Between Innovation, Conflicts and North-South Balances
The intellectual protection of living organisms, particularly plant varieties, raises fundamental scientific, legal and ethical questions. How can one claim ownership of a seed, the basis of all life and all food? This question, ancient but more current than ever, sometimes opposes commercial innovation and the preservation of biological commons. It also engages a global debate between Northern countries, often innovators, and those of the South, guardians of immense biodiversity. This article explores the history, mechanisms and geopolitical issues of this protection, drawing on concrete examples from seed sectors.
As early as Antiquity, the idea of protecting an innovation emerged. In Sybaris, a Greek colony of the 6th century BC, a temporary privilege was already granted to cooks creating new recipes 4 . This concept evolved to apply much later to plant creations.
The Plant Patent Act (PPA) of 1930 in the United States was the first law to grant patents on living organisms (asexually reproducing plants). In Europe, several countries such as the Netherlands (1942), France (1949) and Germany (1953) followed by adopting sui generis systems ("of their kind") to protect new plant varieties 3 .
Under the impetus of Europe, the International Convention for the Protection of New Varieties of Plants (UPOV) was adopted in 1961. This sui generis system, designed for and by commercial breeders, grants a Plant Breeder's Certificate (PBC). It offers a temporary monopoly to the breeder while allowing the use of the variety for research or selection of new varieties 3 .
Early documentation of plant patent applications in the United States
The creation and distribution of a variety mobilizes a chain of specialized actors, particularly visible in France, a world seed power 1 2 .
| Chain Link | Number of Actors | Main Role |
|---|---|---|
| Varietal Creation Companies | 67 | Creation of new varieties (450+/year) and production of basic seeds. SMEs/SMBs. |
| Farmer-Multipliers | 16,636 | Seed production in open field under contract, on nearly 370,000 ha. |
| Production Companies | 255 | Cleaning, treatment, packaging and marketing of seeds. |
| Distributors | 5,097 | Sales and advice to farmers, professionals and amateur gardeners. |
| Users (Farmers) | 390,000 | Agricultural production for food and industry. |
| Amateur Gardeners | 17 million | Use of seeds for the pleasure of gardening. |
Small and medium enterprises driving innovation with over 450 new varieties created annually in France alone.
Thousands of farmers dedicated to seed production under contract across nearly 370,000 hectares.
Northern countries, often innovators, have developed sophisticated intellectual property systems to protect their investments in plant breeding and biotechnology.
Southern countries, often newly independent in the 1970s, denounced the asymmetries of protection systems 3 . They pointed to the marginalization of small-scale farmers and the free flow of genetic resources from South to North.
In response, they pushed for alternative models to recognize and reward farmers' contributions to the conservation and development of varieties.
"The conservation of genetic resources is an essential link in response to biodiversity loss. Conservation centers (public like CIRAD, IRD, INRAE, or associative) have the mission to find, conserve and perpetuate ancient varieties or those with heritage value." 2
A CIRAD study on the tropical vegetable seed sector perfectly illustrates the North-South dynamics .
The study was based on:
Tropical vegetable production faces unique challenges in seed availability
The study revealed that:
| Strategy | Example Species | Main Objective | Dominant Actor |
|---|---|---|---|
| Resistance Research | Tomato (resistance genes) | Fight against diseases and pests | Initial public research |
| Development of F1 Hybrids | Cabbage, onion, melon | Vigor, uniformity, protection of innovation | Multinationals |
| Use of Wild Species | Tomato | Introduction of resistance or quality traits | Public research |
| Improvement of Organoleptic Qualities | All species | Adaptation to consumer preferences | Public and private sector |
"The study concludes that the development of varieties adapted to tropical areas relies on strengthening partnerships, developing Southern expertise, and better alignment with local demand."
Modern varietal creation relies on a set of technical tools and reagents.
Source of genetic diversity (old varieties, related wild species)
ApplicationIntroduction of resistance genes in tomato
Identification and rapid selection of genes of interest without long phenotyping
ApplicationMarker-assisted selection (MAS)
Precise and targeted modification of DNA sequences
ApplicationDeactivation of disease susceptibility genes
Long-term conservation of genetic diversity (seeds, plant material)
ApplicationMaintenance of heritage variety collections 2
Precise and high-throughput characterization of agronomic traits
ApplicationEvaluation of promising new varieties
The future of plant variety protection is at a crossroads. New technologies like high-throughput sequencing and genome editing (CRISPR-Cas9) blur the boundaries between discovery and invention, and pose unprecedented legal questions 3 .
Are current systems like PVP or patent adapted to protect a simple precise modification of a gene without introduction of foreign DNA?
The race for genes of interest could increase pressure on genetic resources from Southern countries.
The challenge of feeding a growing population in a context of climate change will require mobilizing all available genetic diversity.
"The final challenge goes beyond mere intellectual property: it is about ensuring food security, biodiversity and social justice on a global scale."