The Alliance for Food Sovereignty in Africa strongly condemns the
approval during September 2013, by the Council of Ministers of the Common
Market for East and Southern Africa (COMESA) of the draft COMESA Seed
Trade Harmonization Regulations, 2013 (hereinafter referred to as the ?Seed
Regulations?).
The COMESA seed regulations are binding on all COMESA Member
States in terms of article 9 of the COMESA Treaty. Yet, there is no evidence
to demonstrate the involvement of and consultation with the citizens in
COMESA countries, particularly small – scale farmers, despite numerous
pleas to COMESA to consult with small farmers. It is our view that a technical
group from COMESA countries in collaboration with the African Seed Trade
Association (AFSTA) and Commodity Trade in Eastern and Southern Africa
(ACTESA) and well funded by USAID and the EU, deliberated on the issues
and drafted regulations that have now been signed off by the Council of
Ministers, ready for domestication in the COMESA Member States.
Submissions made by CSOs and small-scale farmer representatives, to a
COMESA workshop organized by the ACTESA during 27 and 28 March 2013
in Lusaka, Zambia containing concerns both about the flawed nature of the
process and the implications of the regulations for small farmers and
agricultural biodiversity in Africa, have pointedly been ignored.
Overview of the COMESA Seed Regulations
The ostensible rationale for the seed regulations is to increase the diversity,
quality and quantity of seed available for farmers in the region and reduce the
transaction costs for the seed industry which they currently face, brought
about by differing regulatory and trade arrangements across countries in the
region. These differing regulatory arrangements are regarded as non-tariff
barriers. The envisaged scenario is the free flow- regionally seamless trade of
seed across national boundaries in the COMESA region, which in turn will
attract improved private investment through the expanded markets.
The seed regulations provide for standardized and uniform variety testing
procedures for release of seed on a regional variety list as well as increased
private sector participation in the seed release process itself.
