Dear Mr Dickson

Thank you for your email regarding the proposed EU Regulation on Plant Reproductive Material (PRM).

Please be rest assured that many of the problems you envisage with the proposed regulation have already been brought to my attention by a number of businesses, trade associations and, of course, the UK Government.

The European Commission's expressed aim is to simplify the existing body of EU legislation and to reduce the bureaucracy on Professional Operators. Lighter or more flexible rules are also foreseen for traditional plant varieties. The Commission proposal, however, is not as straightforward as it seems and the draft regulation, if implemented, would do much harm to the horticultural sector, particularly in ornamentals and fruit.

The Commission proposal was considered for the first time in the European Parliament's Agriculture Committee on 30th September, and the Committee's appointed Rapporteur (or draftsman), Mr Silvestris, published the Committee's first amended version of this draft regulation this week. As a member of the Agriculture Committee I will have the opportunity to submit my own amendments to the draft text, with an amendment deadline of 4th December.

As an absolute minimum, the Commission should refrain from introducing new burdens concerning the identity of plant varieties in the ornamentals sector and the registration of fruit varieties. Furthermore, 'Value for Cultivation or Use' (VCU) testing should not be extended to vegetable and fruit species. Such changes would impose a costly burden on the sector, possibly running into hundreds of millions, for which there is no demonstrated benefit.

The proposal to introduce a new category of PRM for 'niche markets' is equally worrying. Whilst the proposed derogation on 'niche market' PRM would allow seed varieties to be marketed in small quantities without registration, this is on the proviso that the company producing and marketing the seed has less than 10 employees. Most companies involved in the professional development of seed varieties exceed this number, as you will no doubt agree, with micro organisations simply not having the resources to do this well. Far from providing operators in the sector with a wider choice of options for producing and marketing different types of PRM; and providing for more lighter or flexible rules for breeders, the proposals, as envisaged, would halt the professional development of varieties for home-gardeners and small-scale farmers.

In brief, my main concerns with the proposals are:

• the removal of the 'commonly known' status from the existing Directive;
• the requirement for an Officially Recognised Description (ORD);
• the extension to include seeds and all other propagation material of ornamentals;
• the labelling requirements and associated costs;
• the extension of VCU requirements to vegetable and fruit species;
• the arbitrary threshold of less than 10 employees for the 'niche market' category;
• the unreasonable number of Delegated Acts.

Finally, you may be interested to know that I am Rapporteur for the report on “The future of Europe's Horticulture Sector- strategies for growth”, currently making its way through the Agriculture Committee of the European Parliament. I have made reference to PRM and my concerns in this report and will continue to work closely with the horticulture sector to raise awareness about the damaging effect that this draft regulation will have on the sector if left unchanged.

Thank you once again for taking the time to write to me.

Yours sincerely

Anthea McIntyre MEP

Anthea McIntyre MEP
Conservative - West Midlands Region
A: The Chapel, Wythall Estate, Walford, Ross-on-Wye, HR9 5SD
E: anthea@antheamcintyre.com
W: www.antheamcintyre.com