As governments prepare for GB11 of the International Treaty on Plant Genetic Resources for Food and Agriculture (ITPGRFA), Euroseeds is calling for a more inclusive, flexible, and practical Multilateral System (MLS). The organization proposes multiple payment options, clearer alignment with the Convention on Biological Diversity (CBD), and an expanded Annex I to cover all PGRFA. These reforms aim to reduce administrative burdens, improve legal clarity on Digital Sequence Information (DSI), and increase participation across diverse seed companies. A modernized MLS, Euroseeds argues, will strengthen innovation, benefit-sharing, and global food security for farmers and breeders worldwide.
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Towards a more inclusive and effective treaty.
For more than two decades, the International Treaty on Plant Genetic Resources for Food and Agriculture (ITPGRFA) has provided a global framework to support the exchange of plant genetic resources for food and agriculture (PGRFA) and ensure that benefits derived from their use are shared fairly. At the heart of the Treaty is the Multilateral System (MLS), which gives breeders, researchers and other users access to PGRFA under agreed conditions.
While the Treaty has achieved a great deal, the landscape of plant breeding, data use and global food security has changed significantly. Digital sequence information (DSI), rapid advances in breeding technologies and increasingly diverse company profiles have made it clear that the MLS needs to evolve if it wants to remain relevant and effective.
“The seed sector has supported the Treaty since its inception. But if we want to truly maximize the use of the MLS and the benefits it can bring, the system must be made more inclusive and workable for the wide range of users who rely on it,” says Ludovic Pâris, regulatory affairs officer at LIMAGRAIN, who serves as chair of Euroseeds Committee on Plant Genetic Resources and as vice-chair of ISF Coordination Group on Genetic Resources.
Euroseeds has set out a series of recommendations to make that evolution possible. These proposals centre on three key elements: offering multiple payment options to make the MLS accessible for different types of companies, ensuring coherence with the Convention on Biological Diversity (CBD) on DSI, and expanding the scope of Annex I to cover all PGRFA.
A More Inclusive Payment System
The current payment structure of the MLS, although inexpensive, is relatively rigid. Companies accessing material from the system face a benefit sharing model that generates a huge administrative cost for traceability and doesn’t fully match the different ways in which seed companies operate. For some, especially those working intensively with crops like vegetables, a possibility of subscription would make sense. For others, particularly those focusing on crops like maize or soy, the current system of single access remains adapted but the never-ending obligation to trace the use made of the initial genetic resource, including when its share in the heritage of the varieties obtained is infinitesimal, can feel disproportionate.
To address this, Euroseeds proposes a more flexible payment architecture. This would include three options:
- Full subscription covering all crops and PGRFA,
- Subscription per crop for companies with mixed portfolios,
- Single access for occasional users or for targeted research projects.
This flexibility would make it easier for a wider range of companies to participate. It would also allow for a more predictable and sustainable flow of benefit-sharing funds, which is critical to the Treaty’s success.
Federico Vittorio Pisani, manager development cooperation and genetic resources at Euroseeds explains it clearly: “Not every company uses the MLS in the same way. We have highly specialized companies, diversified ones, and those with limited needs for additional genetic material. By giving them the flexibility to choose how they contribute, we can bring everyone into the system, instead of excluding those for whom the current model simply doesn’t work.”
Under this model, companies with high breeding activity across many crops (Type 1) might opt for a full subscription. Those with limited interest in MLS material (Type 2) might prefer single access. Companies with mixed portfolios (Type 3) could combine subscription per crop with single access. This way, the payment base broadens without penalizing any particular business model.
This inclusive approach would not only increase participation but also the overall volume of benefit-sharing contributions. Instead of raising rates for a few, the goal is to make it easier for many to engage.
Recognizing DSI as Part of the System
The debate around Digital Sequence Information (DSI) has been one of the most contentious in international biodiversity negotiations. DSI refers to genetic sequence data derived from physical genetic material. Because it can be accessed and used globally without physically transferring seeds or plant material, it challenges existing access and benefit-sharing frameworks.
Euroseeds takes a clear position: DSI should be considered part of the PGRFA. When a company accesses material through the MLS, the benefit-sharing obligation should also cover the DSI derived from that material. This avoids creating parallel and potentially conflicting systems.
“The full subscription option can be a powerful tool here. By covering both PGRFA and DSI, we create a simple, predictable mechanism that benefits everyone,” Pâris notes.
This approach also calls for coordination between the Treaty and the CBD. Euroseeds supports the idea of an agreement between the Treaty’s Governing Body and the CBD’s Conference of the Parties (COP). Under such an agreement, seed companies that subscribe fully to the MLS would be exempted from additional DSI-related contributions to the CBD’s multilateral mechanism (Cali Fund) on seed turnover.
This kind of alignment would give companies the legal clarity they need and avoid overlapping obligations that could discourage participation. “It’s about making one system work well, rather than layering multiple ones on top of each other,” adds Andrea Mertens, lead of expert hub legal at KWS and vice-chair of the Euroseeds Committee on Plant Genetic Resources.
Expanding Annex I to Reflect Reality
When the Treaty was adopted in 2001, its Annex I listed a specific set of crops and forages that were covered by the MLS. But in practice, breeders also work with many other crops outside Annex I. This limits the potential value of the system, both for users and for benefit-sharing.
Euroseeds is therefore calling for an expansion of Annex I to include all PGRFA, paired with a negative list approach. This means that countries could choose to exclude specific sensitive crops if they wish, but the default would be broad coverage.
“If we really want the MLS to support global food security, we need to give breeders access to the full diversity of genetic resources. Expanding Annex I is a critical step,” says Pâris.
This would increase the added value of the MLS for companies and public sector breeders alike. It would also generate more benefit-sharing resources for conservation and sustainable use. Last but not least, Mertens observes that “this is the best way to address the criticism that the seed sector does not sufficiently foster crop diversification.”
Euroseeds also calls for restraint in how countries use the negative list. Overuse of exemptions would risk undermining the goal of wider access. In cases where not enough countries ratify the expanded scope within the transition period, Pisani suggests a careful, evidence-based review before any decisions are made. “If uptake is low, let’s first understand why. We shouldn’t rush into rolling back an important step forward.”
The Importance of Consistency and Fairness
One of the technical but important points in Euroseeds’ proposal concerns differentiated payment rates. Today, companies only pay monetary benefit-sharing when the products they commercialize are not available for further breeding and research. Products that remain accessible to other breeders already provide non-monetary benefits.
In the current co-chairs’ proposal for subscription, however, differentiation would not be applied product by product. Instead, if just one product is restricted, the higher payment rate would apply to the entire portfolio. Euroseeds sees this as a major disincentive to subscription.
“It’s a question of fairness. If companies provide non-monetary benefits for most of their products, they shouldn’t be penalized for having one that’s restricted in another market,” Pâris argues.
Euroseeds proposes to apply the same differentiation logic to subscriptions as to single access, based on actual product availability. This consistency would encourage more companies to subscribe rather than opt out.
Making Traceability Workable
Traceability is another critical aspect of the MLS. Under the current system, tracking the origin of genetic material through multiple breeding cycles can be extremely burdensome. Euroseeds supports simplifying these obligations through a dilution threshold: beyond a certain point, the original material no longer needs to be traced, unless a specific trait of commercial value is involved.
This would significantly reduce administrative hurdles and encourage more companies to use the MLS. Similarly, Euroseeds recommends against introducing any new obligation to declare MLS material in varietal protection filings, beyond what is already required under patent rules.
“Breeding is a long and complex process. We need practical traceability rules that don’t discourage innovation,” says Mertens.
A Broader Base, Not Higher Rates
Euroseeds is clear that rates and thresholds must be realistic. Setting benefit-sharing rates too high would only push companies away from using the system. A better approach is to broaden the base of contributors by making the system attractive to more users.
Small companies should also be considered. Here, the key challenge is often administrative rather than financial. Adopting thresholds aligned with EU definitions of small enterprises (10 to 50 employees) could help lower these barriers.
The proposal also clarifies how affiliates can be included within a subscription agreement, ensuring consistent application of benefit-sharing while allowing flexibility for companies that operate internationally.
A Stronger, More Effective MLS
The changes proposed by Euroseeds are designed to make the MLS more inclusive, coherent and practical. By offering flexible payment options, aligning DSI treatment with CBD mechanisms, expanding Annex I, ensuring fair differentiation and simplifying traceability, the system could reach many more users.
This isn’t just about improving administration. It’s about unlocking the full potential of the Treaty to support plant breeding and food security. The more accessible the system is, the more companies will use it, and the more benefits can be shared globally.
“We believe in this system,” says Pisani. “If it’s modernized in a smart and inclusive way, it can work for companies of all sizes, support public breeding efforts, and strengthen global food security. That’s a win for everyone.”
For more information, you can read the original Euroseeds position papers on the enhancement of the MLS, DSI, and the expansion of Annex I:
https://euroseeds.eu/app/uploads/2025/07/25.0287.1-Euroseeds-position_DSI.pdf
https://euroseeds.eu/app/uploads/2025/07/25.0286.2-Euroseeds-position_Annex-I.pdf
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