IoH Response to DEFRA Consultation on

Review of Seed Certification in England :
Draft Seeds Regulations & Registration, Licensing and Enforcement Regulation

The Institute of Horticluture (IoH) wishes to comment specifically in relation to the UK vegetable seed industry.

The Institute believes the objectives are to satisfy the EC and UK requirements for purchaser protection and to ensure that UK growers have the opportunity to maximise their own potential in product development and crop production. There are two aspects of vegetable production that make it unique when compared to other crop groups:

1. There are now for each vegetable crop, very few key producers (in most crops less than 10).
2. Vegetable seed varies greatly with each crop in reproducibility, value, size and volume used per hectare.

The Institute's main concern is the topic of early stage trials. National listing now takes place on an international scale ensuring that expenditure by a seed breeder benefits many rather than just a handful of local growers. The Institute believe that the same is necessary for control of research samples for use at an early stage. It is also necessary to ensure that UK growers have the same opportunities as overseas producers.

Product development by the small number of producers is allied to market needs and, in some cases, quick varietal development is very necessary. A good example of this is the lettuce crop when fast uptake of varieties with the latest Bremia resistance is important. Bremia control cannot easily be achieved by the use of chemicals and when a new Bremia strain becomes widespread, perhaps over two seasons, a high level of 'natural' control is necessary. Lettuce produce six to eight generations per season, both in breeding and consumption cycles, making a single year a long time in terms of crop development. This compares with hybrids such as brassica or root crops which need more than one year for a single cycle. Therefore a system that enables lettuce varieties to be assessed in trial, produced and commercialised as quickly as possible is the best solution for both consumer and environment.

The volume of seed allowed for research purposes must suit the crop. Beans at say 1,000 seeds per kilo and 120,000 plants per hectare are being classified in the same way as brassicas at 250,000 seeds per kilo and perhaps 25,000 plants per hectare. It is not reasonable to use just one volume figure to control trials for both crops.

Regulations need to keep up with the changes occurring in our industry; we do believe that the issue of early stage sampling is important and should be designed to enhance crop production.