As the European Union moves into the decisive phases of the Trilogue negotiations concerning the Plant Reproductive Material (PRM) Regulation, a coalition of the continent’s leading organic and biodynamic organizations has issued an urgent appeal to the EU Ministers of Agriculture. On March 17, 2026, the European Consortium for Organic Plant Breeding (ECO-PB), the Biodynamic Federation Demeter International, and IFOAM Organics Europe jointly submitted a formal letter calling for a final legislative text that protects the future of agricultural biodiversity. The organizations warn that current restrictive positions held by the Council of the European Union could impose insurmountable barriers on conservation varieties and local cultivars, effectively stifling the growth of the organic sector and undermining the European Green Deal’s biodiversity targets.
The PRM Regulation, often referred to as the "EU Seed Law," is a cornerstone piece of legislation intended to modernize the rules governing the production and marketing of seeds, tubers, and other plant reproductive materials. While the European Commission originally proposed the update to simplify a complex web of decades-old directives, the legislative process has exposed deep ideological rifts regarding how much flexibility should be granted to non-industrial seed varieties. The organic and biodynamic sectors argue that the Council’s current trajectory favors large-scale, uniform seed production at the expense of the localized, genetically diverse seeds that are essential for climate adaptation and chemical-free farming.
The Core of the Dispute: Geographic and Categorical Restrictions
The primary concern voiced by the coalition involves the Council’s proposed limitations on "conservation varieties"—plants that are traditionally grown in specific regions and are often adapted to local soil and climatic conditions. The Council has advocated for a position that would restrict the production and sale of these cultivars strictly to their "region of origin." Furthermore, the Council’s draft suggests limiting the registration of newly bred varieties under more flexible pathways to only fruits and vegetables, excluding vital arable crops such as cereals, maize, and oilseeds.
Eric Gall, Deputy Director of IFOAM Organics Europe, emphasized the gravity of these proposed restrictions during a press briefing in Brussels. "The restrictive Council’s position on conservation and local varieties would have serious consequences on the many organic farmers, breeders, and seed companies that currently rely on them," Gall stated. He further noted that restricting the production of these cultivars to their region of origin and limiting newly bred varieties to only fruits and vegetables would significantly impact the activities of networks, breeders, and seed companies that are developing and selling them across the European single market.
For the organic sector, these restrictions represent a fundamental misunderstanding of how modern sustainable breeding works. Organic breeders often work with diverse genetic material to create "heterogeneous" populations that can survive without synthetic pesticides. By confining these seeds to small geographic pockets, the regulation would prevent organic farmers in other regions from accessing the very tools they need to transition away from intensive chemical use.
The Missing Regulatory Middle: DUS vs. OHM
A central technical hurdle identified by the coalition is the lack of an "intermediate category" in the proposed regulation. Currently, the EU recognizes two main pathways for seed marketing:
- DUS Varieties: Seeds that meet the criteria of being Distinct, Uniform, and Stable. This is the industrial standard, designed for high-input agriculture where every plant in a field is genetically identical.
- Organic Heterogeneous Material (OHM): A category introduced in recent years to allow the sale of seed populations that have high levels of genetic diversity and do not meet the uniformity requirements of DUS.
The coalition argues that many "conservation and local varieties" occupy a middle ground—they are more stable than OHM but do not meet the rigid, often cost-prohibitive uniformity standards of DUS. Without a specific intermediate category, these varieties are frequently rejected by national competent authorities.
The organizations provided concrete examples to illustrate this regulatory gap. In Italy, the organization Rete Semi Rurali (RSR), working alongside an organic farmer in the Veneto region, attempted to notify a specific wheat variety as OHM. However, the application was rejected by Italian authorities on the grounds that the wheat was "insufficiently heterogeneous." Because the wheat also lacked the absolute uniformity required for a DUS registration, it was left in a legal limbo, unable to be legally marketed.
Similarly, in Denmark, the organization Landsorten distributes landraces of arable crops. These varieties are highly sought after by organic farmers because of their natural resilience, strong weed competitiveness, and deep root systems. However, under the Council’s proposed "local variety" restrictions, these Danish landraces might be banned from being sold to organic farmers in neighboring Sweden or Germany, despite their agronomic suitability for those climates.
Chronology of the PRM Regulation
The journey toward the 2026 Trilogue negotiations has been marked by several years of intense lobbying and legislative shifts:
- July 2023: The European Commission publishes its initial proposal for the PRM Regulation, aiming to replace 10 existing directives with a single regulation. The proposal includes provisions for "Organic Heterogeneous Material" but leaves many questions regarding conservation varieties unanswered.
- April 2024: The European Parliament adopts its first-reading position. MEPs largely support more flexibility for farmers to exchange seeds and for small-scale breeders to market local varieties without the full burden of DUS testing.
- Late 2025: The Council of the European Union reaches its "General Approach." This version of the text introduces the geographic restrictions and limits on arable crops that have triggered the current outcry from the organic sector.
- Early 2026: Trilogue negotiations begin between the Commission, Parliament, and Council to reach a final compromise.
- March 17, 2026: IFOAM Organics Europe, ECO-PB, and Demeter International send their joint letter to EU Agriculture Ministers, signaling that the current direction of the Trilogues threatens the EU’s agricultural sustainability goals.
Supporting Data: The Value of Seed Diversity
The push for more flexible seed laws is backed by alarming data regarding the loss of agricultural biodiversity. According to the Food and Agriculture Organization of the United Nations (FAO), it is estimated that 75% of plant genetic diversity has been lost since the beginning of the 20th century as farmers worldwide have moved toward genetically uniform, high-yielding varieties.
In Europe, the organic market has seen consistent growth, reaching a value of over €54 billion in recent years. However, the availability of organic seeds has not kept pace. Currently, a significant portion of organic farming still relies on "untreated conventional" seeds because organic-specific varieties are not available in sufficient quantities. To meet the EU’s "Farm to Fork" target of 25% organic land by 2030, experts estimate that the production of organic seeds must increase by at least 300%. The coalition argues that restrictive PRM rules will make it impossible to reach this target by discouraging investment in organic breeding.
Implications for Food Security and Climate Resilience
The implications of the PRM Regulation extend far beyond the organic niche; they touch upon the broader issue of European food sovereignty. Climate change is bringing increasingly unpredictable weather patterns to the European continent, including prolonged droughts in the south and extreme rainfall in the north.
Genetically uniform DUS varieties are often optimized for specific, controlled environments where water and nutrients are provided via irrigation and synthetic fertilizers. In contrast, local and conservation varieties often possess "latent" traits—such as heat tolerance or pest resistance—that are not expressed in every generation but provide a "genetic safety net" for the crop population. By restricting the movement and development of these varieties, the EU may be inadvertently reducing the resilience of its food system to climate shocks.
Analysis suggests that if the Council’s restrictive view prevails, the market will see further consolidation. Small and medium-sized seed enterprises (SMEs), which are the primary maintainers of local biodiversity, may find the cost of regulatory compliance too high. This could lead to a "seed desert" where only a handful of multinational corporations provide the genetic basis for the entirety of European agriculture.
Official Responses and Next Steps
While the Council has yet to issue a formal collective response to the March 17 letter, individual member state representatives have previously argued that strict "region of origin" rules are necessary to prevent consumer fraud and to ensure that "conservation varieties" do not become a loophole for substandard seeds to enter the market. They maintain that DUS standards are the "gold standard" for ensuring farmers know exactly what they are buying.
However, proponents of the organic sector argue that the "consumer protection" argument is being used as a shield for protectionism. They advocate for a transparency-based approach where seeds are clearly labeled regarding their heterogeneity and origin, allowing farmers to make informed choices rather than having those choices restricted by law.
As the Trilogues continue through the spring of 2026, the focus will remain on whether the European Parliament can successfully defend its more flexible stance against the Council’s restrictive amendments. The outcome will determine the legal framework for European seeds for the next several decades, deciding whether the future of European farming is one of industrial uniformity or biodiverse resilience. For the organic and biodynamic sectors, the stakes could not be higher: the very seeds of their movement are currently on the negotiating table in Brussels.