News Releases

DATE:	July 15, 2003
CONTACT:	Mark Condon
	(703) 837-8140

The View of the American Seed Trade Association on Organic Agriculture

Organic Agriculture

Organic agriculture, as defined by the U.S. Department of Agriculture (USDA), is a production system that is managed in accordance with USDA’s National Organic Program to respond to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity.

National and Global Organic Production and Trends

Organic agricultural production has been increasing in the United States. From 1995 to 2001, U.S. acreage dedicated to organic production increased from 914,800 to 2,341,482. The number of organic farmers has also been increasing by about 12% per year. Acreage of organic production of major crops such as corn and soybeans has almost tripled from 1995 to 2001 from 32,650 to 93,551 and 47,200 to 174,467 respectively. Still organic production remains at less than 0.5% of the total of 828,029,449 acres dedicated to agricultural production.

The top five organic producing countries are Australia, Argentina, Italy, United States and the United Kingdom with a combined acreage dedicated to organic production estimated at 22,811,267 hectares. In Australia and Argentina, most organic production is dedicated to extensive grazing land. The percentage of organic production relative to overall agricultural production for the top ten organic producing countries ranges from 17% in Liechtenstein to 0.23% in the United States.

Organic agriculture is presently a growing niche market that provides new opportunities for member companies of the American Seed Trade Association (ASTA). But as noted by the Organization for Economic Cooperation and Development (OECD), regulatory, infrastructural, and economic factors associated with organic production will impact future growth potential and sustainability of the organic market globally. National and global regulatory standards for organic products are precedents for the seed industry in terms of breeding, production, and marketing. ASTA, therefore, needs to be engaged in the development of policies and standards for organic production and certification especially as they pertain to seed. Organic agriculture is an area of significant interest for all segments of the seed industry including field crop, turf grass, vegetable, and flower seeds.

ASTA recognizes that it took eleven years to implement our current National Organic Program and that organic movement arose out of producer and consumer interest in establishing nationally recognized standards for organic agriculture. ASTA positions have been discussed and developed in the context of organic objectives and include input from all interested segments of the seed industry.
ASTA’s View on NOP Provisions, Standards, and Regulations

Policy and regulatory issues relative to organic agriculture requiring continual monitoring and input by ASTA and its members are:

Biotechnology
ASTA recognizes the inherent conflict between its position on biotechnology and current domestic and international policies and regulations for organic agriculture. USDA’s National Organic Program (NOP) prohibits the use of biotechnology, including biotech seed, in organic production processes. As the prohibition of biotechnology in organic products and production schemes is already precluded by regulations and difficult to amend, ASTA member companies will comply with NOP and other mandatory organic standards at the domestic and global level when seeking official certification of their products. Concurrently, ASTA will continue to educate domestic and foreign policy makers on the benefits of biotechnology as a viable and environmentally-safe tool for agricultural producers.

Process Verification and Adventitious Presence
It is the position of ASTA that product certification does not always coincide with process verification. While the NOP has provided guidelines to ensure organic certification is uniform in all states, it has neither developed uniform standards for organic verification nor identified a viable organization to provide regulatory oversight at national and local levels. As guidelines for organic process verification are being written and the NOP is requesting input in this area from all stakeholders of the organic industry, ASTA deems it imperative to develop and provide seed industry policy on this subject before any legislation is passed to maintain the free movement of seed globally.

ASTA strongly supports that organic certification under the NOP is process, not product, certification. As long as a producer of an organic product has not used excluded methods noted in the NOP and takes reasonable steps to avoid contact with the products of excluded methods as detailed in their approved organic system plan, the unintentional presence of the products of excluded methods should not affect the status of an organic product or operation.

Despite the fact that U.S. organic standards are process based and that only intentional use of excluded methods is prohibited in organic production, some organic producers and customers are still demanding that organic seed be tested for the possible presence of biotech material and meet set levels for unintended presence, usually defined as zero. ASTA strongly maintains that any movement toward organic seed testing or product certification is not only counter to USDA and NOP policy, but also the interests of the U.S. seed industry and organic producers at-large. It is well recognized in numerous food and agricultural production standards, including organic standards, that zero is not possible. Furthermore, any movement by seed producers to respond to such unrealistic market demands will not only undermine the viability of the U.S. government’s organic policy but could erode the U.S. seed industry’s future participation in the organic market.

Organic Breeding
ASTA supports the International Seed Federation’s (ISF) position on organic breeding and believes that limiting breeding methods will have a deleterious result by reducing the number of varieties available to organic producers and inhibiting the seed industry’s ability to develop organic varieties that respond to biotic and abiotic stress of economic importance. As public plant breeding programs are decreasing and fewer seed companies are prepared to fund and develop organic breeding programs, the organic community must create demand for this kind of expensive breeding effort to be viable in the future. The seed industry is willing to investigate where it can cooperate on breeding for the development of organic varieties that would address the needs of the seed industry, organic producers, and consumers alike.

Exemptions on Treated and Non-Treated Seed
NOP provisions do not permit chemical treatments of inbred or stock seed required for hybrid seed production or for foundation seed. ASTA firmly believes that as inbred vigor is generally weak and stand establishment difficult with untreated seed, exemptions must be made for use of treated inbred seed in the production of hybrid organic seed. In addition, as many species require multi-step use of stock seed in hybrid production, exemptions should also include chemical treatment of stock seed as well. Lastly, as seed is not a food product, exemptions for seed treatments should also extend to foundation seed in reproductive processes as long as the final product made available to organic producers remains untreated. These exemptions would greatly reduce the cost of organic hybrids and other seed as well as increase the number and quality of organic varieties for the organic community.

Variety and Species Certification and Equivalence
Prior to the implementation of the NOP, the issue of variety and species certification and equivalence was a concern to the seed industry. Consequently, ASTA advocated a two-year transition period where equivalence would first be defined by variety, not species, quality or price. After October 2004, equivalence would be measured on a “species” level as proposed in the European Union.

To date, the NOP has accepted part of the seed industry’s interim recommendation by defining equivalence by “type” and similar agronomic characteristics such as insect and disease resistance. However, ASTA feels that this definition is still too broad and is not needed to ensure an adequate supply of varieties for organic producers. There will be an adequate supply after the industry has time to increase organic seed inventories. Consequently, ASTA believes equivalence should be measured by “species” when the transition period is over and organic producers will be required to select the most suitable variety for their production location and time. ASTA’s proposed transitional deadline for variety and species certification and equivalence is October 2004. The European Union’s organic regulations are expected to go into effect January 2004.




Generation Issues
NOP provisions concerning generation issues accepts that any seed generation planted with conventional, untreated seed and produced under organic conditions can be certified as organic. ASTA supports the NOP provisions that breeder and stock seed need not be raised under organic conditions. However, ASTA believes that that treated, conventional in-bred and foundation seed raised under organic conditions should also be certified as organic.

Grandfathering Existing Varieties
ASTA agrees with the decision of the NOP that all non-biotech varieties existing prior to October 21, 2002 will be grandfathered as acceptable for organic production. New varieties to be certified as organic after the date when the NOP entered into force will be developed only by NOP-approved breeding methods.

Certified Seed
NOP provisions address the issue of certified seed and organic standards. To date, there are no examples where seed certification standards were unable to be met under organic production systems. This situation, however, may change in the future as different and more difficult species are produced under organic conditions.

Labeling Issues
The Seed Regulatory and Testing Branch under AMS/USDA and USDA’s Office of General Council have ruled that using the term, “certified organic seed,” is not a violation of the Federal Seed Act. The word “certified” therefore can be used to describe organic seed, as well as seed that has been certified for varietal purity. Accordingly, the seed industry does not have an issue with NOP provisions concerning labeling at the current time.

Pelleted Seed
Coating and pelleting operations have already demonstrated the ability to meet NOP specifications regarding organic pellet formulations and seed priming methods. ASTA feels that members can comply with NOP standards and provisions concerning pelleted and coated seed.

New Innovations
Recognizing that the NOP has a clear list of excluded breeding methods, ASTA supports NOP provisions that allow for inclusion of “new innovations” in organic seed breeding and production. ASTA believes that if these guidelines are followed, certain new innovations or breeding techniques (e.g., Clearfield line of herbicide resistant species) remain viable for inclusion in organic production processes.

Federal Seed Act and the NOP
The Federal Seed Act contains, among other items, regulations on labeling, packaging, seed moisture percentages, testing, purities, germination, and seed certification standards. ASTA recognizes and supports the fact that there is no conflict between Federal Seed Act and NOP regulations for seed production, conditioning, and marketing.
Enforcement of the NOP

ASTA’s position is that all NOP standards and regulations be enforced equally and consistently across all crops and all locations.


ASTA’s View on Global Organic Issues

Global Harmonization of Organic Standards
For non-U.S. regulatory systems and standards that affect the free movement of seed, ASTA encourages and will work towards the global harmonization of organic standards.

Different Growing Practices and Market Demand between the U.S. and Other Countries
ASTA recognizes that there are significant differences among growing practices and market demand for organic products in the U.S. and other countries. These differences will no doubt impact organic standards and regulations at the national level as well as the feasibility of global harmonization of organic regulations and standards.

International Federation of Organic Agricultural Movements (IFOAM)
ASTA will keep abreast of IFOAM positions and engage in dialogue either directly or indirectly through the International Seed Federation when appropriate. IFOAM is a non-governmental body and influential organic certifier that often seeks to advise, influence, and lobby governmental decisions. While European in origin, some American certifiers and businesses are IFOAM accredited in order to gain entry into certain markets. Yet, only ISO Guide 65 certification, as indicated in EU regulations 2091/92 and EN45011, is mandated to sell certified organic products in the European Union.

IFOAM and organic farming rules in Europe’s member states are not synonymous. As the EU continues to develop its organic program, there may be a strong effort for the EU to take over and harmonize organic rules within its member states. At that point, organic rules may not always reflect IFOAM standards.

NOP and IFOAM Standards

ASTA believes that NOP standards and regulations should serve as the primary model and foundation for global harmonization of organic systems. NOP and IFOAM organic standards, while similar, are in cases different. The perception that IFOAM standards may be more stringent is not substantiated. It should be recognized that NOP standards are legal and enforced by a governmental agency. Conversely, IFOAM standards are those of a non-governmental body and mostly advisory in nature.

Coexistence of Conventional and Organic Agriculture

ASTA’s believes that national and foreign organic policies and regulations should support the co-existence and viability of both conventional and organic agriculture.

The Role of OECD Seed Schemes in the Global Movement of Organic Seed

At the current time, the role of the OECD Seed Scheme in organic seed certification and the movement of organic seed globally is undefined. The OECD Seed Schemes mainly address issues relative to seed varietal purity and global harmonization of national certification systems for conventional seed. In order for organic seed to move through this system, national designated authorities of the OECD Seed Schemes will need to expand their scope in the area of organic process verification and increase its interaction with national organic certifiers. ASTA encourages continued dialogue with the U.S. National Designated Authority and the OECD Seed Schemes that would lead to a harmonized system for the global movement of organic seed.

Phytosanitary Regulations and Organic Standards

ASTA believes that current regulations and standards for organic seed, in that they restrict conventional production practices, breeding methods, and treatment applications, may ultimately lead to increased phytosanitary barriers to the global movement of organic seed. ASTA opposes this and will continually monitor this issue and advise members on relevant developments in this area.


Approved by the American Seed Trade Association’s Board of Directors on June 26, 2003.

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Founded in 1883, the American Seed Trade Association (ASTA), located in Washington, DC, is one of the oldest trade organizations in the United States. Its membership consists of about 900 companies involved in seed production and distribution, plant breeding, and related industries in North America. As an authority on plant germplasm, ASTA advocates science and policy issues of industry importance. Its mission is to enhance the development and free movement of quality seed worldwide.