New regulation on seed imports into Europe

michaelcmace@gmail.com michaelcmace@gmail.com
Fri, 18 Oct 2019 08:22:26 PDT
Sorry, one more note. I think it would be useful to share the exact info
that Joyce sent to me regarding the situation. It's below. It gives a bit
more detail on how the communications on this issue could work within the
EU: She says we need the country "national plant protection organization"
representatives to contact the EU and tell them about the need for the
exception.

It sounds like input from non-EU countries is also relevant, so if you're
outside the EU but worried about the impact of this on plant societies and
suppliers, it's a good idea to have your country regulators ping the EU
about it.

Also, note that it's the US plant regulators who flagged this issue for the
EU and notified Joyce. This is a direct result of the work Joyce and others
have been doing to create a working relationship with the US federal
regulators. That's been a long, unknown, and pretty much thankless task for
Joyce; if you ever get a chance to chat with her, please tell her thanks.

=====

I just spoke with our representative from APHIS-PPQ who had discussions with
the European Commission earlier this month.  He brought up the subject of
the new requirement for a phytosanitary certificates to accompany all seeds
entering any country within the European Union, and requested some kind of
exemption for small lots of seed.  

Apparently this was news to the EC, as they had not heard from anyone else
that the regulation (to take effect on December 14) would produce any sort
of hardships.

So, if you have been contacting your country's national plant protection
organization (NPPO), it would seem that your NPPO representative has not
made any contact with the Commission.

Since the Commission said that they would consider a derogation for small
lots of seed if they also heard from other countries (especially those
within the EU), it is time to light a fire under your NPPO representatives.

Please contact them (again, if necessary) and let them know that it is
crucial for them to make their wishes for a modification of the regulation
known to the Commission... soon. Very soon.

APHIS-PPQ is about to send a formal letter (as requested by the EC) stating
the facts around the need for this exemption.  
I will be helping by sending every bit of information I can muster: who
would be harmed by the requirement for PCs, what further effects would be
felt in agriculture, horticulture, environment; how the same results can be
obtained through a permit, rather than a PC; additional benefits to the NPPO
from the data gathered via permits.

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