Guidelines for OHM notification

LiveSeeding Project Deliverable 2.2 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. Guidelines for OHM notification Authors: Carl Vollenweider, Maike Bender (DFH) Szilvia Bencze, Mária Megyeri (ÖMKi) Diego Guidotti (AEDIT), Charlotte Bickler (ORC) Deliverable Number D2.2 Work Package WP2 Deliverable type Report Dissemination level Public Deliverable Lead partner Dottenfelder Bio-Saat GmbH (DFH) Due date 31.05.2025 Submission date 30.05.2025 Version v1.0 Reviewers Charlotte Bickler (ORC), Matteo Petitti (RSR), Gyöngyi Györéné Kis (ÖMKi), Frederic Rey (ITAB), Mariano Iossa (FiBL Europe) Contact [email protected] D2.2, Guidelines for OHM notification 1 History of changes Version Date Author Comments v0.1 18 Nov 2024 Carl Vollenweider Maike Bender First structure v0.2 16 Apr 2025 Carl Vollenweider Maike Bender First draft v0.3 2 May 2025 Carl Vollenweider Maike Bender Szilvia Bencze Mária Megyeri Diego Guidotti Advanced draft v0.4 12 May 2025 Charlotte Bickler Additions to section 3.1 and review v0.5 12 - 15 May 2025 Gyöngyi Györéné Kis Frederic Rey Matteo Petitti Carl Vollenweider Reviews, addition of summary v0.6 22 May 2025 Carl Vollenweider, Maike Bender Integration of the different versions, addition of section 1.3 v1.0 23 May 2025 Mariano Iossa Final review before submission D2.2, Guidelines for OHM notification 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 16 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, climateneutral, 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). 15 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. D2.2, Guidelines for OHM notification 3 Table of Contents SUMMARY .............................................................................................................. 6 INTRODUCTION .............................................................................................. 8 DEFINITION OF OHM ....................................................................................................... 8 LEGAL BASIS ................................................................................................................... 11 ADVANTAGES AND PROPERTIES OF OHM ...................................................................... 14 NOTIFICATION PROCEDURE ......................................................................... 16 BASIC OUTLINE ............................................................................................................... 16 STEPS OF THE PROCEDURE .............................................................................................. 17 NOTIFICATION DOSSIER .................................................................................................. 22 EXAMPLE OF A NOTIFICATION FORM .............................................................................. 26 COMPARISON OF NOTIFICATION FORMS FROM DIFFERENT COUNTRIES ......................... 29 IMPLEMENTING THE NOTIFICATION PROCEDURE ....................................... 30 TOOLS FOR OHM NOTIFICATION ................................................................................... 30 3.1.1 Software tools .................................................................................................... 30 3.1.2 LIVESEED toolbox .............................................................................................. 31 RESULTS OF A LIVESEEDING SURVEY ON OHM NOTIFICATION ...................................... 32 POST-MARKETING, RISK-BASED CONTROLS OF PRM OF OHM ..................................... 33 MAINTENANCE BREEDING OF OHM ............................................................................... 36 EXPERIENCE FROM DIFFERENT COUNTRIES ................................................. 37 OVERVIEW OF NOTIFIED OHM IN EUROPE .................................................................... 37 FRANCE ........................................................................................................................... 39 GERMANY ....................................................................................................................... 40 ITALY .............................................................................................................................. 44 POLAND .......................................................................................................................... 47 AUSTRIA ......................................................................................................................... 49 DENMARK ....................................................................................................................... 50 HUNGARY ....................................................................................................................... 50 UNITED KINGDOM .......................................................................................................... 52 GROWING AREA OF OHM IN EUROPE ............................................................................ 53 CONCLUSION AND RECOMMENDATIONS .................................................... 56 REFERENCES ......................................................................................................... 60 ANNEX 1: LIST OF NOTIFIED OHM ......................................................................... I D2.2, Guidelines for OHM notification 4 ANNEX 2: TABLE ON THE COMPARISON OF NOTIFICATION FORMS FROM FRANCE, GERMANY, ITALY AND THE UK .............................................................. IV List of figures Figure 1: Winter wheat OHM 'Liocharls' with awned as well as unawned ears and ears of different colours and shapes. This OHM is officially notified in Germany. ................ 9 Figure 2: The timeline of the five main steps of the OHM notification procedure ..... 17 Figure 3: Total growing area of OHM in Europe in the vegetation period 2023/24 ... 54 Figure 4: Growing area of OHM in Europe by country and crop species in the vegetation period 2023/24. UK: United Kingdom. Other countries: include Belgium, Ireland and the Netherlands. ................................................................................................... 54 List of tables Table 1: Comparing the two terms “OHM cultivar” and “PRM of OHM” ........................ 12 Table 2: Examples of requested quantities for the representative PRM (seed) samples in the notification procedure in France and Germany ....................................................... 19 Table 3: Notification form of the German Federal Plant Variety Office (Bundessortenamt). Version as of April 2025. ...................................................................... 27 Table 4: Overview of officially notified OHM in Europe, specifying the country where OHM are notified, number of notified OHM per country, crop species as well as the number of OHM per crop species and the growing area in the vegetation period 2023/24. ........................................................................................................................................ 37 Table 5: List of notified OHM in the EU (not complete). ...................................................... I Table 6: Comparison of notification forms from France, Germany, Italy and the United Kingdom (UK) (adapted from Guidotti & Marchi 2025). ..................................................... IV D2.2, Guidelines for OHM notification 5 List of abbreviations API Application Programming Interface BRAPI Breeding Application Programming Interface CCP Composite Cross Population CPVO Community Plant Variety Office DP Dynamic Population DR Delegated Regulation DUS Distinctness, Uniformity and Stability EC European Council ECO-PB European Consortium for Organic Plant Breeding EEC European Economic Community EU European Union Fn Filial generation n after the crossing of parental genotypes FS Farmers’ Selection HM Heterogeneous Material MAGIC Multi-parent Advanced Generation Inter-Cross Population OHM Organic Heterogeneous Material OR Organic Regulation PRM Plant Reproductive Material Sx Selfing generation x UPOV International Union for the Protection of New Varieties of Plants VCU Value for Cultivation and Use WP Work Package D2.2, Guidelines for OHM notification 6 Summary Organic Heterogeneous Material (or OHM for short) is a novel cultivar category introduced in the EU Organic Regulation No. 2018/848. It is characterised by a high level of genetic diversity as well as its dynamic nature allowing it to adapt to different growing conditions. OHM may be only marketed after it is notified by means of a descriptive dossier, which is sent to the competent authorities together with a representative sample. The description of the OHM consists of five main elements. Among them, there are a phenotypic characterisation, documentation of agronomic traits, the parental material and breeding process. The objective of this deliverable is to provide background information, guidelines for OHM notification and recommendations on the basis of past experience. Target groups of this document include: breeders, seed producers, responsible authorities and policy makers at the national and European level. Section 1 provides the basic definition, legal framework, advantages and properties of OHM. Section 2 provides guidelines on how the elements of the OHM description may be presented by the applicant. In addition, the main steps of the notification procedure from the preparation of the documents to the listing and marketing of the OHM are explained in detail. Sections 2.4 and 3.1 present notification forms provided by the authorities to enter the information of the dossier and the open-source software tool OHMTrack facilitating the notification procedure, respectively. The remainder of section 3 is devoted to an outlook on the post-marketing, risk-based official controls for Plant Reproductive Material (PRM) of OHM as well as on maintenance breeding. Section 4 is dedicated to the presentation of experience from different EU Member States on the implementation of the notification procedure, including an overview of all the 49 OHM cultivars of seven agricultural and nine vegetable species currently notified in eight EU Member States. Finally, in section 5, conclusions and policy recommendations are developed to improve the implementation of the regulatory framework for OHM, relating to the notification procedure, the official controls of PRM marketing as well as the policy and legal basis. These can be summarised as follows: - Clear and comprehensive cultivar descriptions should be mandatory and publicly accessible to ensure transparency and traceability. - Field trials for agronomic and quality traits should be expanded, including targeted and low-cost testing schemes. D2.2, Guidelines for OHM notification 7 - Competent authorities must have the power to request corrections or terminate notifications when needed. - PRM certification bodies should oversee risk-based post-marketing controls, with roles clearly defined alongside organic control authorities. - Labelling requirements must be strictly enforced to avoid misleading claims. - Finally, while OHM may benefit conventional agriculture, its regulatory framework must remain stable to safeguard existing value chains and protect the interests of the organic sector. D2.2, Guidelines for OHM notification 8 Introduction Definition of OHM ‘Organic Heterogeneous Material’ (hereinafter referred to as OHM) is a novel cultivar category introduced in the European Regulation (EU) No. 2018/848 on organic production and labelling of organic products (the “Organic Regulation”). A key feature of OHM is that it does not meet the variety definition set out in Council Regulation (EC) No. 2100/94, particularly in terms of uniformity among individual plants within the material. Instead, OHM is defined as follows (Box 1): Box 1: Basic definition of Organic Heterogeneous Material (OHM) in the European Organic Regulation (EU) No. 2018/848, Art. 3 (18) “OHM means a plant grouping within a single botanical taxon of the lowest known rank which: (a) presents common phenotypic characteristics; (b) is characterised by a high level of genetic and phenotypic diversity between individual reproductive units, so that that plant grouping is represented by the material as a whole, and not by a small number of units; (c) is not a variety within the meaning of Art. 5 (2) of Council Regulation (EC) No. 2100/94; (d) is not a mixture of varieties; and (e) has been produced in accordance with this Regulation.” There are two important defining properties of OHM (at a genetic and phenotypic level). The first property follows directly from the basic definition in Box 1: 1. OHM must exhibit a certain minimal degree of heterogeneity between its constituent plants for some phenotypic characteristics. These may include characteristics proposed by the ‘International Union for the Protection of New Varieties of Plants’ (UPOV) (such as the presence or absence of awns or different ear colours in wheat, see Fig. 1). Note that it is not a contradiction that the OHM must also present other common characteristics. Of particular importance in that regard may be agronomic and quality traits (such as yield, baking quality and specific disease resistances in the case of the wheat OHM from Figure 1). The second important defining property of OHM is clarified in Recital (6) of the Delegated Regulation (EU) No. 2021/1189 (which supplements the Organic Regulation with more detailed rules on the marketing regime for OHM, see also Section 1.2): D2.2, Guidelines for OHM notification 15 also Ceccarelli et al. 2010 or Weedon et al. 2023). Some genotypes in heterogeneous materials may tolerate better prolonged dry periods and others higher precipitation, reducing the risks of yield loss. Heterogeneous cultivars of wheat and barley showed a higher (dynamic and static) stability of yield and quality traits across growing environments compared to pure line varieties (Weedon & Finckh 2019, Raggi et al. 2017, Döring et al. 2015, Vollenweider et al. 2021). Bocci et al. (2020) found that heterogeneous wheat populations evolving under drought conditions in Sicily became the highest yielding test entries in their trials. 3. Adaptation to specific locations and growing conditions. Changes of heading time were observed by Goldringer et al. (2006) after cultivating wheat populations for 10 generations in contrasting locations in France. More recently, Schneider et al. (2024) using whole-genome pool-sequencing molecular techniques found specific adaptations to conventional and organic farming conditions in barley populations, in particular with respect to traits associated with root morphology. These findings are in line with results from Bertholdsson et al. (2016) showing that the early vigour traits root and shoot length of wheat populations were significantly increased within five generations maintained under organic relative to conventional management (see also Bhaskar et al. 2019 and Raggi et al. 2022). Heterogeneous materials should therefore be particularly suitable for organic and low input farming (Murphy et al. 2004). 4. OHM have the potential to conserve and increase genetic diversity within the farming system. Dynamic management strategies were proposed where heterogeneous materials are grown at multiple locations in order to maintain genetic diversity (Henry et al. 1991, Goldringer et al. 1998, Enjalbert et al. 2011). Heterogeneous populations may also serve a “mass reservoirs of variability” (Simmonds 1961) from which lines for standard variety breeding programs can be extracted (Suneson 1956, Harlan 1956). Therefore, OHM and standard variety breeding should be seen as complementary rather than as mutually exclusive approaches. Each strategy has its own unique opportunities and challenges. OHM may offer additional socio-economic benefits: It may contribute to a more resilient local supply of PRM allowing farmers to save their own seed or contribute to regional value chains focusing on marketing OHM with special taste or other characteristics. Traditional landraces may be preserved and their cultural and economic value harnessed. Most studies found that heterogeneous materials of self-pollinating cereal crops exhibit comparable (mean) yield levels and quality traits compared to standard pure line varieties. OHM offer the important advantages mentioned above. Potential challenges such as the lack of incentives for breeders, insufficient breeding gains, susceptibility D2.2, Guidelines for OHM notification 16 to seed-borne diseases (see section 3.3 for more details) or natural selection of detrimental alleles within the population (Knapp et al. 2020) are addressed within the LiveSeeding project and offer interesting perspectives for future research. It is important to ensure that the implementation of regulations and associated procedures create an enabling environment for the advantages of OHM to be realised and its properties maintained. Whilst a number of OHM are now notified and in production across Europe, there remains a lack of clarity in some countries as to how the legislation is or will be implemented. Below, in sections 3 and 4, more detail is outlined on procedures in place on time of publication of this report (May 2025). Notification procedure Basic outline Plant Reproductive Material (PRM) of OHM may only be marketed after the notification of the OHM cultivar. The corresponding legal framework is contained in Article 13 of the Organic Regulation (EU) No. 2018/848 and mainly in Articles 4, 5 and 8 of the Delegated Regulation (EU) No. 2021/1189. As it was pointed out in section 1.2, the notification procedure of an OHM cultivar may be understood as a simplified analogue of the registration of a standard variety in the sense of the Council Regulation (EC) No. 2100/94. An OHM cultivar can be notified by a natural or legal person referred to as the supplier or applicant in the Organic Regulation (EU) 2018/848 or also as the notifier in this report. The supplier does not necessarily have to be registered as a professional plant breeder 4 . Article 13 (2) of the Organic Regulation (EU) 2018/848 foresees the competent authorities referred to in the 11 sectoral directives of the ‘horizontal’ PRM legislation as the official body that implements the notification procedure in an EU member state. In many member states these are the Plant Variety Offices, see sections 2.5 and 4 for examples. The notification is made by means of a descriptive notification dossier (see Box 5). This dossier is sent by the supplier to the official body. Within three months after the dossier was sent in, provided that no additional information was requested or a formal refusal was communicated, the notification shall be either expressly or implicitly acknowledged by the official body. Finally, the responsible body proceeds to the official listing of the OHM, which shall be free of charge to the supplier. 4 Although e.g. in Germany the notification form can only be accessed if the applicant is registered with an official identification number. D2.2, Guidelines for OHM notification 17 Box 5: The notification dossier must contain (according to Article 13 (2) of the Organic Regulation (EU) No. 2018/848): (a) the contact details of the applicant; (b) the species and denomination of the OHM; (c) the description of OHM (see section 2.3); (d) a declaration by the applicant concerning the truth of the elements in points (a), (b) and (c); and (e) a representative sample. The steps involved in the notification procedure of OHM are described in more detail in the following section 2.2 and the notification dossier for OHM is described in section 2.3. Steps of the procedure An overview of the main steps of the notification procedure of OHM is given in Figure 2. Figure 2: The timeline of the five main steps of the OHM notification procedure D2.2, Guidelines for OHM notification 18 Each of the steps in Figure 2 is explained in more detail below: 1. Preparation of the notification dossier The notifier will often be the breeder or farmer who developed the OHM. It is also possible that the notification is delegated to a third party, e.g. a seed producer. In any case, the necessary information for the dossier has to be generated and collected already during the development phase of the OHM. The task has to be completed before the dossier is filled in and it may take several years to achieve this. The requested information in the dossier includes according to Article 4 (1) of the Delegated Regulation (EU) No. 2021/1189 (see also section 2.3 for more details) the: • phenotypic characterisation of the OHM (of key common characteristics as well as its heterogeneity), • documentation of agronomic and quality traits (including available results from field trials) and the • description of the breeding process. Some of this information will be collected during the breeding process itself, but it may require additional recordings and visual scorings (e.g. UPOV/CPVO descriptors). For the assessment of the agronomic and quality traits options are to carry out (exact) field trials or the OHM candidate may be included in (regional) postregistration trials. Frugal testing schemes may play an important role as they are developed in the WP2 of the LiveSeeding project (see deliverable D2.5: Synthesis of cultivar evaluation case studies, recommendations and follow-up plans; due date April 2026). Depending on the relevant parameters, e.g. to assess specific resistance to abiotic stress or suitability for low input conditions (see section 2.3), additional targeted testing methods can be used. In many EU Member States the competent authorities provide a form, in which the information for the dossier can be entered. These forms greatly facilitate the notification procedure (see sections 2.4 and 2.5 for examples). Finally, sufficient quantities of PRM for the representative samples must be produced and kept available for the notification. 2. Sending in the dossier According to Article 13 (2) of the Organic Regulation (EU) No. 2018/848 the notification dossier shall be sent in by registered letter, or by any other means of communication accepted by competent authority, with confirmation of receipt requested. The time span of the three months granted to the authority to check the documents will start with the date shown on the return receipt. However, if additional information is requested the time period will be extended by another three months. As an integral part of the notification, a representative sample of PRM of the OHM must be delivered to the responsible bodies. The shipping address is indicated in D2.2, Guidelines for OHM notification 19 publicly available documents, e.g. in France by the Variety and Seed Study and Control Group (GEVES) 5 , in Germany by the Federal Plant Variety Office (Bundessortenamt) 6 and in Italy by the Council for Agricultural Research and Economics (CREA). These documents also specify requirements on the representative PRM samples of OHM. First of all, the PRM samples of OHM must comply with the requirements on sanitary quality, analytical purity and germination as they are laid out in Article 6 of the Delegated Regulation (EU) 2021/1189. In particular, these include the provisions of Regulation (EU) 2016/2031 on protective measures against pests of plants. Second, the PRM of the representative sample must be organically produced. In order to demonstrate this, the organic control number of the organic control body (and the farm) should be indicated on the delivery note. This information should be checked by the competent authority. In Germany, the Federal Plant Variety Office requires that the PRM must not have undergone any treatments.6 Finally, the requested quantities for the representative samples for different crop species are specified by the authorities, often in publicly available lists. Examples from France and Germany are presented in Table 2 below. Table 2: Examples of requested quantities for the representative PRM (seed) samples in the notification procedure in France and Germany. Lists containing this information are available online.5,6 The quantities from France should be considered as indicative. In Germany, also a minimum germination of the sample is required, which is added in the last column of the table. Crop species Quantity requested in France Quantity requested in Germany Minimum germination in Germany Agricultural species Cereals, e.g. barley, rye, wheat 1 kg 1 kg 85% Maize 5,000 grains 900 g 90% Rapeseed 250 g 60 g 85% Mustards 250 g 150 g 85% Small-grain legumes, e.g. clover, sainfoin, and grasses - 150 g 80% Large-grain legumes, e.g. faba bean, lupine, peas - 600 g, 700 g (pea) 80%, 75% (blue lupine) Vegetable species Carrot 50 g 15 g 65% Brassicaceae family: Brussels sprouts, cauliflower, Chinese cabbage, headed cabbage 30 g 900 seeds, 1,200 seeds 75% 5 https://www.geves.fr/wp-content/uploads/echantillons-de-semences-MHB.pdf [last accessed 19th April 2025] 6 https://www.bundessortenamt.de/bsa/media/Files/Bekanntm/BNr_2221.pdf [last accessed 19th April 2025] D2.2, Guidelines for OHM notification 20 (Chinese cabbage) Melon/water melon 50 g 150 seeds 75% Tomato 5 g 600 seeds 75% Vegetable/sweet maize 500 g 300 g 85% Zucchini 100 g 150 seeds 75% Overall, the requested quantities are very similar in the two countries, with a tendency to be higher in France. For crop species not contained in the official list, the competent authority shall be contacted in France. In Germany, in that case, the representative sample must only be sent in at the request of the official body. The Federal Plant Variety Office also requires a minimal germination for the representative PRM sample of the OHM (see the last column of Table 2). 3. Acknowledgement of the notification The notification dossier will be reviewed by the competent authority. If the dossier is incomplete, or if it does not comply with requirements of the Organic Regulation (EU) 2018/848 7 , the authority can request additional information or even formally reject the notification. In the former case, the three months-time period for checking the documents will be extended by another three months. If the dossier is positively evaluated the Organic Regulation (EU) 2018/848 foresees that the notification will be either implicitly or expressly acknowledged by the responsible authority. In Germany, the Federal Plant Variety Office writes that it always intends to confirm the notification formally. In France, in order to enable a more comprehensive assessment of the dossier, a committee surveying the notification process and checking the dossiers consisting of recognised experts in the field has been set up. Such an approach could be particularly suitable also for smaller Member States, considering that experts from other countries could also serve on the committee. 4. Listing of the cultivar After the acknowledgement of the notification the competent authority proceeds to the listing of the OHM cultivar. This listing shall be free of charge to the applicant. According to Article 13 (2) of the Organic Regulation (EU) 2018/848 the listing shall be communicated to responsible bodies from the other Member States and to the European Commission. It appears that this communication has not yet been implemented at the time of publication of this report (May 2025). However, the competent authority in France (GEVES) maintains a website with a table presenting notified OHM from the European Union (see section 4.1 for more details): 7 in the sense of Article 3 (57) of the Regulation D2.2, Guidelines for OHM notification 21 https://www.geves.fr/variety-seed-expertise/organic-agriculture/organic-heterogeneous-material/ [last accessed 20th April 2025] It is recommended that a European body takes on the task of maintaining and regularly updating a comprehensive list of the notified OHM in the EU. Information from the notification dossier will be relevant for customers of OHM cultivars. Moreover, evidence from Member States suggests that improved and open access to knowledge on the characterisation and properties of the OHM described in the dossier may help to facilitate the traceability and control systems of the PRM (see section 4). A high level of transparency is generally an important goal in organic agriculture. It is therefore a recommendation of the LiveSeeding project that the information in the notification dossier should be made publicly available by the competent authority, e.g. by uploading the content on an official website. The supplier shall be informed before the submission (e.g. through a note on the form) that the information provided in the dossier will be fully disclosed to the public after the acknowledgment of the notification of the OHM. 5. Marketing of the PRM The marketing of PRM of OHM is permitted as soon as the three months-period has passed or the notification is expressly confirmed by the responsible authority. Operators can then place PRM on the market and it is their responsibility that the requirements of the Organic and Delegated Regulations (EU) 2018/848 and 2021/1189 on quality, labelling and packaging of the PRM are fulfilled. Official risk-based, postmarketing controls are important to ensure quality and safety within the seed system. Traceability is an additional important building block for the marketing regime of OHM. Concretely, it is required that the supplier and operators collect and store the information as described in Box 6. Procedures for implementation are discussed in more detail below. The legal texts do not clearly state how long the OHM will remain notified. In Germany, the Federal Plant Variety Office and representatives of the organic sector agreed that the notification of a cultivar should initially be granted for 10 years and will then be re-evaluated. During this period, in order to monitor the maintenance breeding (see section 3.4 for more details), the authority may request the supplier to submit another representative PRM sample of the OHM. Finally, the possibility to correct information or even terminate the notification of an OHM cultivar must also be considered. It should always be possible for the competent authority to request necessary corrections of the notification dossier even after the initial three months-period, e.g. if new information on the OHM becomes available or if mistakes are discovered. Moreover, it should be an option for the authority to withdraw the notification of an OHM cultivar if important requirements of the Organic and Delegated Regulations (EU) 2018/848 and 2021/1189 can no longer be met, also D2.2, Guidelines for OHM notification 22 in the case when PRM of the OHM repeatedly violates important provisions of the legislation. The protection and safety of customers is a priority. Box 6: Information to be kept by the supplier and operators of OHM according to Article 8 of the Delegated Regulation (EU) 2021/1189: Article 8 (1): The supplier and operators of the OHM must keep copies of the: • notification dossier submitted to the competent authorities, • declarations made in the context of the organic certification controls (specified in Article 39 (1) (d) of the Organic Regulation (EU) 2018/848), • organic certificate (of PRM) of the OHM and • information allowing the identification of the operators which have supplied parental material of the OHM. These documents shall be kept by a minimum of five years. The responsible official body for the OHM notification procedure shall have access to this information. It is not clear whether Article 8 (1) also refers to operators producing and marketing PRM of the OHM other than the notifier of cultivar. Note that this issue can be partly 8 resolved if the notification dossier is made publicly available by the competent authorities as it is recommended by the LiveSeeding project. Article 8 (2): Operators producing PRM of OHM intended for marketing shall keep an accessible and up-to-date register and record (for each lot of PRM) the: • species, denomination and the type of technique used for the production (of the PRM) of the OHM, • phenotypic characterisation of the OHM, • location of production of the PRM, • surface area for the production and quantity produced. Notification dossier The notification dossier of an OHM must contain general information on the applicant, the species and proposed denomination as well as a representative sample (see Box 5 in section 2.1). At its heart, however, the dossier consists of a comprehensive description of the OHM cultivar. In fact, a detailed and precise description forms the basis of a functioning marketing regime for OHM. Exact information on agronomic and quality characteristics is of great value for customers of OHM too. Moreover, such a description facilitates the traceability as well as official controls systems of the PRM (see section 3.3). An 8 The information on the parental material of the OHM can really only be plausibly kept by the supplier of the OHM cultivar. D2.2, Guidelines for OHM notification 23 overview of the main elements of the description of an OHM cultivar as they are proposed in the Organic and Delegated Regulations (EU) No. 2018/848 and 2021/1189 is given in Box 7. Box 7: Description of an OHM cultivar in the notification dossier: The main elements of the description according to the Organic Regulation (OR) 2018/848 and Delegated Regulation (DR) 2021/1189 and references to the relevant articles are summarised in the following table: In summary, the phenotypic characterisation as well as the documentation of agronomic and quality traits are the two elements which constitute a ‘classic’ description of a cultivar. The objective is also to describe the phenotypic heterogeneity of the OHM. The remaining three elements help to encapsulate the specific properties of OHM, notably its dynamic nature. Of particular importance in this respect are the elements of the description of the breeding technique, year of production and pedoclimatic conditions. The elements 3 - 5 in Box 7 also help to guarantee the integrity of OHM as an organic product. This refers in particular to the description of the parental material as well as the breeding technique. It should be emphasized that it is the elements as a whole that provide reliable information for customers/end-users and allow in that sense the identification of PRM of the OHM in a particular location and year. Below we outline additional detail and guidelines on how the elements of the description in Box 7 could be presented in the notification dossier: 1. Phenotypic characterisation As already introduced in section 1.1, phenotypic characteristics proposed by the ‘International Union for the Protection of New Varieties of Plants’ (UPOV) and/or of the CPVO technical protocols can be used to describe both key common characteristics as well as the heterogeneity of the OHM cultivar. Guidelines explaining the No Element of the description Article in the OR Article in the DR 1 Phenotypic characterisation of a) key common characteristics b) heterogeneity 13 (2) (c) 4 (1) (a) (i) 2 Documentation of agronomic and quality traits (including available test results) 4 (1) (a) (ii) - (iii) 3 Breeding technique 4 (1) (b) - (d) 4 Parental material 4 (1) (c) - (d) 5 Country of breeding, year of production, pedo-climatic conditions 4 (1) (e) D2.2, Guidelines for OHM notification 24 assessment of these ‘UPOV-traits’ exist for the conduct of tests for Distinctness, Uniformity and Stability (DUS) for the relevant crop species. They can be found at: https://www.upov.int/test_guidelines/en/ [last accessed 14th May 2025] and https://cpvo.europa.eu/en/applications-and-examinations/technical-examinations/technical-protocols/cpvo-technical-protocols?page=1 [last accessed 14th May 2025]. In the case of the heterogeneity of the OHM, one option is to indicate the different expressions of UPOV-traits. As quantitative information, also (ranges of) the proportions of each expression can be specified, e.g. that 20-30% of the plants in a wheat OHM are awned. In the case of key common characteristics, it may be appropriate to use agronomic and quality traits to describe the OHM in addition to UPOV criteria (see also the explanations for element 2 below). Note that from a legal point of view all types of traits (and not only those proposed by UPOV) are available to the notifier. It is important that the phenotypic characterisation of an OHM is sufficiently detailed and precise. As explained above, such a description forms the basis of a functioning marketing regime for OHM. However, it should be also taken into account that the OHM will evolve and adapt to growing conditions at different locations and over time (see section 1.1 for explanations). The characterisation needs to be flexible (and general) enough to allow for these changes. Therefore, it should be considered to indicate ranges for the expressions of UPOVtraits when describing the heterogeneity of an OHM. On the other hand, if an expression of a characteristic is not present at all it may be plausible to assume that it will not appear in the cultivar over time or at different locations. Agronomic and quality traits may also be particularly appropriate descriptors, especially if they represent an average (such as technological baking quality parameters) which may be stabilised by a high genetic diversity when the OHM is grown in different environments (see e.g. Döring et al. 2015 or Vollenweider et al. 2021). It should also be considered, that for OHM characterised by a very high level of heterogeneity (e.g. the FURAT wheat CCP with ca. 2,000 different genotypes), it could be challenging to describe in detail the overall range of traits and their diversity. Especially in these cases the focus should be on the key and most representative traits. 2. Documentation of agronomic and quality traits Examples of relevant traits are listed in Article 4 (1) (a) (ii) of the Delegated Regulation (EU) 2021/1189. They include: • agronomic characteristics, e.g. yield, yield stability, suitability for low input systems, resistance to abiotic stress, disease resistance and • quality parameters: product quality, taste and colour. D2.2, Guidelines for OHM notification 31 • SeedLinked: is an interactive, user-friendly platform that enables decentralized cultivar evaluation designs; OHMTrack allows users to connect with SeedLinked and retrieve test results (e.g. locations, traits data); • European Router Database for Organic Seed: is a tool developed by FIBL that allows a central upload of seed offers across the national organic seed databases; OHMTrack shares crops and OHM vocabularies with the EU database. One critical aspect of the process of developing OHMTrack is establishing agreements with national authorities and stakeholders on the adoption of the most effective national strategies for the implementation of the notification and traceability requirements of OHM. One possible solution would be the creation of a digital notification data format that can be used as a best practice to standardise the notification data and to support the creation of an EU database for notifications. Using the approach of the EU Router database, it is envisioned that each country could consider one of the following options: • adopt OHMTrack as the standard tool: countries may choose OHMTrack for submitting notification data and managing traceability, ensuring consistency across the EU; • use compatible national tools: countries could maintain their own national tools for data storage. It will be crucial to assess how these systems can be compatible with common standards to enable interoperability at the EU level. It is important to highlight that the tools must support data entry through both web interfaces and interoperability API. This will prevent the need for users who already employ software for seed traceability from re-entering the same data. In the coming months, within WP3 and WP9 of the LiveSeeding project, the interoperability functions will be further developed, to define optimal strategies for ensuring proper OHM notification and traceability. The final results of this activity will be described in D9.1 “Report on internal and external interoperability of LiveSeeding digital tools” (month 48, September 2026). 3.1.2 LIVESEED toolbox Within the LIVESEED project, which preceded LiveSeeding, an extensive consultation process was conducted with breeders, those working with OHM/HM and policy makers. This resulted in the development of a “toolbox” for the description and identification of OHM. It is available for reference at: https://liveseed.eu/wp-content/uploads/2020/10/LIVESEED_D2.8_Toolbox-on-heterogeneous_materials.pdf [last accessed 19th May 2025]. Briefly, the work highlighted the key tools that notifiers and authorities should consider when developing, registering and tracing OHM to be: • origin D2.2, Guidelines for OHM notification 32 • region of cultivation • breeding methods • phenotypic traits • traceability of lots of PRM/seeds. These factors constitute the regulatory framework described in this report (in particular in sections 2.3 and 2.2). However, the “toolbox” approach emphasizes how the relevance of these factors may vary depending on the type of OHM being considered (for more details see the LIVESEED report cited above). Alongside the regulation, and development of traceability tools such as OHMTrack, we should also take into account what the practical limitations and opportunities presented by the application of such tools are. This may be within the notification process but is also important within the framework of OHM PRM production and maintenance. These factors are explored in further detail below. Results of a LiveSeeding survey on OHM notification A survey was conducted among plant breeders to assess the current status of OHM and the notification procedure in several EU Member States. Respondents to the in-depth interviews included OHM breeders from countries with more experience (such as Italy and Germany) as well as those from Member States where the notification procedure has only recently been implemented (such as France and Poland) or where few or no notifications have been initiated so far (e.g. Hungary and Spain). The results highlight positive experiences across Europe and also suggestions for improvements. In some countries, OHM is well accepted by the public, has taken its (though minor) place in agricultural production and has successfully entered the market. One example for this is Italy, one of the most engaged countries in the field, where, however, the relevant legislation was still in course of adoption at the time of the interview (in the meantime a Ministerial decree was signed in December 2024) 9 . Another positive example is Germany, where the implementation of the OHM notification procedure has progressed well and smoothly and a broad range of OHM has already been notified. However, there is still no unified procedure for the official PRM controls in place, as the responsibilities and arrangements vary between different Federal states. In many cases, official authorities lack practical experience with OHM. 9 https://www.crea.gov.it/documents/63509/2215922/MASAF-2024-0641978-decretoMEB_signed_signed.pdf/bfa0e3d9-1689-5383-0ebf-9bbf9d2be39e?t=1734342964567 [last accessed 19th May 2005] D2.2, Guidelines for OHM notification 33 Stakeholder discussions and a political discourse to support engagement and training could help address these challenges. In Poland and France OHM notification procedures have been implemented. The responsible authorities are COBORU (the Polish National Plant Variety Office) and GEVES (the Variety and Seed Study and Control Group), respectively. In France, the LiveSeeding project is contributing to data collection efforts to facilitate future submissions and processes. In Spain, an officially approved procedure for OHM notification is still missing. In Hungary the aim is to develop an OHM notification procedure which involves a simple application with minimal bureaucracy. However, due to the lack of real cases (applications) the official authority has limited practical experience and no established procedure is in place. Closer collaboration with the competent authority may be necessary to develop appropriate protocols and encourage applications from all stakeholders involved in OHM. The common challenge identified in the survey regarding guidelines for the notification procedure, including available protocols and templates for notification forms, are addressed in this report. It can also, to some extent, address the challenge of a lack of experience on the part of the official authorities assuming that it is accessed by these authorities. In addition to the challenges related to the official notification procedure, there were also important concerns pointed out in the survey about the seed quality of candidate OHM, including low germination rates and phytosanitary risks. For some crops, phytosanitary checks would be essential – for example, in wheat, due to the high risk of common bunt infections (see section 3.3). Another concern relates to the traceability of notified OHM as unauthorized seed use or the appearance of poorquality OHM on the market might damage the public reputation of OHM overall. There are also challenges in relation to dispersed farmer networks engaging with official notification and post-marketing, risk-based controls if they are not familiar with policies and procedures and do not have the support or resources of more experienced breeders or seed companies (relevant experience from Austria in that respect is presented in section 4.6). Post-marketing, risk-based controls of PRM of OHM The legal basis for establishing risk-based controls is set out in the Delegated Regulation on OHM supplementing the EU Organic Regulation: Box 8: Official controls (Article 9 of the Delegated Regulation (EU) No. 2021/1189; emphasis added): D2.2, Guidelines for OHM notification 34 “The competent authorities of the Member States or the delegated bodies, where the competent authorities have delegated control tasks in accordance with Chapter III of Title II of Regulation (EU) 2017/625, shall carry out risk-based official controls in relation to the production and marketing of PRM of OHM to check compliance with the requirements of Articles 4, 5, 6, 7, 8 and 10 of this Regulation. The testing of germination and analytical purity shall be carried out in accordance with the applicable methods of the International Seed Testing Association.” The requirements concerning the sanitary quality, analytical purity and germination of PRM of OHM are laid out in Article 6 of the Delegated Regulation 2021/1189. In particular, according to Article 6 (1): “PRM of OHM shall comply with the provisions of Regulation (EU) 2016/2031, Commission Implementing Regulation (EU) 2019/2072 (16) and the other relevant acts adopted pursuant to Regulation (EU) 2016/2031 concerning the presence, and the measures against, Union quarantine pests, protected zone quarantine pests and Union regulated.” The regulatory flexibility provided for by the legal framework of OHM is essential to maintain diversity in the seed supply chain and facilitate the practical use of OHM. However, it also implies a need for enhanced post-marketing oversight of seed/PRM of OHM to avoid quality risks, including low germination or phytosanitary risks, and to ensure consumer trust in OHM-based systems. The survey conducted within the LiveSeeding project among breeders in the EU on the current status of OHM highlighted seed quality concerns related to various OHM crops. These include the high risk of seed infestation with Tilletia and/or Ustilago species (e.g. in soft and durum wheat or barley; see also Box 8 below), occasional Fusarium infections (in soft and durum wheat, rice, and maize), the possible presence of smut in maize ( Mycosarcoma maydis , formerly Ustilago maydis ), ergot ( Claviceps purpurea ) in rye and viral infections in tomato and pepper. These phytosanitary risks will be addressed through seed health testing, as per the delegated regulation, and – where applicable – through regular field monitoring and by using resistant materials as crossing parents. Best practices at the field level include appropriate crop rotations and adherence to the principles of Integrated Pest Management (IPM). In seed processing selection based on seed size or optical sorting, hot water treatment, brush cleaning, seed coating and other biological control methods may be applied. D2.2, Guidelines for OHM notification 35 Box 9: Common Bunt in Wheat Organic Heterogeneous Material (OHM) Pathogen: Tilletia caries and Tilletia laevis . Most commercially available wheat cultivars lack (full) resistance (with the exception of a number of organically bred cultivars in Denmark and Germany), so emphasis must be laid on precaution. Impact: Common bunt reduces yield and damages grain quality. The bunt fungi produce the organic compound Trimethylamine , which is associated with a "fishy" odour. Disease cycle: Millions of spores per infested head may be released at harvest, which contaminate healthy kernels and the soil where they can persist for years. The disease is initiated when soil-borne but mainly seed-borne teliospores germinate together with the wheat seedlings in response to moisture and produce hyphae that infect the germinating plants. The fungus proliferates in the spikes; converting entire grain kernels into bunt sori (“bunt balls”) consisting of dark brown to black mass of teliospores. Environment: Cool soil temperatures (5 to 10 °C) favour infection Disease control - In the field: Regular field inspections are recommended. Crop rotation - avoid wheat monoculture (susceptible is the whole wheat family) to disrupt disease cycles. In case of infection, no susceptible crop species should be cultivated for a minimum of five years. Since UV radiation and other environmental factors reduce the viability of fungal spores, leaving crop stubbles unincorporated on the surface until the next sowing can significantly reduce soil re-infestation. OHM, which are intended to be repeatedly resown so that adaptation and evolution can take place, may be particularly vulnerable to the disease due to the accumulation of the disease pressure. Another reason is that only partial resistance within an OHM against common bunt (with some susceptible plants in the population) is usually not sufficient to avoid the disease. Thus, special attention must be paid, and regular seed checks must be applied to prevent a building up of the infestation within the material through subsequent generations. Seed treatment: mechanical (brush) or hot water treatment and other permitted seed treatments in organic farming (e.g. vinegar, seed coating with microbiota (e.g. Trichoderma sp. ) may be used to decrease infection risks. However, OHM with high levels of resistance to common bunt have been developed by organic crop breeders in Denmark and Germany. The cultivars are available and successful on the market. With these OHM it became possible to establish a reliable disease (and in particular common bunt) management for farmers as well as seed producers. D2.2, Guidelines for OHM notification 36 Maintenance breeding of OHM The legal basis is laid out in the Delegated Regulation on OHM: Box 10: Maintenance breeding (Article 10 of the Delegated Regulation (EU) No. 2021/1189; emphasis added) Where maintenance is possible, the operator who has notified the OHM […] shall preserve the main characteristics of the material at the time of its notification, by maintaining it as long as it remains on the market. That maintenance shall be undertaken according to accepted practices adapted to the maintenance of such heterogeneous material. The operator responsible for the maintenance shall keep records of duration and content of maintenance. At all times, the competent authorities shall have access to all records […]. The operator shall keep those records for five years after the moment the PRM of OHM is not marketed anymore. Breeders responding to the survey mentioned above agreed that the maintenance of OHM is a challenging task, especially considering that these materials can evolve and adapt over time and to different locations. The exact composition of the OHM may change genetically and phenotypically. It is important to understand that the maintenance of an OHM does not mean that the cultivar should not change. A more appropriate definition implies that only the key common characteristics of the OHM shall be preserved as well as the degree of heterogeneity. One key issue during maintenance concerns the minimal number of individuals required to preserve the genetic diversity of the OHM while simultaneously allowing for natural or artificial selection to occur. Brumlop et al. (2019) (see also Goldringer et al. (2001)) suggest that for practical purposes wheat OHM should be maintained on at least 150 m2 (and that an effective populations size of at least 5,000 individuals should be guaranteed corresponding to an actual or census population size of about 15,000 plants). Note that the number of required plants for the maintenance of OHM also for outcrossing species (such as maize or sunflower) will be usually higher than those of more homogeneous (standard) open-pollinated varieties due to its generally higher degree of genetic diversity. Another critical aspect is the elimination of off-types and different species. Regular negative selection is advised to eliminate such individuals and a crop rotation interval of at least four years is recommended to minimize the risk of contamination with different varieties, which may be particularly difficult to detect and remove in OHM. Note that to preserve the genetic diversity of the OHM, seed cleaning must be performed with care, taking into account the naturally occurring diversity in seed size, shape, and colour. D2.2, Guidelines for OHM notification 37 Experience from different countries Overview of notified OHM in Europe Cultivars of Organic Heterogeneous Material (OHM) are currently notified in eight Member States of the European Union. It is also in these countries that a notification procedure as defined in the Organic Regulation (EU) 2018/848 has been implemented. OHM is notified for a growing number of crop species. As of April 2025, when this deliverable was finalised, these included seven agricultural species: barley, faba bean, maize, rice, rye, sunflower and wheat, including durum and Khorasan wheat. In addition, there are notified OHM of nine vegetable species: among them are aubergine, common beans, lettuce, pepper, tomato and zucchini. Table 4 summarises the number of notified OHM in different European countries, information on the crop species and growing area. Table 4: Overview of officially notified OHM in Europe, specifying the country where OHM are notified, number of notified OHM per country, crop species as well as the number of OHM per crop species and the growing area in the vegetation period 2023/24. Country Notified OHM [n] Crop species Growing area 2024 [ha] FR 1 Wheat ( Triticum aestivum L.) DE 15 Faba bean ( Vicia faba L.; 1), maize ( Zea mays L.; 6), rye ( Secale cereale L.; 4), wheat ( Triticum aestivum L.; 4) > 800 IT 12 Barley ( Hordeum vulgare L.; 1), maize ( Zea mays L.; 1), wheat ( Triticum aestivum L.; 5), durum wheat ( Triticum durum Desf.; 1), Khorasan ( Triticum turanicum Jakubz.; 1), rice ( Oryza sativa , L.; 1), sunflower ( Helianthus annuus L.; 1), zucchini ( Cucurbita pepo L.; 1) PL 5 Maize ( Zea mays L.; 4), black radish ( Raphanus sativus subsp. niger var. niger J.Kern) AT 2 Rye ( Secale cereale L.), wheat ( Triticum aestivum L.) < 100 CZ 8 Tomato ( Solanum lycopersicum L.; 2), zucchini ( Cucurbita pepo L.; 1), pepper ( Capsicum annuum L.; 1), lettuce ( Lactuca sativa L.; 1), common bean ( Phaseolus vulgaris L.; 1), aubergine ( Solanum melongena L.; 1), maize ( Zea mays L.; 1) ? DK 2 Wheat ( Triticum aestivum L.) > 450 SI 4 Common bean ( Phaseolus vulgaris L.; 2), runner bean ( Phaseolus coccineus L.), spinach, beet or chard ( Beta vulgaris L.) D2.2, Guidelines for OHM notification 38 More details on the cultivars can be found in Annex I and a list published by the French authority GEVES: https://www.geves.fr/variety-seed-expertise/organic-agriculture/organic-heterogeneous-material/ [last accessed 29th April 2025]. In total there are 49 officially notified OHM cultivars in the European Union as of April 2025 from eight Member States and of 16 crop species as indicated above (see Table 4). The OHM comprise a variety of different types, including Composite Cross Populations, Dynamic Populations and Farmers’ Selections (see Box 2 in section 1.1 for explanations). As a genetic basis breeding lines from organic breeding programs were used, e.g. in Denmark and Germany to develop successful winter and spring wheat Dynamic Populations with excellent baking quality and disease resistance, but also landrace varieties. The wheat and rye OHM in Austria created and maintained by farmers are suitable for very specific growing conditions in mountain regions as the name ‘Berglandroggen’ (‘mountain region rye’) suggests. Value chains for OHM have been established with maize, rye and wheat OHM growing already on more than 1,000 hectares in Denmark, Germany and Austria in the vegetation period 2023/24 (see Table 4 and section 4.10 for more details). It should be emphasised that organic breeders, seed producers, farmers, traders and processors depend on these markets for their income. In some cases, dedicated value chains with a focus on direct marketing have been started: Artisanal bakers in Germany demand the special quality of wheat and rye OHM and with vegetable OHM there is great potential to focus on quality traits, taste, local adaptation and robustness for organic cultivation. The notification procedure is generally recognised as an efficient system for regulating the market access of OHM cultivars in different countries. Challenges in Member States are mainly associated with the marketing of PRM and the implementation of the risk-based, post-marketing control system. Open questions concern the allocation of responsibilities (in particular between the PRM certification and organic control authorities), costs and additional requirements (see sections 4.2 - 4.9 where experiences from different European countries are summarised). Targeted recommendations to address these challenges will be presented in section 5 of this deliverable. UK 1 Wheat ( Triticum aestivum L.). EU 49 > 1,200 Europe 50 > 1,200 D2.2, Guidelines for OHM notification 39 France Organisation providing the information (within the LiveSeeding project): GEVES (Groupe d'Etude et de Contrôle des Variétés et des Semences) Contact person: David Hidrot, Head Manager - Cavaillon GEVES unit / Organic Agriculture 1. General information No. Question Short Answer (Yes, No, Number of OHM, cost in €) Comment 1. Is a procedure (or any possibility) for OHM notification established in your country? Yes https://www.geves.fr/variety-seed-expertise/organic-agriculture/organic-heterogeneous-material/ [last accessed 23rd April 2025] 2. Is there an official form for OHM notification available? Yes https://www.geves.fr/wp-content/uploads/Applicationform-of-0rganic-Heterogeneous-Material.docx [last accessed 23rd April 2025] 3. Which is the official body responsible for OHM notification (sensu Art. 13 of 2018/848/EU) in your Member State? French Ministry of Agriculture and Food GEVES studies the application and the French Ministry of Agriculture and Food makes the official notification 4. How many OHM are notified in your member state? For which crop species? 1 (+1 in progress) 1 winter wheat (+ 1 melon) 5. What are the costs for the notification of OHM (i.e. the fees of the official body)? 0 € Free of charge 6. Is there the obligation (or possibility) to deposit a representative PRM sample of the OHM together with the notification documents? Yes Deposition of a seed sample is compulsory 7. Is there a procedure for risk-based official controls of the production and marketing of plant reproductive material (PRM) of OHM in your country? (as foreseen in Art. 9 of the delegated regulation (EU) 2021/1189) Yes 8. Which is the competent authority (or delegated body) carrying out the risk-based official controls of the production and marketing of PRM of OHM? SEMAE 9. Are there field inspections for OHM (carried out in the course of the riskbased official controls of PRM of OHM)? Yes D2.2, Guidelines for OHM notification 40 10. What are the costs of the risk-based controls of PRM of OHM (compared to certification costs of standard varieties)? - 2. Description of the situation with OHM notification In 2022, the French Ministry in charge of Agriculture designated GEVES as the competent authority for handling OHM notifications. The dedicated Organic Agriculture commission of GEVES quickly set up a specific email address ([email protected]) and developed a technical questionnaire enabling applicants to submit their request directly via the GEVES website. Upon receipt of an application – including a seed sample and a denomination – the request is reviewed by a species-specific expert group. Depending on the content of the application additional technical information may be requested from the applicant. Within a few weeks GEVES issues an expert opinion and informs the French Ministry of Agriculture, which then proceeds with the official notification of the new OHM. The Ministry forwards this information to the relevant European authorities. A list of notified OHMs in France and across the European Union is available at the following this link. Germany Organisation providing the information (within the LiveSeeding project): Dottenfelder Bio-Saat, Bad Vilbel Contact person: Maike Bender, Organic Plant Breeder 1. General information No. Question Short Answer (Yes, No, number of OHM, cost in €) Comment 1. Is a procedure (or any possibility) for OHM notification established in your country? Yes https://www.bundessortenamt.de/bsa/en/seeds/organic-heterogeneous-material [last accessed 23rd April 2025] 2. Is there an official form for OHM notification available? Yes https://www.bundessortenamt.de/bsa/en/form-notifizierung-oehm [last accessed 23rd April 2025] 3. Which is the official body responsible for OHM notification (sensu Art. 13 of 2018/848/EU) in your member state? - Federal Plant Variety Office (Bundessortenamt) D2.2, Guidelines for OHM notification 47 Poland Organisation providing the information (within the LiveSeeding project): Research Centre for Cultivar Testing (COBORU) Contact persons: Edward Gacek, Tomasz Lenartowicz 1. General information No. Question Short Answer (Yes, No, number of OHM, cost in €) Comment 1. Is a procedure (or any possibility) for OHM notification established in your country? Yes According to regulations, the list of OHM is maintained by the Research Centre for Cultivar Testing (COBORU); the procedure was implemented in accordance with the specific provisions of Regulation (EU) 2018/848 of the European Parliament and of the Council as well as with the delegated act adopted pursuant to that Regulation. 2. Is there an official form for OHM notification available? Yes There is a model application - NOTIFICATION - application for entry of the plant reproductive material to THE ORGANIC HETEROGENEOUS MATERIAL list, available at: https://coboru.gov.pl/en/ohm/ohm [last accessed 26th April 2025] 3. Which is the official body responsible for OHM notification (sensu Art. 13 of 2018/848/EU) in your member state? - Research Centre for Cultivar Testing (COBORU) 4. How many OHM are notified in your member state? For which crop species? 5 See: https://coboru.gov.pl/en/ohm/ohm_list [retrieved 26th April 2025]; There are 4 maize OHM notified: Hańcza in December 2023, Ukiel, Isąg and Notyst in November 2024.1 black radish ( Raphanus sativus L.) Axona was notified in April 2025. 5. What are the costs for the notification of OHM (i.e. the fees of the official body)? - There are no costs 6. Is there the obligation (or possibility) to deposit a PRM sample of the OHM together with the notification documents? Yes Together with the submission of the application, the applicant shall deliver a representative sample of plant reproductive material 7. Is there a procedure for risk-based official controls of the production and marketing of plant reproductive material (PRM) of OHM in your country? (as foreseen in Art. 9 of the delegated regulation (EU) 2021/1189) It is not the responsibility of COBORU 8. Which is the competent authority (or delegated body) carrying out the riskState Plant Health and Seed Inspection Service D2.2, Guidelines for OHM notification 48 based official controls of the production and marketing of PRM of OHM? 9. Are there field inspections for OHM (carried out in the course of the riskbased official controls of PRM of OHM)? 10. What are the costs of the risk-based controls of PRM of OHM (compared to certification costs of standard varieties)? 2. Description of the situation with OHM notification in your country The four maize OHM are marketed (in spring 2025) as silage maize, mainly to the conventional market, see e.g. https://centrumnasionpietrzak.pl/produkt/kukurydza-notyst/ https://rolmarket.pl/nasiona-kukurydzy/kukurydza-kiszonkowa-notyst-wysoki-plonodpornosc-doskonale-parametry-jakosciowe-worek-50-tys-nasion https://ppseeds.pl/sklep/produkty/kukurydza-notyst-bio/ (*) [all websites: last accessed: 26th April 2025] The maize OHM are (mostly) marketed in small packages (with a max. net mass of 30 kg for cereals) for which it is argued from Art. 7 (5) of the Delegated Regulation (EU) 2021/1189 that “packages and containers may be sold to final users in unmarked and unsealed packages up to the maximum quantities provided for in Annex II, provided that, on request, the purchaser is informed in writing at the time of delivery about the species, the denomination of the material and the reference number of the lot.” For most offers it is neither indicated that these are seeds of OHM (using this phrase and a yellow label with a green diagonal cross) nor are the OHM seeds labelled as organically certified (but see the offer denoted by a * above). The LiveSeeding project-partner PIN (Polish Seed Trade Association) estimates a high market potential of maize OHM. The labelling, marketing arrangements and official PRM controls of the maize OHM must be critically evaluated. A combination of measures should be proposed to ensure the protection of customers and the integrity of OHM value chains (see section 5 – conclusions). D2.2, Guidelines for OHM notification 49 Austria Organisation providing the information: Arche Noah (https://www.arche-noah.at/ [last accessed: 26th April 2025] Contact persons: Bernd Kajtna Two OHM are notified in Austria: one winter rye OHM (‘Berglandroggen’) and one spring wheat OHM (‘Wildschönauer Sommerweizen’). Both OHM are of the type farmers’ selections and they are characterised by their suitability for their particular growing locations. An official list is available at: https://www.baes.gv.at/fileadmin/baes/Pflanzensorten/%C3%96kologisch_biologisch_heterogenes_Material/2_Oesterreichische_Liste_notifiziertes_OEHM_Stand_23sept2022.pdf [last accessed 26th April 2025] A notification procedure is in place in Austria https://www.baes.gv.at/zulassung/pflanzensorten/oekologisch/biologisch-heterogenes-material and an official notification form is available at Antragsformular_OEHM.docx [ [both links: last accessed on 26th April 2025] According to the applicants the notification of the OHM cultivars with the submission of the documents was uncomplicated and worked smoothly. Support by the non-governmental organisation Arche Noah was of great help. However, there were challenges with regard to marketing PRM of the OHM and the official controls. In fact, the time interval between harvest and sowing is very short, especially in the case of the rye OHM, due to the special location in the Austrian mountains where the material is grown. Therefore, there is very little time for control of the PRM. The official laboratory seed analyses cannot be flexible enough to mana this special situation. Moreover, the costs for the analyses are prohibitively expensive and the requirements for seed purity and also for labelling seem to be too restrictive for this type of niche cultivars. A proposal for solving these challenges was put forward (by the applicant of the rye OHM V. Müllner): A written declaration could be signed by the farmer confirming that • seed cleaning has taken place (indicating also the date and type of cleaning • no diseases were detected during harvesting and/or cleaning and also the • status of the germination capacity. For this type of farmer’ selections suitable for particular growing conditions and locations this information seems to be adequate for the customers. In conclusion: Although the notification of OHM was uncomplicated, the actual control system of seed transfers seems to require optimisation and also more time and information so that farmers can familiarise themselves with it. D2.2, Guidelines for OHM notification 50 Denmark Organisations providing the information: Agrolgica (https://www.agrologica.dk/) and Landsorten (https://landsorten.dk/, last accessed for both websites: 26th April 2025) Contact persons: Anders Borgen (Agrologica) and Johan Siboni Lund (Landsorten) In Denmark there is a flexible notification system in place based on direct communication with the competent authority. No fees for registration nor administration are charged. Two OHM of the type ‘dynamic population’ are notified: ‘Mariagertoba’ – a spring wheat, notified in 2022 and grown on 350 h in 2023 and Popkorn – a winter wheat, notified in 2022 and grown on 150 ha in 2023. These OHM are marketed within the Landsorten community and there are no seed sales to third parties. More information on the experience with OHM in Denmark and the Landsorten community was given in a presentation of Dr. Anders Borgen at the 1st LiveSeeding Workshop on OHM on 26th June 2023: OHM Workshop – Anders Borgen: "Notification and Marketing" Hungary Organization providing the information (within the LiveSeeding project): The Hungarian Research Institute of Organic Agriculture (ÖMKi) Contact persons: Szilvia Bencze, Gyöngyi Györéné Kis 1. General information No. Question Short Answer (Yes, No, number of OHM, cost in €) Comment 1. Is a procedure (or any possibility) for OHM notification established in your country? No There was no application request until the end of 2024 2. Is there an official form for OHM notification available? No No official form has been developed yet but the old version from the 7-year temporary experiment (from 2021) may be used (it has not been updated) 3. Which is the official body responsible for OHM notification (sensu Art. 13 of 2018/848/EU) in your member state? NÉBIH National Food Chain Safety Office (NÉBIH) homepage for variety registration (in Hungarian): https://portal.nebih.gov.hu/-/novenyfajta-kiserletek-fajtaelismeres [last accessed 15th May 2025] 4. How many OHM are notified in your member state? For which crop species? 0 There was a drum wheat population registered within the temporary experiment in 2021. D2.2, Guidelines for OHM notification 51 5. What are the costs for the notification of OHM (i.e. the fees of the official body)? 0 € Up until now no cost was indicated 6. Is there the obligation (or possibility) to deposit a representative PRM sample of the OHM together with the notification documents? Yes For cereals the minimal amount of required seed will be 1 kg 7. Is there a procedure for risk-based official controls of the production and marketing of plant reproductive material (PRM) of OHM in your country? (as foreseen in Art. 9 of the delegated regulation (EU) 2021/1189) No It has not been specified for OHM but may be required if there is a risk of high disease pressure 8Which is the competent authority (or delegated body) carrying out the risk-based official controls of the production and marketing of PRM of OHM? NÉBIH National Food Chain Safety Office (NÉBIH) 9. Are there field inspections for OHM (carried out in the course of the riskbased official controls of PRM of OHM)? There may be 10. What are the costs of the risk-based controls of PRM of OHM (compared to certification costs of standard varieties)? No data on that 2. Description of the situation with OHM notification Hungary joined the 7-year temporary experiment (EU) 2014/150 on cereal populations rather late. The Hungarian Research Institute of Organic Agriculture (ÖMKi) got involved in this experiment together with the National Food Chain Safety Office (NÉBIH), the official body of variety registration in Hungary. During the temporary experiment ÖMKi had one OHM notified, the durum wheat population EPO (in 2021), developed by, and provided by INRAE within the EU-project SolACE. Although in the temporary experiment a registration procedure was initiated in Hungary, since then no more application request has been made for any species. The Agricultural Institute of HUNREN Centre for Agricultural Research developed a few durum and common wheat OHM. However, they were only tested unofficially and have not been notified. ÖMKi started its organic breeding programme in 2020 with the aim of developing emmer and durum OHM, and in the long-run, also organic varieties. Possible candidates for OHM notification are under testing – also with the participation of interested farmers – to collect enough data on their performances for the application process. The best materials may be entered in the notification process in 2025. D2.2, Guidelines for OHM notification 52 Unfortunately, in Hungary OHM are still lacking attention, people don’t know them and there is no procedure settled. Despite that the official body NÉBIH is open and basically positive on OHM. Sufficient experience has not yet been accumulated on practical issues and how OHM should be handled. United Kingdom Organization providing the information (within the LiveSeeding-project): Organic Research Centre (ORC) Contact person: Charlotte Bickler 1. General information No. Question Short Answer (Yes, No, number of OHM, cost in €) Comment 1. Is a procedure (or any possibility) for OHM notification established in your country? Yes 2. Is there an official form for OHM notification available? Yes 3. Which is the official body responsible for OHM notification? APHA The Animal and Plant Health Agency (DEFRA) 4. How many OHM are notified in the UK? For which crop species? 1 Spring wheat 5. What are the costs for the notification of OHM (i.e. the fees of the official body)? 0 No costs to notify 6. Is there the obligation (or possibility) to deposit a seed sample of the OHM together with the notification documents? No 7. Is there a procedure for risk-based official controls of the production and marketing of plant reproductive material (PRM) of OHM in your country? Yes After notification, the process is the same as for all seed. See: https://www.gov.uk/guidance/the-marketing-of-agricultural-and-vegetable-seed-varieties [last accessed 26th April 2025]. Perhaps there is some internal adjustment of protocols, but these have not been outlined. I think it is being determined on a case-by-case basis and, seen as we have not registered many OHM, they are not prioritising adapting these processes/protocols more broadly. 8. Which is the competent authority (or delegated body) carrying out the riskbased official controls of the production and marketing of PRM of OHM? NIAB https://www.niab.com/services/seed-certification [last accessed 26th April 2025] D2.2, Guidelines for OHM notification 53 9. Are there field inspections for OHM (carried out in the course of the riskbased official controls of PRM of OHM)? Yes 10. What are the costs of the risk-based controls of PRM of OHM (compared to certification costs of standard varieties)? Same Seed certification costs vary depending on the crop type, application method (online or by post), and whether the inspection is official or licensed. They are outlined here: https://www.gov.uk/guidance/the-marketing-of-agricultural-and-vegetable-seed-varieties [last accessed 26th April 2025] 2. Description of the situation with OHM notification National authorities in the UK were very engaged in the temporary experiment (EU) 2014/150 on cereal populations, both nationally and at an EU level. However, the UK left the EU and did not adopt the EU organic regulation 2018/848. Instead, they worked with stakeholders to design a Statutory Instrument which would create (another) Temporary Experiment: The Seed Marketing (Heterogeneous Material) (Temporary Experiment) (England) Regulations 2023, see https://www.legislation.gov.uk/uksi/2023/676/made [last accessed 26th April 2025]. This outlines the notification (registration) process for heterogeneous material in England. Scotland and Wales are developing their own legislation as this is a devolved responsibility, but nothing has been finalised at time of writing (March 2025). A copy of the template is available here. So far UK Grain Lab have only registered one spring wheat OHM, and are not aware of any other organisations registering any. The process was very straightforward but felt somewhat performative. The challenges arise when it comes to complying with standardised controls for seed after notification/registration. It is a delicate situation as resources and capacity for work on (O)HM is very low and actors do not feel that there is value in engaging with the national authorities particularly when they do not adapt their systems for (O)HM. At the same time, the authorities observe that demand is low and therefore do not adapt their systems. Growing area of OHM in Europe At the moment only rough and incomplete estimates are available for the dissemination of OHM in Europe. The data collected within the LiveSeeding project suggests that OHM was grown on a total surface area of more than 1,000 hectares (ha) in Europe in the vegetation period 2023/24. Maize, rye and wheat OHM contributed each with more than 400 ha, 150 ha and 600 ha to this total area (see Figure 3). D2.2, Guidelines for OHM notification 54 Figure 3: Total growing area of OHM in Europe in the vegetation period 2023/24 Note that the data to create Figure 3 was obtained from only two operators, the membership organisation Landsorten 10 in Denmark and the seed marketing company BioSaat GmbH 11 in Germany, both specialists in marketing organic seeds. In total they placed seed of eight OHM on the market: three maize, one rye, three winter wheat and one spring wheat cultivar (the contribution of Landsorten was one winter and one spring wheat OHM each). These OHM were grown in seven European countries in the season 2023/24 (see Figure 4). Figure 4: Growing area of OHM in Europe by country and crop species in the vegetation period 2023/24. UK: United Kingdom. Other countries: include Belgium, Ireland and the Netherlands. 10 https://landsorten.dk/ [last accessed 29th April 2025] 11 https://biosaat.eu/ [last accessed 29th April 2025] 0 200 400 600 800 1000 1200 1400 Growing area [hectares] Wheat Rye Maize 0 100 200 300 400 500 600 700 800 900 Denmark Germany, Austria UK Other Growing area [hectares] Wheat Rye Maize D2.2, Guidelines for OHM notification 55 The numbers in Figures 3 and 4 are conservative estimates of the area of OHM being cultivated across Europe. In particular, in the case of the cultivars marketed by BioSaat GmbH, it was not possible to include the growing area from farm saved seed. There were attempts made in the LiveSeeding project to collect data from other European countries. The numbers obtained from Austria and France, however, were quite low (well below 100 hectares in the season 2023/24). Project partners report that the quantities and growing areas from Italy will represent relevant contributions but until spring 2025 there was no official notification procedure in place in this country. Likewise in the UK, there is likely to be a greater area under cultivation than any reported figures. The dissemination of OHM will continue to grow in the coming years. It will be important to collect and process this data. Especially in the case of vegetable OHM and OHM for niche markets, it will also be appropriate to introduce other indicators than growing area, e.g. the number of packages sold or information on quantities of final products to determine the broader value of OHM. The aim of the data collection should be to represent the promising future perspectives of OHM in Europe accurately. D2.2, Guidelines for OHM notification 56 Conclusion and recommendations Organic Heterogeneous Material has strong potential to increase the resilience and genetic diversity of organic farming systems, particularly by mitigating effects of climate change. In the years ahead, it will be essential to further investigate and assess the wide variety of OHM types and crop species under real farming conditions. As of April 2025, when this deliverable was finalised, eight EU Member States had implemented the OHM notification procedure. A total of 49 OHM cultivars had been notified, covering seven agricultural and nine vegetable species, including faba bean, maize, rice, rye, sunflower, bread wheat, durum and Khorasan wheat, aubergine, tomato, and zucchini. The notification procedure is generally recognised as an efficient system for regulating the market access of OHM by different stakeholders. In particular, the application forms provided by competent authorities in at least five Member States are seen as valuable tools for applicants. These forms allow for the structured submission of information required in the descriptive dossier, which includes phenotypic characterisation, agronomic traits, breeding techniques and details on parental material, among other elements. The templates used across the different countries are largely consistent. Within the LiveSeeding project, concrete recommendations have been developed to strengthen the implementation of the OHM regulatory framework. These proposals target OHM breeders and seed producers, authorities responsible for notification and plant reproductive material (PRM) control as well as European and national policy makers. The following sections present these recommendations in order: first, those related to the notification procedure, followed by suggestions on official PRM controls, and finally, broader policy considerations. A. Notification procedure A.1 A detailed and accurate description of cultivars is essential for the effective regulation and marketing of Organic Heterogeneous Material (OHM). Such descriptions are not only relevant to customers but also support traceability, strengthen official plant reproductive material (PRM) control systems, and help safeguard the integrity of OHM as an organic product. Section 2.3 of this deliverable provides guidance to help applicants prepare clear and comprehensive cultivar descriptions. It is the responsibility of competent authorities to carry out a critical review of the submitted descriptive dossiers. It is important to underline that, beyond phenotypic characterisation, the documentation of parental material, breeding methods and the breeding process itself is of particular significance. These elements are crucial in capturing the D2.2, Guidelines for OHM notification 63 Weedon, O., Brumlop, S., Haak, A., Baresel, J. P., Borgen, A., Döring, T., Goldringer, I., Lammerts van Bueren, E., Messmer, M., Mikó, P., Nuijten, E., Pearce, B., Wolfe, M., Finckh, M. R. (2023) “High Buffering Potential of Winter Wheat Composite Cross Populations to Rapidly Changing Environmental Conditions.” Agronomy, 13, 1662. doi: 10.3390/agronomy13061662. Wuest, S. E., Peter, R., Niklaus, P. A. (2021) “Ecological and evolutionary approaches to improving crop variety mixtures.“ Nature Ecology & Evolution, VOL 5, 2021, pp. 1068– 1077. doi: 10.1038/s41559-021-01497-x. D2.2, Guidelines for OHM notification I Annex 1: List of notified OHM Table 5: List of notified OHM in the EU (not complete). Source: https://www.geves.fr/variety-seed-expertise/organic-agriculture/organic-heterogeneous-material/ [last accessed 29th April 2025] Member State Species Denomination Operator Date of registration Austria Secale cereale L. (winter type) Berglandroggen Veronika Müllner, Kaltenbach 25, 3632 Bad Traunstein 02.06.2022 Austria Triticum aestivum (spring type) Wildschönauer Sommerweizen Emil Platzer, Gainfeld 14, 5500 Bischofshofen 08.06.2022 Czech Republic Capsicum annuum Měňavka Marek Kvapil, Pňovice 55, CZE – 784 01 03.03.2022 Czech Republic Cucurbita pepo Lofthousova zimní tykev Marek Kvapil, Pňovice 55, CZE – 784 01 07.02.2023 Czech Republic Lactuca sativa Listonoh Marek Kvapil, Pňovice 55, CZE – 784 01 06.01.2023 Czech Republic Phaseolus vulgaris Lofthouse Landrace Beans Marek Kvapil, Pňovice 55, CZE – 784 01 03.03.2022 Czech Republic Solanum lycopersicum Vejce ptáka Ohniváka Marek Kvapil, Pňovice 55, CZE – 784 01 03.03.2022 Czech Republic Solanum lycopersicum Valouny Marek Kvapil, Pňovice 55, CZE – 784 01 03.03.2022 Czech Republic Solanum melongena Kvapík Marek Kvapil, Pňovice 55, CZE – 784 01 03.03.2022 Czech Republic Zea mays Malované hory Marek Kvapil, Pňovice 55, CZE – 784 01 06.01.2023 Denmark Triticum aestivum (spring type) Mariagertoba Landsorten, Houvej 55, DK-9550 Mariager 30.06.2022 D2.2, Guidelines for OHM notification II Denmark Triticum aestivum (winter type) Popkorn Landsorten, Houvej 55, DK-9550 Mariager 30.06.2022 France Triticum aestivum (winter type) Pop Orvilliers Ferme d'Orvilliers 25.01.2024 Germany Secale cereale L. Baldachin Landbauschule Dottenfelderhof e.V., Dottenfelderhof 1, 61118 Bad Vilbel 12.05.2022 Germany Secale cereale L. Dodo Werner Vogt-Kaute, Steingrund 27, 97797 Wartmannsroth 11.04.2022 Germany Secale cereale L. Perfirmalina Herr Malte Kraus, Hofäckerweg 3, 71579 Spiegelberg 08.05.2024 Germany Triticum aestivum (spring type) Convento C Landbauschule Dottenfelderhof e.V., Dottenfelderhof 1, 61118 Bad Vilbel 02.02.2022 Germany Triticum aestivum (spring type) Convento E Landbauschule Dottenfelderhof e.V., Dottenfelderhof 1, 61118 Bad Vilbel 02.02.2022 Germany Triticum aestivum (winter type) Brandex Landbauschule Dottenfelderhof e.V., Dottenfelderhof 1, 61118 Bad Vilbel 02.02.2022 Germany Triticum aestivum (winter type) Liocharls Landbauschule Dottenfelderhof e.V., Dottenfelderhof 1, 61118 Bad Vilbel 02.02.2022 Germany Vicia faba L. (Partim) Detta Werner Vogt-Kaute, Steingrund 27, 97797 Wartmannsroth 11.04.2022 Germany Zea mays Evolino Firma Getreidezüchtung Peter Kunz Deutschland, gemeinnützige GmbH, Gut Mönchhof 2, 37290 Meißner 01.06.2022 Germany Zea mays Almito Landbauschule Dottenfelderhof e.V., Dottenfelderhof 1, 61118 Bad Vilbel 02.02.2022 D2.2, Guidelines for OHM notification III Germany Zea mays Bogdan Landbauschule Dottenfelderhof e.V., Dottenfelderhof 1, 61118 Bad Vilbel 02.02.2022 Germany Zea mays Tambudzai Landesanstalt für Landwirtschaft Institut für Pflanzenbau und Pflanzenzüchtung, Am Gereuth 8, 85354 Freising 10.02.2022 Germany Zea mays Weihsteph 2 Landesanstalt für Landwirtschaft Institut für Pflanzenbau und Pflanzenzüchtung, Am Gereuth 8, 85354 Freising 10.02.2022 Germany Zea mays Weihsteph 3 Landesanstalt für Landwirtschaft Institut für Pflanzenbau und Pflanzenzüchtung, Am Gereuth 8, 85354 Freising 10.02.2022 Poland Zea mays Hańcza "Pietrzak" sp. z o.o. sp. k. 05.12.2023 Poland Zea mays Ukiel "Pietrzak" sp. z o.o. sp. k. 27.11.2024 Poland Zea mays Isąg "Pietrzak" sp. z o.o. sp. k. 27.11.2024 Poland Zea mays Notyst "Pietrzak" sp. z o.o. sp. k. 27.11.2024 Poland Raphanus sativus subsp. niger var. niger J.Kern Axona GLOBALGRASS sp. z o.o. 08.04.2025 Slovenia Beta vulgaris L. - Spinach beet or Chard Tanja Ekološka kmetija Ipavec, Mitja Ipavec, Šmarje 68, 5295 Branik 30.11.2022 Slovenia Phaseolus coccineus L. Šurk EKOSEMENA, Rožna Dolina 50 A, 4248 Lesce, Urška Šranc, Belska cesta 36, 4281 Mojstrana 02.12.2023 Slovenia Phaseolus vulgaris L. KIS Bogo Kmetijski inštitut Slovenije, Infrastrukturni Center Jablje, Grajska cesta 1, 1234 Mengeš 22.12.2023 Slovenia Phaseolus vulgaris L. KIS Deodat Kmetijski inštitut Slovenije, Infrastrukturni Center Jablje, Grajska cesta 1, 1234 Mengeš 22.12.2023 D2.2, Guidelines for OHM notification IV Annex 2: Table on the comparison of notification forms from France, Germany, Italy and the UK Table 6: Comparison of notification forms from France, Germany, Italy and the United Kingdom (UK) (adapted from Guidotti & Marchi 2025). Cells highlighted in orange indicate fields that are not required in that country. The numbers (No.) refer to the numbering in the German notification form (see Table 3 in section 2.4). No. Entry France Germany Italy UK 1 Name of the notifier Name of the applicant Notifying person or company Name of the applicants with fiscal identification code, farm registration code and organic registration code Name and address of applicant (where the applicant is not an individual, the person responsible for participation in the experiment) Address Address Address Address Address Phone Telephone Long distance call Telephone Email Email Email Email 1-B Name of the maintainer Name of the applicants with fiscal identification code, farm registration code and organic registration code Address 2 Contact for communication Address 3 Species Species Species Species (botanical and common) Species and varieties used to create population 4 Denomination Proposed name Denomination of the OHM Denomination of the OHM Name of the population (or proposed name) D2.2, Guidelines for OHM notification V 5 Trade mark registration The indicated denomination has been registered as a trade mark 6 Parental material Parental description Description of the parent material, if applicable, indicate the varieties or genotypes used to create the OHM Parental description Species and varieties used to create population 7 Type of breeding technique Type of breeding technique 8 Description of the breeding technique Description of the method Description of the breeding technique, the crossing and production protocols (for a CCP) or the onfarm management and selection practices Adopted methods Objectives of the breeding programme Description of the type of technique used to generate the population, including the breeding scheme 9 Phenotypic characterization Phenotypic characterization, common traits (and level of heterogeneity) Phenotypic characterization of essential features common to the materiel Phenotypic characterization Description of the population’s characteristics, including - whether it is self-pollinating; disease resistance; taste or colour; and any other characteristic which the applicant regards as relevant. Results of any experimental trials concerning the D2.2, Guidelines for OHM notification VI characteristics specified. Heterogeneity Level of heterogeneity Degree of heterogeneity Define the level of homogeneity for a character (if homogeneous) or, if possible, the level of variation for heterogeneous characters The degree of heterogeneity Agronomic value Agronomic and use value Documentation of relevant traits including agronomic aspects (e.g. yield, yield stability, suitability for extensive management, direction of use, performance, resistance to abiotic stress, disease resistance, quality, taste or colour) Agronomic value, use value Yield, yield stability and quality; performance 10 Country/ locations Site Country of breeding or production, indication of region, if applicable Location where the OHM has been bred Region or proposed region of production 11 Pedo-climatic conditions Description of soil and climatic conditions Description of soil and climatic conditions Description of soil and climatic conditions 12 Year of production Indication of the year of production Maintainer (if different) Name of the operators that maintain the OHM Name and address of the person responsible for the breeding, production D2.2, Guidelines for OHM notification VII and maintenance Suitability for organic or low input growing conditions Favourable conditions for cultivation and use (not mandatory) Usability in low-input agriculture