- welcomes the legislative proposal put forward by the European Commission for the production and marketing of plant reproductive material (PRM) and forest reproductive material (FRM). The EESC supports the simplification of the registration rules which will allow for improved diversity of reproductive materials as well as the inclusion of sustainability requirements, in line with the objectives of the European Green Deal. However, the EESC would like to draw attention to a few points that require further consideration;
- emphasises the importance of implementing an effective follow-up and evaluation mechanism to monitor the reduction of administrative burden and red tape for operators in the plant and forest reproductive material sector. This mechanism should be transparent, enabling the identification of persistent obstacles and the implementation of necessary corrective actions;
- calls for explicit implementation of the rights of rural workers and farmers, as laid down in the International Treaty on Plant Genetic Resources for Food and Agriculture (ITPGRFA) and the United Nations Declaration on the Rights of Peasants and Other Rural Workers (UNDROP). These rights include the right to participate in decision-making processes, access and use of plant genetic resources, protection of traditional knowledge, fair and equitable sharing of benefits, access to land and natural resources, and the right to practice traditional agricultural techniques;
- raises concerns about the planned use of numerous delegated acts in the legislative proposal. While acknowledging the necessity of such acts to define practical details, the EESC emphasises the need for clear limitations to prevent them from expanding the scope of the basic regulation or causing uncertainty about its fundamental provisions. Adequate consultation with the Council of Ministers, the European Parliament, the EESC and the concerned stakeholders should be ensured to enhance transparency and democratic scrutiny, taking into account previous criticisms made during the 2013 PRM proposal.