State of Organic Seed Report
“Seed growers are at the heart of organic seed systems. From farmers who save seeds to the growers behind the varieties in seed catalogs, there wouldn’t be a seed—or food—supply without these producers. By the very nature of their work, seed growers continue the time-honored practice of keeping our seeds alive and adapting to changing environmental conditions and needs.”
– State of Organic Seed, 2022
As part of the 2022 State of Organic Seed project, OSA conducted a survey and interviews with certified organic seed producers to better understand their challenges. We received 127 responses to our survey, and interviewed 25 organic seed producers. Producers faced a range of challenges that were not directly related to production (see Figure 12 from the report below). The full chapter on organic seed production can be found here: https://stateoforganicseed.org/state-of-organic-seed-2022/#chapter-2-organic-seed-production-1
One of the challenges that came up in the survey and interview revolved around the challenges involved in organic certification. From the State of Organic Seed, 2022:
“Seed producers also identified organic certification as a challenge, with 60 percent of respondents noting the cost, and 55 percent noting the recordkeeping. Regarding cost, one seed producer shared: “Cost-share programs are decreasing. Certification costs are increasing, and yet many farmers still can’t even afford healthcare.” Comments on recordkeeping challenges fell into two categories: 1) managing highly diverse operations, and 2) the requirements of needing numerous certifications for different components of their operation. As one seed producer shared, “Due to the diversity that we grow (upwards of 200 varieties per year), the various recordkeeping requirements for certified organic production are excessive. The system penalizes biodiverse farm models.” Another seed producer shared, “It would be so great if the organic certifiers actually had a channel for seed production. We are certified as a grower, processor, and handler so the paperwork is EXCESSIVE!” When producing organic seed for commercial sale, organic seed producers need both a seed certification from the state in addition to organic certification.”
Seed Producer Concerns Raised Over Email
From 2019 through 2023, several email threads around organic certification concerns circulated among organic seed producers and handlers. While it is not appropriate to share those conversations directly, some of the primary themes that arose across several certified organic operations included:
- Requiring an immediate notice of adding or dropping varieties, rather than once a year.
- Requiring that the specific varieties of all off-farm sourced seed be listed in each producers’ certification, rather than just “seed” or the crop types.
- Requiring new certifications on older lots of seed that were certified at the time of production.
- The challenge of bringing in non-organic seed or seed acquired via seed exchanges, the USDA germplasm system, etc, where there is no organic commercial source of (until the producers grow it and make organic seed available to the market)
- Certifiers not understanding that, for the sake of seed production, certain lots or strains of an open-pollinated variety can be superior to others and shouldn’t be considered as equivalent when sourcing stock seed.
- Per-label charges on varieties offered can add up very quickly and can limit seed companies from offering varieties that are not the top sellers.
- The speed at which the certification process allows new varieties to be added to their certifications (up to 6 weeks) can be very hard to make work with the tight timeline between seed harvest and the winter peak seed selling season.
- Hurdles to move to a new seed packing facility, both around the slow timeline (up to 8 weeks turn-around) and the requirement that the facility be completely set up prior to inspection when seed packeting needs to continue throughout the process and the company can’t hire and supply two facilities for the two-month facility inspection process.
- Many find the overall costs for handling certificates too high.
- Feeling like they don’t fit the handling process — that it was designed for food manufactures and many of the questions don’t fit.
These concerns were raised to certifying agencies and trade groups, who desired to better understand and address organic seed producer and handler concerns.
Organic Seed Producer and Handler Certification Survey
In January of 2024, a survey was sent to certified organic seed producers and handlers to get more detailed information on some of these challenges around certification.
Seventeen certified organic seed producers and/or handlers responded to the survey, as well as one producer who had been previously certified.
In 2023, survey respondents had certified acreage ranging from 2 to 100 acres, and had produced between 1 and 150 different seed crops. Respondents had been certified from 3 to 35 years.
The chart below shows the respondents’ ratings of challenges around the certification process. Respondents reported spending between 2 and 150+ hours each year on record-keeping and paperwork for their certifications.
Collaborative Planning Session Breakout Session Summary
In collaboration with staff from Oregon Tilth and Accredited Certifiers Association, on February 27th 2024, OSA hosted an online collaborative planning session for organic seed producers, organic seed handlers, and certifying agency staff to better understand the challenges being faced in the certification process, and to identify potential solutions. Approximately 80 participants joined the session.
The agenda for the session consisted of a brief overview of the issues and a summary of the producer and handler survey, followed by a resource and influence exercise. The remainder of the meeting utilized the “TRIZ” facilitation process as described by Liberating Structures (https://www.liberatingstructures.com/6-making-space-with-triz). Participants were assigned to breakout rooms based on the following four topics:
- Seed Strain/Type
- Certification Process
- Certification Cost/Time
- Understanding Between Certifiers and Seed Producers/Handlers
Below are summaries of the main concerns and suggestions that came from the breakout groups on each of those topics:
1. Seed Strain/Type:
Main Concerns:
- The necessity for seed producers to source non-organic seed when there’s no available organic option.
- Lack of understanding from certifiers about the importance of specific seed strains or types, especially in terms of regional adaptation and genetic diversity.
- The cumbersome process and unrealistic expectations for sourcing multiple organic options when limited or no options exist.
Suggestions:
- Revise NOP 5029 to provide clearer guidelines on exceptions for non-organic seed use and define “equivalent” varieties more comprehensively.
- Encourage more input from growers to inform certifiers about the nuanced requirements of seed production.
- Develop a glossary of seed terms to ensure clear communication between producers and certifiers.
2. Certification Process:
Main Concerns:
- Overly burdensome paperwork and recordkeeping requirements, particularly for operations that maintain a high diversity of seed varieties.
- The current certification process does not adequately accommodate the unique aspects of seed production and handling.
- Lack of transparency regarding the resources and guidelines available to seed producers and handlers.
Suggestions:
- Create a specialized certification channel or process tailored for seed producers to address their specific needs and reduce administrative burdens.
- Improve transparency and access to information about certification resources and requirements.
- Encourage certification agencies to develop a deeper understanding of seed production nuances and tailor their processes accordingly.
3. Certification Cost/Time:
Main Concerns:
- The high costs associated with certification, particularly for small operations and those handling multiple seed varieties.
- Delays in the certification process can adversely affect the timing of seed catalog publication and market readiness.
- The need for expedited certification processes imposes additional financial burdens on producers.
Suggestions:
- Explore options for streamlining certification processes to reduce costs and accelerate timelines, such as adopting risk-based approaches or allowing for remote inspections.
- Develop clearer, more consistent guidance from the NOP on certification standards and requirements, reducing the need for repeated clarifications.
- Establish a centralized database or resource for organic seed availability to facilitate easier compliance and planning for producers.
4. Understanding Between Certifiers and Seed Producers/Handlers:
Main Concerns:
- Certifiers often lack specific knowledge or training on seed production, leading to misunderstandings and inefficiencies in the certification process.
- Seed producers and handlers feel that their unique challenges and operational realities are not adequately acknowledged or addressed by certifiers.
Suggestions:
- Provide targeted training and resources for certifiers to better understand seed production and handling, perhaps through dedicated staff or specialized training modules.
- Encourage more direct communication and feedback loops between certifiers and the seed community to foster mutual understanding and collaboration.
- Develop shared resources, such as glossaries or best practice guides, to standardize terminology and procedures across the certification landscape.
Next Steps
Organic Seed Alliance is committed to working with organic seed producers, organic seed handlers, certifying agencies and other interested parties to address the needs of the organic seed community around organic certification. We intend to form a working group to review the findings summarized in this document and identify and implement actions to improve the process for organic seed certification. If you are interested in participating in this process or would like to be kept informed about future developments, please contact Cathleen McCluskey, Organic Seed Alliance’s Director of Advocacy and Communications at cathleen@seedalliance.org or Jared Zystro, Organic Seed Alliance’s Co-Director of Research and Education at jared@seedalliance.org