An Update on the Organic Seed Rule
by Micaela Colley, Bulk Seed Representative

Seeds of Change has always been committed to growing and selling 100% Organic seed. In 2003, with the adoption of the USDA organic seed rules, we launched our first bulk seed catalog to extend our offerings of organic seed to market growers. The USDA rules provide that organic growers are required to utilize organic seed, except "When an equivalent organically produced variety is not commercially available." (NOP Section 205.204). Now in its second season of implementation, the organic seed rules are still confusing and stimulating much discussion among growers, seed companies, certifiers, and the rest of the organic community about the interpretation of equivalency, the development of a timeline for adoption of 100% organic seed, and the stringency of enforcement.

	Market Growers: Featured Variety, Scarlet Nantes Carrots growing in the field. Check out information on this variety in our Market Grower section on the website.

As growers adopt organically grown varieties, we at Seeds of Change strive to support growers' choices through extensive trials of our varieties and other commercially available varieties at our research farm and on cooperating organic growers' farms. We are excited to participate in this important step toward the development of a truly sustainable organic production system, but recognize that change can be difficult and supporting organic growers is crucial throughout this process.

Clearly the NOP (National Organic Program, USDA) recognizes the importance of organic seed in lending integrity to a national organic label, but the looseness of the wording reflects the reluctance to place an undue burden on organic growers in a limited seed market. The hope is that by granting exceptions and asking for a good faith effort from growers that, in time, the organic seed market will develop and availability won't be an issue.

Many seed companies have expressed the desire for stronger rules to ensure a market for organic seed and justify their investments. In July of 2003, the American Seed Trade Association (ASTA) released a position statement to the USDA that they would like to see a requirement that organic seed must be used if any organic variety of that species is available (i.e. if organic broccoli is available it doesn't matter what variety it is). At the recent Organic Seed Conference hosted by Organic Seed Alliance, a representative of Washington State Organic Certifying Program commented that she does not envision that there will ever be a day when exceptions won't be granted. The expectations and opinions about how to move forward are widespread, but those at the core of the movement are working toward creative measures to aid both growers and seed companies in the growth process.

There have been recent discussions among the seed community regarding the opportunity for cooperative organic plant variety breeding and improvement projects, as well as the need to publicly fund variety trials to evaluate available germplasm. The research community is also developing new projects focusing on organic controls for seed-born diseases. In addition, recent USDA funding has released grant opportunities that are explicitly geared toward supporting organic breeding and seed research.

Much of the discussion of the seed rules has surrounded the exception clause and the interpretation of the word "equivalency". The exception reflects the lack of commercially available organic seed and the fact that most organic producers have grown accustomed to varieties created and produced by the conventional seed industry. Many of these varieties are not available organically grown and are proprietarily held by conventional seed companies. Recent discussions between the USDA and seed industry representatives have addressed the need for a national database, accessible to all, that lists organically available varieties and their key traits. Such a database would aid growers making seed selection decisions, increase certifying agencies awareness of availablility, and help guide seed companies in filling gaps in availability.

The word "equivalency" has also raised questions of defining equivalent-type, equivalent-quality, equivalent-cost, and more. The rules do not state that price difference is a reason for exemptions, but some certifying agencies have interpreted it as such. Quality issues address concerns of germination rates, seed vigor, disease-free seed, seed cleanliness, uniformity, and availability of seed treatments. On the positive side, raising such questions has brought awareness to growers of scrutinizing seed quality.

At Seeds of Change we have always held high quality standards and welcome this heightened awareness. All of our seed is tested for high germination rates and scrutinized for cleanliness, and the integrity of our varieties is maintained through our network of cooperating seed growers and at our research farm. The best growers know that seed quality is invaluable, and we are working to keep our prices as competitive as possible without sacrificing quality. All of our seed is grown by our network of certified organic growers rather than bought off of a large scale commodity market and our prices reflect our dedication to supporting their livelihood. However, we are also working with our growers to improve efficiency and keep our prices reasonable, as we move toward offering larger quantities and a wider selection of varieties.

The vagaries in the rules have been left for each organic certifying agency to interpret and enforce. Their approaches have varied widely. Recently, Matthew Dillon, director of Organic Seed Alliance, conducted an informal survey of certifying agencies' enforcement of the seed rules. He reports wide inconsistencies: certifiers guidelines varied from requiring no documentation of attempts to source organic seed, to asking for documentation of at least three sources where the grower's chosen variety was unavailable, to requiring that the grower trial at least some organic seed. Some certifiers, including Peter Miller of Oregon Tilth, report that they ask growers to show a plan of how they are working toward integrating organic seed into their system; this "bigger picture" approach asks growers to really make a good faith effort, rather than just checking a couple catalogs. At Seeds of Change we have found many growers excited to have access to organic seed, especially the availability of our unique varieties, and we encourage growers who are attached to non-organic varieties to at least try some alternatives.

We look forward to growing together,
Micaela Colley
Bulk Seed Field Representative

Photo caption: Scarlet Nantes field trials.