Organic Broadcaster

Changes in the works to strengthen National Organic Program’s organic seed policy

By Kiki Hubbard, Organic Seed Alliance

The National Organic Standards Board (NOSB) Crops Subcommittee currently is tweaking its organic seed policy proposal introduced at the fall NOSB meeting in preparation for the board’s spring meeting. The proposal aims to do two things: 1) update the organic seed regulation, and 2) strengthen the National Organic Program’s (NOP) organic seed policy guidance document for certifiers.

The proposal recommends a requirement that farmers demonstrate annual improvements in organic seed sourcing until they reach full compliance. The recommendation allows certifiers flexibility in working with operations to meet this goal and in measuring improvement. The proposal also provides detailed recommendations for improving the NOP’s 2013 guidance document on organic seed and planting stock (NOP 5029), a crucial resource for certifiers who are charged with interpreting and enforcing the organic seed rule. If passed by the NOSB and implemented by the NOP, these changes would result in clearer guidance and more consistent enforcement of the organic seed requirement.

Current organic regulations require organic farmers to use organic seed when commercially available. Because the organic seed supply was insufficient when the rules were implemented, farmers have been allowed to plant conventional, untreated, and non-GMO seed when organic seed is unavailable. This exemption was meant to provide a transition time for the organic seed supply to catch up to demand.

Over the last 15 years, we’ve made much progress in increasing the quantity, diversity, and quality of organic seed available. Though the exemption is still needed given supply gaps, it is more important than ever that organic operations continuously improve their use of organic seed. The benefits of doing so go well beyond meeting a regulatory requirement.

Organic Seed Matters
Organic plant breeders and seed producers are working for organic farmers by focusing on characteristics that are especially important to low-input systems, such as quick emergence, weed competitiveness, nutrient-use efficiency, disease resistance, and more. Too much of our seed is currently bred and produced under conventional, agrochemical conditions, and with breeding goals that often don’t benefit organic farmers. The organic community has an opportunity to create a path for organic seed that’s distinct from the dominant seed industry controlled by agrochemical interests.

We all have a role to play in creating this path. As mentioned, increasing the availability of organic seed isn’t just important for helping organic farmers meet a regulatory requirement—the benefits are potentially far-reaching. Seed holds endless potential for transforming our food system, especially when coupled with the principles that built the organic movement—diversity, health, ecology, and fairness. We can breed and grow more organic seed that is adapted to organic farming systems and regional climates, and that contains traits important in the field and on our plates. This path is shaped by our individual decisions to choose organic seed when appropriate, to communicate ongoing supply gaps and challenges to the organic seed community, and to advocate for collaborative solutions to meet these needs.

It is no one’s intent to advocate for actions or policies that force organic farmers to use organic seed that isn’t a good fit for their production systems and markets. Yet the allowance to use non-organic seed has also proven a challenge to growing the diversity and quality of organic seed available. This modest proposal recommends that organic operators who don’t make an effort to source more organic seed over the years be encouraged to take extra measures to demonstrate improvement. This is a practical proposal that signals to the broader organic community that organic seed is important to organic integrity, and that further investments in organic seed will have a positive ripple effect that leads to more high-quality seed options that are well-suited to organic systems.

GMO Contamination in Seed
The NOSB is also working to address genetic integrity issues in organic and other forms of non-GE seed. The unwanted presence of genetically engineered (GE) material in seed used by organic growers remains an unfair burden on the organic sector. Organic crop producers, seed producers, and seed companies are responding to the challenges GE contamination poses through routine testing, prevention strategies, and by redirecting contaminated seed to less valuable conventional markets. These practices result in burdens that go beyond the cost of testing and monitoring the problem, resulting in risks to reputations and breeding projects.  

To date, the NOSB Materials/GMO Subcommittee has published three discussion documents and one report on the topic of seed integrity and is currently working on a proposal in advance of 2018 meetings. At the November 2017 meeting, the NOSB invited additional comments in response to these documents. See the documents online at

Some questions that remain unanswered:

•   What are the best sampling procedures and testing methods?

•   Who bears the brunt of testing costs and the consequences of rejected seed?

•   What, if any, threshold is appropriate and feasible for unwanted GE material in organic and other non-GE forms of seed?

•   Who should pay for the costs associated with contamination when it is identified?

Plant Breeding Excluded Methods
The Materials/GMO Subcommittee is tackling a seond complex seed issue: excluded methods as they pertain to plant breeding. Crop improvement methods—such as controversial gene editing techniques—continue to evolve rapidly and are outpacing current regulations that oversee new forms of agricultural biotechnology. Understanding and addressing new breeding techniques that may or may not align with organic principles are important challenges the organic community must confront.

In 2016, the NOSB passed a proposal that includes principles and criteria for evaluating the appropriateness of new methods for organic production systems. The proposal also includes definitions that clarify the broader excluded methods definition, describing terms like “traditional breeding” and “genetically modified organism.” The proposal has a terminology chart for easily referencing which methods are excluded, which are allowed, and which are yet to be determined. Collectively these various pieces serve as a framework for reviewing new and existing methods to establish if they should be excluded.

At the November 2017 meeting, the NOSB voted to exclude three more methods—agroinfiltration, cisgenesis, and intragenesis—and also charged the Materials/GMO Subcommittee to develop clear definitions for these and other methods listed in the terminology chart. The organic community will likely have the opportunity to review and comment on these definitions ahead of the April 2018 meeting.

Next Steps
Organic seed policy issues are complex, to be sure, and the NOSB is striving to honor this complexity by providing practical recommendations that balance reality on the ground with regulatory requirements. The next NOSB meeting is scheduled to take place April 25 – 27, 2018, in Tucson, Arizona.

Stay abreast of organic seed policy comment opportunities by following Organic Seed Alliance on social media (Facebook and Twitter) or by signing up for our quarterly enews at Or contact me directly with questions or ideas at

Kristina (Kiki) Hubbard is the director of advocacy and communications for the Organic Seed Alliance.


From the January | February 2018 Issue

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