Navigating seed license renewals in the US

March 6, 2024

Seed licenses are mandatory for any business selling seeds in the US. Issued and regulated at a state level, the objective is to ensure seeds are properly labeled and satisfy quality standards. Managing these requirements is hard because each state has its own requirements surrounding data and labeling. While a general license may encompass all seeds in some states, others require individual seed products to be registered as well or instead. There are also discrepancies in matters such as the expiration cycles of registration or licensing, and the frequency and format of tonnage reporting. This is further complicated by the fact that states frequently, and sometimes quietly, change their requirements. Achieving 100% compliance nationwide can feel like an impossible task.

Regulatory experts at TSG Consulting say there are five key points to consider when developing a seed renewal strategy.

1. License duration varies among states

A seed license is usually valid for three years, but most states require annual renewal. With this in mind, careful management, planning, and preparation is necessary to ensure the renewal process is
handled efficiently.

2. Labeling requirements are state mandated

In general, seeds sold in the US must be clearly labeled with specific information surrounding their type, quality, and origin. Labeling is mandated at a state level and it’s not uncommon for requirements to evolve, so they should be checked prior to renewal on a state-by-state basis. Much on-label information is based on seed tests related to purity, germination, and the presence of noxious weeds. Such tests take time to complete, so a proactive approach is essential.

3. Many states have additional obligations

Requirements outside of general labeling also vary among states. For instance, in Vermont, seeds that have been genetically engineered must be reported to the Vermont Agency of Agriculture on an
annual basis. In many states, treatments used on coated seeds require data analysis, especially where the coatings deliver active compounds such as growth regulators or microbial inoculants. Additional obligations enforced by most states include reporting on seeds’ gross sales figures as this may impact the cost of the license.

4. Renewal processes are dynamic and inconsistent

There are also different processes and platforms for submitting renewal documentation. While many states use the Kelly Registration Systems (KRS) platform and/or the USA Plants portal, most still require paper submissions. Washington uses its own portal, known as Plant Inspection Services and Certification / Electronic System (PISCES). This is further complicated by the fact that states regularly update their renewal, reporting, and tracking tools with new features.

5. Penalties and enforcements are inconsistent

If a seed license for a given product lapses and it remains on sale, the consequences can range from a reminder or warning to a fine or even a stop sale notice. For companies with a large seed portfolio, the potential liability is high, bringing financial and reputational risk. Ensuring renewals are handled in a timely and effective manner is essential.

State-level renewals are hard to manage effectively. Monitoring deadlines and keeping track of evolving requirements is time consuming, and many processes are labor intensive. Even a seemingly simple task like handling fee payments involves multiple steps which can take an hour or more per transaction.

Here at TSG Consulting, we can manage the entire process, or specific aspects of it, to achieve seamless seed license renewals. Our regulatory experts have the insights and expertise to make the process more efficient and cost-effective. And our custom built database streamlines the monitoring and management of renewal deadlines and requirements in all 50 states.

If you’re looking to enhance your seed license renewal process, contact us at info@tsgconsulting.com

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