicated to seed production, a good result considering that 10 years ago, this figure was around 4%. Figure 7: Graph on the evolution of the Italian sowing areas for organic seed production in hectares since 2010.Source: CREA-DC. The National Plan’s emphasis on participatory plant breeding is one of its most promising features. This approach recognises the value of farmers’ experiential knowledge and the need to include them in research programmes. By involving farmers directly in the selection and breeding process, the plan will enhance the development of varieties that are not only resilient and diverse, but also better suited to the realities of organic farming. The focus on organic heterogeneous material also reveals the willingness to develop genetically diverse and resistant populations. The National Plan foresees also the creation of an organic testing network for agricultural species, a fist relevant step for registering organic varieties. Another strength lies in the long-term goal of progressively reducing derogations, by improving both the quantity and quality of available organic seeds and identifying a list of “equivalent varieties” that could replace conventional ones without harming organic production. This reflects a strategic approach to phasing out derogations by expanding the portfolio of suitable varieties for organic farming.
D4.1, Updated and improved roadmap 46 with expert insights and to foster confidence in market development by clearly communicating which crops will be phased out by 2036. Creating regular exchanges between representatives of EU member state authorities who handle derogations daily, along with seed experts and control bodies from neighbouring countries, will foster a more harmonised approach and improve understanding of regional differences.
D4.1, Updated and improved roadmap 47 References and further reading Bruszik, A.; Raaijmakers, M.; Messmer, M. A roadmap and vision towards 100% organic seed in Europe. LIVESEED, 2021. https://www.liveseed.eu/wpcontent/uploads/2021/07/Roadmap-Final.pdf Orsini, S.; Costanzo, A.; Solfanelli, F.; Zanoli, R.; Padel, S.; Messmer, M.M.; Winter, E.; Schaefer, F. Factors Affecting the Use of Organic Seed by Organic Farmers in Europe. Sustainability 2020, 12 , 8540. https://doi.org/10.3390/su12208540 Padel, S., Orsini, S., Solfanelli, F., & Zanoli, R. (2021). Can the Market Deliver 100% Organic Seed and Varieties in Europe? Sustainability , 13 (18), 10305. https://doi.org/10.3390/su131810305 Raaijmakers, M.; Bruszik, A.; Sommer, M.; A national roadmap towards 100% organic seed, 2021. https://liveseed.eu/wp-content/uploads/2021/09/Policy-briefRoadMap-National-Authorities_final_compressed-4.pdf Raaijmakers, M.; Bruszik, A.; Sommer, M.; A national roadmap towards 100% organic seed, LIVESEED 2021. https://liveseed.eu/wp-content/uploads/2021/09/Policybrief-RoadMap-National-Authorities_final_compressed-4.pdf Raaijmakers, M.; Heining, N.; van der Velden, L. Regulation and policy on organic seed in five North-western European countries. LIVESEED, 2020 https://liveseed.eu/wp-content/uploads/2021/11/LIVESEED-brochure-organicseed-in-5-NWE-countriesDEF.pdf Raaijmakers, M.; Heining, N.; Solfanelli, F.; Ozturk, E.; Zanoli, R.; Feher, F.; Schäfer, F.; Toncea, I. Creating incentives for farmers to use organic seed. LIVESEED, 2020. https://www.liveseed.eu/wpcontent/uploads/2020/11/FNL-BOOKLET-6-WEB-.pdf Schäfer, F.; Gutzen, K.; Raaijmakers, M.; Meyer, K.; Gatzert, X.; Sommer, M.; Bruszik, Á.; Messmer, M.M. Securing Commitments from Stakeholders in 10 EU Member States—The Organic Seed Declaration to Foster Stakeholder Involvement. Sustainability 2022, 14 , 9260. https://doi.org/10.3390/su14159260 Solfanelli, F.; Ozturk, E.; Zanoli, R.; Orsini, S.; Schäfer, F. The State of Organic Seed in Europe. LIVESEED, 2021. https://www.liveseed.eu/wpcontent/uploads/2021/03/Booklet2-LIVESEED_2021_web.pdf ; https://orgprints.org/id/eprint/39800/
D4.1, Updated and improved roadmap 48 Solfanelli, F., Ozturk, E., Dudinskaya, E. C., Mandolesi, S., Orsini, S., Messmer, M., Naspetti, S., Schaefer, F., Winter, E., & Zanoli, R. (2022). Estimating Supply and Demand of Organic Seeds in Europe Using Survey Data and MI Techniques. Sustainability , 14 (17), 10761. https://doi.org/10.3390/su141710761
D4.1, Updated and improved roadmap 49 Annexes Annex 1: List of crop species in Category 1 (no derogations) for Denmark, France, Germany, Latvia, Italy and Sweden (July 2024) 5 DENMARK • Bean: Field Bean • Buckwheat • Calendula arvensis • Chrysanthemum sp.: Moon Daisy, Ox Eye Daisy • Common Spruce: Whitewood, Norway Spruce • Cucumber • Fir: Blue Noble Fir, Nordman Fir • Papaver sp.: Common Poppy • Serradella: Ornithopus sativus • Phacelia • Potato • Radish: Winter Radish, Tillage Radish • Sanguisorba sp.: Sanguisorba minor, Great Burnet • Flax (Linseed) • Fodder Kale • Garlic • Hill mustard: Warty cabbage • Lactuca sp. (lettuce): Cos Lettuce • Lolium sp.: Italian Ryegrass • Luffa sp.: Dishcloth gourd, Luffa Sponge, Smooth Loofah, • Sponge gourd • Lupinus sp. (lupin): White Lupin, Yellow Lupin, Blue Bean, • Perennial lupin • Mixtures: Catch crop mixtures, Green manure mixtures • Mung Bean (Golden Gram) • Soybean (Soya) • Spreading Bentgrass (Creeping Bent) • Sunflower • Timothy • Trifolium sp: Squarrose Clover, White Clover, Crimson Clover, 5 Category1_July2024.pdf
D4.1, Updated and improved roadmap 50 • Egyptian Clover • Turnip • Triticale: Winter Triticale • Vicia sp. (vetch): Common Vetch, Winter Tares, Winter Vetch • (Hairy Vetch, Fodder Vetch) • Viola arvensis FRANCE • Alfalfa • Aubergine • Barley • Bean: Soybean • Beetroot • Cabagge: White cabbage, Savoy cabbage • Carrot • Chicory • Courgette • Cucumber • Fennel • Field bean • Field pea • Fooder radish • Gherkin, smooth or thorny • Kohlrabi • Lactuca sp. (Lettuce) • Leek: Hybrid Leeks, Leek op (= non-hybrid) • Lolium sp. (ryegrass) • Lucerne • Maize • Mustard: White Mustard • Oat • Onion • Orchard grass • Parsley • Phacelia • Potato • Pumpkin • Rye • Spelt • Sunflower • Sweet pepper
D4.1, Updated and improved roadmap 51 • Tomato • Trifoium sp. (clover) • Triticale • Wheat GERMANY • Bean: Climbing French Bean (Stick Bean, Pole Bean) • Buckwheat • Rye: Winter Rye • Sugar beet • Cress: Land Cress • Cucumber • Endive • Field Bean • Lupinus sp.(lupin): Blue Lupin • Lolium sp.: Italian Ryegrass, Perennial Ryegrass, • Westerwolds Ryegrass • Maize: Maize, Corn • Mustard: White Mustard • Onion, Onion (seed) • Potato* • Pumpkin: Hokkaido • Sweet pepper • Trifoilum sp.: Egyptian Clover (Berseem) Persian Clover, • Reversed Clover, Stawberry Clover, Crimson Clover • Triticale: Winter Triticale • Vicia sp. (Vetch): Common Vetch, Winter Tares, Winter Vetch • (Hairy Vetch, Fodder Vetch), Vicia pannonica • Wheat: Winter Wheat *Exceptions are possible in the period from 1/10/20xx to 31/01/20xx Latvia • No category 1 crops listed Sweden • Watercress, Land Cress • Tulipa sp. • Winter Wheat
D4.1, Updated and improved roadmap 52 Italy • Alfalfa • Troflium alexandrinum • Durum • Soft wheat • Barley • Common oat • Bizantine oat • Emmer • Monococcum. Annex 2: Questionnaire Introducing the project: • What is the objective of the project? • What is the funding structure for the project, and what sources of funding are being utilised? • Who are the key stakeholders involved in this project, and what roles do they play? • What is the duration of the project? Seed expert groups: • Can you describe the PRM expert groups that are in place in your country and how they are involved in the project? • How often do the PRM expert groups meet? Which crops do they focus on? What is their mandate and how are decisions made within the expert groups? Vegetative propagation material: • What is the current status of vegetative planting material? Does the project also address challenges related to the supply of vegetative planting material? Lessons-learned: • What are key success factors/lessons learned that other countries should focus on when starting similar projects aiming for 100% organic PRM use? • Are there any specific success stories or case studies from your project that highlight its impact so far? • What challenges should be anticipated, and how can they be addressed early in the process? • What role does stakeholder involvement play in achieving organic PRM goals, and how can countries encourage broad participation?
D4.1, Updated and improved roadmap 53 Policy recommendations: • Which policies or support mechanisms (e.g., financial) are necessary? Which are in place in your country? • What key recommendations would you offer to policymakers in other countries looking to implement similar national projects?