This submission was made by civil society groups at a COMESA meeting in Lusaka during March 2013, in which serious concerns were raised about the COMESA seed trade laws as negatively impacting on small farmers in the COMESA region.
Statement made by:
Zambia Climate Change Network (ZCCN); East and Southern Africa Small Scale Farmers Forum (ESAFF) ? Zambia; Participatory Ecological Land-Use (PELUM) Association; Alliance for Agro-Ecology and Biological Diversity Conservation; Kasisi Agriculture Training Centre (KATC); Community Technology Development Trust (CTDT); Green Living Movement (GLM); African Centre for Biosafety (ACB)
The Regulations allow for the expedited registration of seeds to enable the creation of a seed free trade zone within the COMESA region. ?Seed trade? is not defined in the regulations as being restricted to only the commercial seed sector. In this regard, there are serious concerns that the Regulations do not provide any safeguards that small farmers will be allowed to freely use, save, sell, barter and exchange traditional varieties of seed.? Lack of these safeguards will open the door for the criminalising of the customary practises of small farmers to exchange, sell and