analysis of the alternative agriculture’s seeds market ... · keywords organic seed seed...

REVIEW PAPER

Analysis of the Alternative Agriculture’s Seeds MarketSector: History and Development

Pietro Barbieri1 • Stefano Bocchi1

Accepted: 15 July 2015 / Published online: 22 July 2015

� Springer Science+Business Media Dordrecht 2015

Abstract Alternative agricultural systems, like organic and local agriculture, are

becoming increasingly important in Europe to the detriment of conventional

methods. As a matter of fact, sustainable agriculture, which started as a niche sector,

has been able to conquer a significant share of the European agro-food market.

Institutional promotion along with increasing consumer demand has allowed for the

development of different agricultural models, from the farm to the fork, with an

increasing focus on the ethical issues associated with the agro-food production

system. For instance, the organic agriculture agro-food chain is based on four

principles, namely health, ecology, fairness and care (IFOAM 2004) with the goal of

competing in the global agro-food market while respecting the environment, live-

stock, producers, and consumers. Within these themes, the seed market represents

an extremely complex part of the whole picture. The present paper analyses the

historical evolution of the seed sector by identifying the main issues related to

sustainable agricultural systems and protection of biodiversity. It follows the

identification of different seed markets based on different farm types. The two

aspects are then discussed and matched in order to identify the main issues char-

acterizing the sector. A review of possible solutions to those problems, taking into

account their ethics, is also provided.

Keywords Organic seed � Seed legislation � Semi commons � Seed markets � Plantbreeding

& Pietro Barbieri

[email protected]

Stefano Bocchi

[email protected]

1 DiSAA – Dipartimento di Scienze Agrarie e Ambientali - Produzione, Territorio, Agroenergia,

Universita degli Studi di Milano, Milan, Italy

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J Agric Environ Ethics (2015) 28:789–801

DOI 10.1007/s10806-015-9563-x

http://crossmark.crossref.org/dialog/?doi=10.1007/s10806-015-9563-x&domain=pdf

http://crossmark.crossref.org/dialog/?doi=10.1007/s10806-015-9563-x&domain=pdf

Introduction

Sustainable agriculture and, in particular, organic agriculture have become

increasingly important in the European agro-food market since 1991, when, in

the context of EU farm policy reform, the European Council of Agricultural

Ministers adopted the first organic farming regulation (EEC No 2092/91).

Increasing consumer demand and institutional promotion supported the adoption

of various production models that are respectful of the environment, livestock,

producers, and consumers while simultaneously enabling them to compete in the

global agro-food market. The seed market is an intrinsic part of this picture and

needs to be analyzed in detail with regards to how it relates to sustainable

production systems, based on ethical and holistic approaches to agricultural

production. Therefore, all the different aspects of the seed sector have to be

analyzed in order to provide an in-depth analysis. This requires investigating the

historical evolution of the seed industry and relevant legislation from the beginning

of modern plant breeding. Such an investigation is essential since both moral and

ideological issues are fundamental to seed production systems. Relevant issues that

need analysis are the definition of the rights to use, protect, and exchange genetic

information and its improvements, both as an abstract or as a physical seed property.

Hence, in order to progress in this field, a synthesis of the status of the art is

required. Interdisciplinary approaches and research methods in cooperation between

farmers, scientists, and policy makers have to be found in order to solve the

problems identified (Barlow et al. 2011; Pautasso et al. 2013). Therefore, this paper

aims to (1) describe the structure of the seed sector based on the historical evolution

of genetic resource management, (2) describe the current state of the global seed

markets, (3) discuss, compare, and contrast, how identifying current laws impacts

sustainable agricultural systems and potential development prospects for the sector.

The Seed Branch Historical Evolution

Seeds are part of a larger picture involving genetic resources while being one of the

most important agricultural inputs. At the same time, seeds’ intrinsic genetic

information is the starting point for any breeding process. Plant selection has been

characterized by a multi-step evolution that often overlap or compete with each

other. The process started with gathering plant material, which lasted for millions of

years. This material (i.e. seeds) was unconsciously collected from the best plants,

leading to a first kind of selection. Then, after the birth of agriculture, plant genetic

resources were domesticated and diversified into different varieties by small-scale

traditional agriculture over 10,000 years. Modern genetic science led to the

development of so-called improved varieties (BEDE 2011) and the application of

property rights to plant genetics. Therefore, it is essential to understand the

interactions between such property rights and plant genetic resource management.

The analyses carried out by Enrico Bertacchini (2007) shows the historical

evolution of such aspects.

790 P. Barbieri, S. Bocchi

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First, we have to mention that the ability to modify and manipulate genetic

information, after Mendel’s experiments, created the bases for the birth of a highly

specialized plant breeding private industry (Morris et al. 2006). In earlier times,

plant selection was simply carried out by farmers without a commercial interest.

Second, we have to consider the arrival of the ‘‘green revolution’’, defined as a

series of research, development, and technology transfer initiatives occurring

between the 1940s and the late 1960s, which increased agricultural production

worldwide, particularly in the developing world, leading to industrial agriculture.

This agricultural model, still applied today, is based on much more uniform plant

varieties than in the past. The process of genetic erosion, consisting in loss of

genetic variation (Van Treuren 1991) and which has been under discussion for the

last decades, has been partially linked to this form of agriculture (Lotti 2010;

Pautasso et al. 2013). On the other side, the genetic erosion, summed up with the

introduction of other techniques, like genetic engineering, increased the value of

plant genetic resources. Seed and genetic resources regulations have already been

recognized to be part of the biodiversity threatening factors (Pautasso et al. 2013).

This introduction of ‘elite varieties’ went through the production of stable and

homogeneous cultivars, and through the transformation of the information stored in

the DNA by the modern biotechnological methods. Eventually, in the last decades,

synthetic biology and the nanotechnologies were applied (BEDE 2011), increasing

the value of genetic resources.

The increase in genetic resource value is from applying the patent system to plant

genetic material. The idea was to improve resource allocation by signing an

international agreement known as TRIPs (agreement on Trade Relates Aspects of

Intellectual Property Rights) promoted by the WTO (World Trade Organization). In

addition to such property rights, a second agreement, known as CBD (Convention

on the Biological Diversity) was signed in 1992, creating the legal bases for the

birth of the sovereign rights on plant resources. These agreements regulated the

genetic resources exchanges by introducing a bilateral mechanism. Hence,

according to Bertacchini (2007) and other authors (Herdt 1999; Gulati 2001;

Helfer 2005), the genetic resources can be considered as a global common, which is

slowly disappearing. As with all changes, this ongoing process involves positive and

negative aspects. On one hand, privatization promotes innovation while, on the

other hand, access to vital information in a cumulative process such as plant

breeding is slowly denied. A solution to this dualism may be to consider genetic

resources as semi-commons goods (Bertacchini 2007). This is because seeds can be

considered either in physical terms as the phenotype, which can be used as a private

good in the breeding activity, or in genetic terms as the genotype, which should be

maintained as a freely accessible common good.

In the past, farmers simply saved a portion of their harvested seeds, from their

best plants, to plant the following year. This system was highly decentralized and

characterized by a huge number of varieties and information was freely exchanged

among farmers in order to develop new varieties. Therefore, genetic information for

each crop was captured by using phenotypic traits. In such a system, the genetic

resource value is low, due to how seeds are to be replicated and exchanged. As

previously mentioned, modern breeding was born following the discovery of the

Analysis of the Alternative Agriculture’s Seeds Market… 791

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Mendel’s laws. The increased selection ability and further development of modern

agriculture led to the development of modern varieties and consequently, genetic

erosion. The increased cost of production caused the solution of this public goods

dilemma by public funding of ex situ conservation centres. Gene banks became

crucial for preventing the process of genetic erosion, and due to the fact that the

modern world agriculture was based on non-autochthonous varieties. In 1971, under

the supervision of the CGIAR (the Consultative Group for International Agricultural

Research), new international gene banks and non-governmental research centres

were created. Nowadays, at an international level, the research centres (e.g. NARCs,

IARCs and CGIAR) freely exchange genetic resources for research purposes. This

globalization led to a further increase in the value of genetic information, especially

for those countries that rely on non-indigenous crops.

Nevertheless, other genetic resources’ management methods developed in the

private sector. The technological changes simultaneously led to the emergence of

property rights and plant breeders’ rights. Created in the 1960s, they were initially

different from the patent system (BEDE 2011). They protected the material from

multiplication without payment, not the innovations themselves. At the beginning,

no information about the plant’s progenitor was provided, but the market value of

the seed was protected. ‘‘This means that any breeder could prove that their varieties

had been used in a breeding plan where a competitor now had an intellectual

protection’’ (BEDE 2011, p. 32), and it was impossible to prevent farmers from re-

sowing. Those characteristics were obviously a limitation to the level of protection

of private breeders. This problem of information distribution on one side and access

Table 1 UPOV evolution (Modified from: GRAIN 2007)

UPOV 1961/1978 UPOV 1991 Possible next UPOV

revision

Considered

species

Optional All species All species

Protected

material

Reproductive material All material. Optional for the

derived products

All material. Optional for

the derived products

Protection

lifetime

15–18 years 20–25 years 25–20 years

Use for the

selection

Always authorized Always authorized, but

absence of new protection

on derived varieties

Non-usable for 10 years.

Then usable only after

payment of royalties to

the owner

Possibility of

seed

conservation

The signatory states can

authorize, restrict or

prohibit the

conservation

The signatory states can

authorize the conservation

only after a royalty payment

or prohibit it

It depends on the breeder

authorization

Double

protection

thanks to the

patent system

Missing Only in Europe on genes but

not on varieties

Present


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to information on the other side is even more notable in a system where innovation

is a cumulative and collective process (Barbieri 2012).

With the development of these new breeding techniques, the role of the states

progressively decreased, opening the path to the private industry. Additionally,

production costs increased and led to new property rules allowing for further

valorisation of plant genetic resources with the introduction of the patent system.

This expansion of the property rights reached a worldwide level by the previously

mentioned agreements known as ‘‘Trade Related Aspects of Intellectual Property

Rights’’ (TRIPs), managed by the WTO. Furthermore, the CBD created in 1992 led

to the birth of the Sovereign Right on Plant Resources. This was required by the

private breeders in order to protect their investments, as well as by the states with

high biodiversity in order to regulate the access to their resources. The reformation

in 1991 of the 1961 and 1978 UPOV (International Union for the Protection of New

Varieties of Plant) (Table 1) caused what Bertacchini (2007) calls ‘‘the Semicom-

mons systems enclosure’’ (Fig. 1). A system based on the interaction between the

private (private use of the phenotype obtained from the breeding activity) and the

public use (free access to the genetic information) was about to run out. This model

had huge repercussions on the current seed system and is a clear expression of a

mentality based on the agriculture industrial revolution.

The Seeds Markets

According to Wolfe et al. (2008), there are three main types of farms characterized

by three different market requests (Table 2):

• The global commodity producers or the large-scale farmers, who require highly

standardized and productive varieties.

Fig. 1 Scheme of the genetic resources structure. The figure on the left represents the situation before thesigning of the CBD. The exchange relationships among the stakeholders were free (solid lines) orregulated by market exchange rules (broken lines). The free exchange within the stakeholders waspossible. The figure on the right represents the systems after the emerging of the property rights. The freeexchange was substituted by access property rules (broken lines). The exchange within singlestakeholders is under regulation (modified from: Bertacchini 2007)


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• The regional producers, who provide highly variable products, interested in both

modern and old regional varieties.

• The small local farmers, who are more likely to use locally adapted varieties in

no input systems.

Considering the two primary situations, attention has to be focused on both

global and local markets.

Two main points characterize local markets and farmers (The international

commission on the future of food and agriculture 2006): first, they are essential for

the sustainability and the maintenance of diversity as a security source against

possible future natural disasters (e.g. the spread of plant diseases). Diversity is the

key aspect of any holistic approach in terms of varietal, microbial, and animal

(including human) genetic diversity. Seed diversity in such a system is the basis of

that system’s diversity (Barbieri 2012). The biodiversity conservation level also

depends on the farmers’ ability to earn sufficient revenue. Therefore, the

establishment of local direct production-consumption chains for the protection of

local agriculture is strictly linked to the safeguard of local farming, as conciliation

between tradition and innovation. Secondly, local markets are characterized as

freedom systems or systems where seed is a common property resource. The

intellectual property principles are violating this freedom when they exclude the

possibility of any other different action. In particular, free access to genetic

resources has to be guaranteed, and the farmers’ role in the collective and

cumulative breeding process recognized.

The global market needs more standardized varieties. An increase in seed

production depends on an increase in farmer demand. Nevertheless, this virtuous

process can only be achieved if the seed companies are able to provide the market

with suitable varieties and have access to information regarding the farmers’

requests. Therefore, a market investigation on farmers’ needs consisting of request

data crosschecked with the varieties released is essential. Another crucial problem is

Table 2 Different farming systems

Farming

system

Breeding

orientation

Genetic resources Selection methods Naturalness

component in

focus

Large-

scale

farmers

BFCA*,

BFOA**,

OPB***

Advanced breeding lines

and varieties

Centralized, wide

adaptation

Non chemical

approach

Regional

farmers

BFOA, OPB Advanced breeding lines

and regional varieties

Decentralizes, both wide

and local adaptation

Agroecological

approach

Local

farmers

OPB Locally adapted varieties PPB, decentralized Integrity of life

approach

* BFCA: Breeding for Conventional Agriculture; ** BFOA: Breeding for Organic Agriculture (in con-

ventional organizations); *** OPB: Organic Plant Breeding (in organic organizations); PPB: Participa-

tory Plant Breeding. (Source: Wolfe et al. 2008)


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the registration process for the new varieties. The main problems in the present

legislation can be ascribed to the DUS (Distinctiveness, Uniformity and Stability)

parameters and VCU (Values of Cultivation and Use) tests, which had been

designed for industrial agriculture. Those tests have to be overcome for the

registration of any varieties to the official catalogue, which is required to get the

legal status of any plant. This registration was initiated in order to create a

transparent market (Chable et al. 2012). According to Chable et al. (2012), if the

early varietal description parameters were based on agronomic factors, DUS

parameters were grounded on yardsticks that have no agronomic value. In addition,

all the varieties have to overcome VCU testing, which are performed under high

input conditions, returning erroneous performance results for the varieties selected

for low input agriculture. If a change in the registration tests would be beneficial, a

similar thought should be applied to the breeding system. The decentralization level

of breeding is indeed lower than for the local market. Nevertheless improvements

have to be achieved in order to match the farmers needs to the breeders research.

Global seed legislation currently does not recognize or support the coexistence of

both local and global agro-production systems, which leads to the presence of a

formal and informal seed markets. (Table 3).

The formal seed supply chain is characterized by (1) the development,

evaluation, registration and release of a variety, (2) seed production and processing,

(3) seed marketing and distribution and (4) seed quality tests (Bishaw and Van

Gastel 2009). On the contrary, the informal system depends mainly on the farmers’

knowledge and on the local seed management and distribution (Bocci et al. 2009)

(Fig. 2). Lipper et al. (2010) recognized the coexistence of such systems in the same

county. According to the FAO (2009), ‘‘many country reports indicated that

informal seed systems remain a key element in the maintenance of crop diversity on

farm and can account for up to 90 % of seed movement’’. The continue presence of

Table 3 Formal and informal markets and possible exchange systems (modified from: Lipper et al.

2010)

Seed system

Formal Informal

Seed Market

Formal Certified, improved and purified seed,

sold by authorized sellers

Sales of seed conserved by farmers, where the

selling of informal seed is allowed or where

the legislation is not respected and the public

authorities recognize the presence of such an

informal market.

Informal Sales of certified seed outside the

formal markets

Sales of non-certified seed that is not explicitly

recognized as a product. The distinction

between seed and grain may not be explicit.

Non-

regulated

exchanges

Theoretically, this does not take place,

since certified seed is produced only

for selling

Purchasing of seeds towards external market

sources, like the use of own conserved seed.


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these two systems suggests that all of the policies created to develop an efficient

private sector ended up creating some market failures (BEDE 2011). Furthermore, it

is possible to identify cases in which the informal system takes on a particular

importance. For instance, this happens when (1) farmers need varieties with specific

qualities such as being specifically adapted to certain local conditions, (2) formal

systems are inefficient or expensive (BEDE 2011), (3) informal production can

assure an acceptable seed quality (Louwaars 2007) or (4) access to improved seed is

difficult (Lipper et al. 2010). The recognition and promotion of informal supply

systems are nowadays considered important for a sustainable use of plant genetic

resources. The special rapporteur on the right to food of the United Nations stressed

in a report published in 2009 the importance of farmers’ seed systems and claimed

reforming seed regulations is one of the measures that states could adopt in order to

ensure that traditional knowledge is kept alive (De Schutter 2009).

Discussion

The current legislation ruling the seed markets appears to be unable to guarantee the

use of genetic resources by both the public and private sectors. Therefore, the

reestablishment of a semicommon system, defined as a mix of common and private

rights having equal significance and being able to interact (Smith 2000), is

necessary. Specifically, this interaction consists in free access to genetic information

contained in seeds, while allowing a private appropriation of benefits derived from

the use of germplasm devoted to crop improvements. This may result in opening

new possibilities for the future of seed and agriculture by simplifying access to the

germplasm for all the stakeholders, including both public and private research. This

is one of the main aims of the International Treaty on Plant Genetic Resources for

Food and Agriculture (ITPGRFA) promoted by FAO (Food and Agriculture

Organization). This treaty recognizes the value of genetic resources and creates an

international regime for germplasm transfer and development. The system

introduced is based not on a remuneration for the farmers’ genetic material

Fig. 2 Formal (above) andinformal (below) seed systemsand their relationship (modifiedfrom: (BEDE 2011)


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utilization, but rather on a conservative approach, guaranteeing the farmers rights to

preserve agro-biodiversity (Bertacchini 2007) (Fig. 3) as the fundamental basis for

the genetic resources system sustainability. In the 1992 Convention on Biological

Diversity (CBD) farmers’ rights had already been introduced in order to recognize

farmers’ role in creating and domesticating varieties, and building sources of

genetic diversity. Nevertheless, until now, there has not been any clear legal

expression of such rights (Das 2011). Therefore, the FAO ITPGRFA takes on

additional importance in protecting the farmers’ rights. This treaty should be taken

into account in the new regulation proposed by the European Council. As suggested

by ‘Rete Semi Rurali’ (2013), the new procedure should promote a sustainable use

of agricultural biodiversity and protect farmers’ rights. Additionally, it should

guarantee an eased access to genetic resources for research purposes (Articles 5, 6

and 9 of the FAO Treaty).

The expected extension of the patents system and the UPOV’s Plant Variety

Rights regime risks undermining the small local scale production systems both in

Europe and in developing countries (Das 2011). Regarding this aspect, the

‘conservation varieties’ directive (98/95/CE), approved in 1998, represents an

important step forward in the protection of small scale agriculture by establishing a

partial exception to the DUS parameters and to the formal certification tests, as well

as decreasing the certification costs. The directive was revised and reapproved in

2008, and, according to Bocci (2009) and Rete Semi Rurali (2013), can be

considered as the start of a new path to link seed production to the local level,

opening towards decentralized agricultural models. It has four main aims: (1)

conserve the plant genetic resources, (2) allow the reproduction of such varieties in

their place of diversification or origin, (3) establish a traceability system to prevent

Fig. 3 Scheme of the reopening of the semicommons system by the FAO ITPGRFA, where the exchangerelationships among the stakeholders are free (full lines) or regulated by market exchange (shaded lines)or by liability rules (dotted line). The free exchange within the states and the ‘traditional’ agriculture isalso possible (Modified from: Bertacchini 2007)


123

abuses, (4) establish exceptions on the DUS criteria. Additionally, such a directive

should also guarantee the certification of varieties produced by PPB (Participatory

Plant Breeding) methods that are not consistent with the DUS parameters, varieties

that are used as source of genetic material, and varieties that are not bound with any

specific geographical area (Bocci 2009). Regarding the VCU tests, the evaluation of

uniformity for registration should be adapted to the type of variety. Additionally, the

VCU tests should be voluntary and used as a way to inform farmers about which

kind of variety they are buying (Rete Semi Rurali 2013). Furthermore, future

legislation should take into consideration the ethical principles of so-called

biodiversity elaborated from the CGIAR principles. In particular, the following

should be taken into account: (1) strengthen the link between people and

biodiversity and ensure continuous access to biodiversity resources; (2) recognize

farmers’ rights and traditional resource rights of local communities; (3) practice fair

exchanges and safe movements of germplasm; (4) encourage active participation of

partners in research and conservation; (5) give due recognition to all the actors

(Engels et al. 2011).

The third problem is the recognition of the presence of the local and the global

markets, with their different needs and prospective. In particular, no actions have

been undertaken to allow alternative certification methods such as the Participatory

Guarantee Systems (PGS). Such a certification, defined by IFOAM as a system

focused on assuring quality by certifying the producers towards a methods based on

the stakeholders active participation, would be able to support the local sector

(IFOAM 2008). Furthermore, it is built on reliance, on the social network, and on

knowledge sharing. This system could be applicable to Salvatore Basile’s idea of

bio-districts or, more in general, to agricultural districts. Bio-districts are geographic

areas where farmers, citizens, the tourism industry, associations and public

administrations sign an agreement for a sustainable resources management. These

agreements should start from the organic agricultural model and a short food chain

(Basile 2011). In this way, it could be possible to control the informal seed market.

This is particularly important for the spread of local adapted varieties in case of: (1)

an expensive formal system, (2) high quality informal seed production (Lounwaars

2007) or (3) difficult access to formal markets (Lipper et al. 2010). The use of such

models in addition to participatory breeding methods (PPB—participatory plant

breeding, PVS—participative variety selection) and the use of cross composite

populations (CCP) developed by Salvatore Ceccarelli, could allow developing local

seed enterprises to fulfill the needs of the local system. Such systems are not suitable

for the global market. PPB is in reality a very flexible tool because it refers to a set

of methodologies characterized by different interaction levels between farmers and

researchers. It shifts between the complete participative methods (PPB) and the

participatory varietal selection (PVS), where farmers interact only in the final

evaluation stage (Morris and Bellon 2004). A good model for global seed

production could be efficient participatory breeding, where farmers and researchers

collaborate with germplasm source selection and in the final evaluation (Morris and

Bellon 2004).

Regarding the previously mentioned certification problems, DUS and VCU

parameter should be modified for local agricultural seed production to allow the


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continuation of research in low input environments and consider important

parameters. For instance, in the organic revision report (Micheloni et al. 2007),

specific parameters for organic agriculture had been identified, and some countries

(Holland, Austria, Denmark, Switzerland, and Latvia) had already introduced

specific VCU tests at experimental level (Belicja and Bleidere 2005). Similar advice

is offered in the final policy recommendations document edited at the end of the

SOLIBAM (Strategies for Organic and Low-input integrated Breeding and

Management), a European collaborative project run from 2010 to 2014. As

reported by SOLIBAM, the VCU parameters are nowadays an obstacle for

alternative agriculture. Therefore, the VCU tests should be an optional choice for

companies and, as suggested before, organic VCU test should be in place

(SOLIBAM 2014). Additionally, all the previously mentioned issues were not

recognized by the last European seed legislation proposed by the European

Commission. This proposal was rejected on March the 11th, 2014 by the European

Parliament, pursuant to strong opposition from the public, as the Agriculture

Committee chair Paolo De Castro confirmed by declaring that ‘‘it is clear that the

draft new rules must be redesigned to better respect different situations in different

member states and bring about real improvements for all producers, consumers and

the environment’’ (Euro-parliament website). With the new legislation period, the

EU seed regulation will be renegotiated. Therefore, it is essential that the issues

discussed above be taken into account. Possibly, a new path was set up in the last

meeting with the new agricultural commissioner on January the 30th 2015. Two

scenarios are possible: the reform of the seed legislation will be abandoned or, a

completely new proposal will be prepared, based on a new investigative study on

the sector.

Conclusion

It is still difficult to assess the full implications of declaring genetic resources as not

a global public good, due to the little time that has passed. Nevertheless, according

to the outlined problems, genetic resource use has to be reviewed by starting an

innovation process and reinstituting a semi-commons system. Additionally,

governments and decision-making bodies should consider all the ethical issues

related to the collection and use of agro-biodiversity, and should make them an

integral component of new legislative decisions (Engels 2011).

In Europe, the legislation for the conservation varieties may be a starting point.

New DUS and VCU tests have to be established for sustainable agriculture, for both

the local and industrial farming systems. In this process, all the different

stakeholders, researchers, breeders, retailers and farmers, have to be legally

recognized. Furthermore, future specific research projects based on holistic and

systemic research models have to be developed. All those stakeholders have to be

included in innovation research platforms. The research, collection, and use of

biodiversity and seed should be legislated by addressing ethical considerations, even

if this complicates the legal access to genetic resources. Governments and

legislators should be likely to consider whether certain ethical principles should


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represent a precondition of agreements regarding access to and exchange of

germplasm, although bureaucracy should be kept at a minimum to promote

efficiency.

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