United States Agricultural Livestock, Seed Regulatory and Testing Division 

Department of Marketing Poultry, and 801 Summit Crossing Place, Suite C 

Agriculture Service Seed Program Gastonia, NC 28054-2193 

 704-810-8871, FAX 704-852-4189 

 www.ams.usda.gov/rules-regulations/fsa

 

September	2017	–	Seed	Company	Records	and	the	Federal	Seed	Act	 Page	1	

SEED COMPANY RECORDS AND THE FEDERAL SEED ACT 

I. INTRODUCTION 

Maintaining proper records as required under the Federal Seed Act (FSA) is a problem for 

some seed companies. The failure to keep proper records is contrary to good business 

practices. Records necessary for normal good business management will ordinarily meet the 

requirements of the FSA and FSA Regulations. Under the FSA and FSA Regulations, 

interstate shippers are required to keep, and make accessible for inspection, a complete record 

of each lot of seed shipped in interstate commerce. Such information includes keeping a file 

sample and records of receiving, variety, conditioning/blending, tests, labeling, and sales and 

shipping/disposition. The term "complete record" is defined in the FSA Regulations Section 

201.2(l). The FSA Section 202 and the FSA Regulations Sections 201.4(a), 201.5, 201.6, 

201.7, and 201.7a describes the record keeping requirements. 

A complete record of each lot is required to be kept for three years, except that the file sample 

may be discarded one year after disposal of the entire lot of seed. The records should be kept 

in a manner to permit comparison with the records kept by others for the same seed lot. This 

is so the seed may be traced from the place where it is officially sampled back to the grower, 

if necessary. 

The person procuring the seed from the grower should keep grower’s declarations of kind, 

variety, or type. Subsequent handlers should keep shipper’s declarations, invoices, or other 

labeling establishing the kind, variety, or type labeled. 

The complete record for any lot consisting of or containing treated seed shall include records 

necessary to disclose the name of any substance or substances used in the treatment of the 

seed. This may include a label, invoice, or other document received from any person 

establishing the name of any substance or substances used in the treatment, and a 

representative sample of the treated seed. 

The following information provides guidance about the records required for seed subject to 

the FSA. It is designed for simplicity, yet relates a continuous history of the seed. No record 

is of value unless it is kept up to date and filed where it is readily available. The complete 

records may be kept together in one file folder for each lot or they may be kept separately. 

II. LOT NUMBERS 

Lot numbers are the principal means of identifying seed and should be shown on all records. 

The lot number shown in the labeling is required to be the same as that used in the records 

pertaining to the seed. When a change is made to the seed in a lot, such as adding a seed 

treatment, the change should be reflected in the lot number. Choose a simple set of numbers. 

Do not repeat the series of lot designations more often than every three years. 
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III. RECEIVING RECORDS 

Information from receiving records may be recorded electronically or printed in a ledger or 

notebook. Dealers purchasing seed primarily from growers may prefer a simple style. An 

invoice may also serve as a receiving record. 

Record the lot number each time a purchase of seed is made. If the seed is assigned a new lot 

number, this information should be entered as indicated below. Invoices, scale tickets, labels or 

tests, and grower’s declarations supplement this record. 

RECEIVING RECORD (Ledger/Notebook Style Example): 

Date Incoming Lot # & Remarks Our Lot # Amount Received From Supplier Kind & Variety 

10-1-08 bulk load 1 

lot 1 3231 18,460 lbs. Farmer Brown 

Brookhaven, NY 

‘Minhafer’ 

oat 

10-2-08 30 bags uncleaned 

Lot RC-2 3232 1,610 lbs. John Doe 

Farmdale, NJ 

VNS 

red clover 

10-2-08 lot B1014 3233 25 50-lb. J’s Seed Co. 

St. Louis, MO Ky. bluegrass 

10-6-08 lot 6K16R 3234 50 50-lb. Country Jones, Inc. 

Portland, OR Per. ryegrass 

10-8-08 Lot 881462 

Blend of lots 988, 992, 1004 3235 60 50-lb. Boomer Falls Seeds 

Jefferson, OR 

‘Kentucky 31’ 

tall fescue 

12-8-08 

Lot 881462-T 

Blend of lots 988, 992, 1004 

Treated remains of lot 992 

3235-T 40 50-lb. Boomer Falls Seeds 

Jefferson, OR 

‘Kentucky 31’ 

tall fescue 

Receiving records showing more information may be recorded on individual documents and kept 

in numerical order by lot numbers: 

RECEIVING RECORD (Individual Document Style Example): 

Our lot No.: _____________________________ Date received: __________________ 

Kind & Variety: _________________________________________________________ 

Amount received: ________________________________________________________ 

Received from: __________________________________________________________ 

Address: _______________________________________________________________ 

City, State, Zip: __________________________________________________________ 

Supplier’s lot No.: _______________________ Brand: _________________________ 

Supplier’s invoice No. and date: _____________________________________________ 

Transportation record or bill of lading No.: ___________________________________ 

Name and address of carrier: ________________________________________________ 

________________________________________________________________________ 

Remarks: _______________________________________________________________
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IV. VARIETY AND ORIGIN/GROWER'S DECLARATION 

Origin: A grower's declaration of origin or information traceable to the origin or evidence 

showing that a declaration of origin could not be obtained is required for alfalfa, red clover, 

white clover, and non-hybrid field corn. 

 

Kind, Variety, or Type: The person procuring the seed from a grower should obtain a 

declaration of kind. If the seed is to be labeled with the name of a variety or type, obtain a 

declaration of variety or type. The grower should keep a copy of the declaration and a sample 

of the seed. Variety records of vegetable seeds are necessary, as all vegetable seed must be 

labeled to show the variety name. 

 

If agricultural seed is not required to be labeled as to origin or is not labeled with the name of a 

variety, you do not need declarations or other documents establishing origin or variety. 

 

The following grower’s declaration is an example. Similar grower’s declarations may be 

available from other sources. A declaration can also be a written statement from a grower if it 

includes the required information such as an invoice or other document establishing the variety 

name or other documents establishing the variety as labeled. 

GROWER'S DECLARATION OF ORIGIN, KIND, VARIETY, OR TYPE (Example): 

 

Kind of seed: ________________________ VARIETY*: ________________ TYPE*: ____________ 

Grower's lot number or mark, if any: ______________________ Bags: _______ Pounds: __________ 

ORIGIN/where grown: County __________________________ State __________________________ 

Seed sold to: ________________________________ Address: _______________________________ 

City and State: ______________________________________________________________________ 

Delivered to: _______________________________ Address: ________________________________ 

City and State: ______________________________________________________________________ 

Date shipped or delivered by grower: __________________________________________, 20_______ 

*The grower should have adequate information to support their naming of the variety or type. Not having such 

information, the variety or type should not be stated. 

 

Signature of grower: _________________________________________________________________ 

Grower Name: _____________________________________________________________________ 

Address: ________________________________________ City and State: ____________________ 

Note: The grower should retain a copy of this declaration. 

 

(To be filled in by purchaser) 

Purchaser's receiving lot No.: 

____________________________________________________________ 
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V. CONDITIONING/BLENDING RECORDS 

 

Conditioning/blending records consist of cleaning, scarifying, treating, inoculating, or 

blending prior to testing the seed for labeling. Records of blending, cleaning, and treating 

may be combined. If you did not condition the seed, you do not need a conditioning record. 

CONDITIONING/BLENDING RECORD (Example): 

 

New lot No.: 21 Instructions: 

Kind: Red clover Clean: [X] clipper, gravity & dodder 

Variety: Unknown Blend: [X] ____________________ 

Origin: IL Rebag: [X] plain white 60 lbs. 

Date conditioned: 12-10-08 Treat: [X] Thiram 1 oz. per. bu. 

 

Seed cleaned or blended: 

Kind and Variety Origin Lot No. No. bags Weight 

Red clover IL 3 7 710 

 " " IL 11 4 450 

 " " IL 17 10 1120 

 " " IL 18 10 980 

 3260 

 

After conditioning: 

New lot No. No. bags Weight Disposition 

Show lot into which bulked or to whom shipped. Date 

21 43+10 lbs. 2590 to stock record lot 21 12-10-08 

21#1 SCR 2 215 to lot 37 12-28-08 

21#2 SCR 1 1⁄2 132 to lot 37 12-28-08 

21#3 SCR 1 114 to lot 37 12-28-08 

no value 2 167 to feed bin 12-28-08 

mill loss 42 

total 3260 

 

VI. TEST RECORDS 

Some firms send samples to a commercial or State laboratory for testing. The reports received 

are the seed company’s test records. A seed company employing its own seed analyst usually 

relies upon the analyst to maintain a record of each test made. Test records can be maintained 

in a variety of ways, provided they are accessible for examination. 

 

All tests for labeling purposes should be made in accordance with the procedures set forth in the 

FSA Regulations or similar testing procedures in the Association of Official Seed Analysts Rules 
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for Testing Seeds. Be sure that the sample is drawn in such a manner that it represents the 

entire lot of seed. Also, be sure that tests are made to determine the name and rate of 

occurrence of noxious-weed seeds for each State into which the seed may be shipped. Include 

tests for Federal noxious-weed seeds, which are prohibited in agricultural and vegetable seeds, 

shipped in interstate commerce. Purity records for vegetable seed need not be kept as that 

information is not required to be shown on the label. 

 

Note: Non-uniformity in seed lots is believed to be the biggest single cause of mislabeling. If a 

lot is non-uniform, mislabeling is likely since, under the FSA, every bag of seed in the lot is 

required to be accurately labeled. Quality control procedures designed to detect and remedy 

non-uniformity are strongly encouraged. An example of such a quality control procedure would 

be to test samples from different portions of the lot. If these tests indicate non-uniformity, clean, 

blend and/or subdivide a large lot into several smaller lots, or otherwise condition the seed to 

eliminate the nonuniformity. After the non-uniformity has been eliminated, test a sample 

representing the entire lot for labeling purposes. 

 

VII. SALES AND SHIPPING/DISPOSITION RECORDS 

 

Invoices and bills of lading documenting the lot number, kind or kind and variety, date and 

amount shipped, and to whom the shipper sold the seed should be retained. These records 

serve to document sales and shipping of seed. 

 

A record of disposition of each lot of seed may be kept as a separate record or combined with 

other records. Such a record should identify the seed by lot number, kind or kind and variety, 

and should show the original amount of the lot. Space should be provided to enter the invoice 

date, amount, invoice number, and date shipped of each sale of the lot. 

 

The disposition record may also serve as an inventory record. Disposition records of retail 

sales are not usually kept. Firms doing both retail and wholesale business may choose to 

assign certain lots for retail purposes. 

DISPOSITION RECORD OR STOCK RECORD (Example): 

 

Lot No.: 21 Kind: red clover Variety: Unknown 

 

Original amount 43 bu. + 10# 2,590# 43 + 10# 

Invoice 

No. 

Invoice 

Date 

Date 

Shipped Bags Weight Balance Sold/Transferred to 

101 12/17/08 12/22/08 10 600# 33 + 10# XYZ Seed Co. 

114 12/19/08 12/22/08 20 1200# 13 + 10# Kassie Gardens 

126 12/22/08 12/22/08 10 600# 3 + 10# Lucky Seed Co. 

---- ---- 12/23/08 3 + 10# 190# -0- into lot No. 36 

 

IIX. LABELING RECORDS 
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The actual label, copy of the label, actual container (seed packet or lawn seed container), or 

copy of the container showing the labeling of the seed serves as a labeling record. Sections 

201.8 – 201.31 of the FSA Regulations describes the label contents. 

 

Agricultural seed labels are required to show the kind name, variety name or the words 

“Variety Not Stated” (Section 201.10 of the FSA Regulations), pure seed, other crop seed, 

weed seed, and inert matter percentages, noxious-weed seed name and rate of occurrence, 

origin (for alfalfa, red clover, white clover, and non-hybrid field corn), germination percentage 

and date of test, lot number, and interstate shipper’s name and address or code designation i.e., 

AMS number (explained further on the Seed Regulatory and Testing Division (SRTD) Web 

site under “AMS Code Designation”). 

 

Vegetable seed labels for one pound or less for seed meeting standard germination are required 

to show the kind name, variety name, and interstate shipper’s name and address or code 

designation i.e., AMS number (explained further on the SRTD Web site under “AMS Code 

Designation”). 

 

Vegetable seed labels for one pound or less for seed below standard germination are required to 

show the kind name, variety name, interstate shipper’s name and address or code designation 

i.e., AMS number (explained further on the SRTD Web site under “AMS Code Designation”), 

germination percentage and date of test, and the words, “Below Standard.” 

 

Vegetable seed labels for more than one pound are required to show the kind name, variety 

name, interstate shipper’s name and address or code designation i.e., AMS number (explained 

further on the SRTD Web site under “AMS Code Designation”), germination percentage and 

date of test, and the lot number. 

 

IX. FILE SAMPLES 

A file sample representing each lot of seed is considered a part of the purity and germination 

record. The containers should be marked, or other records kept, showing when, where, and 

how the sample was obtained and the amount and identification of the lot of seed it represents. 

Plastic bags may be used to prevent infestation by insects or to isolate infested samples. A file 

sample of agricultural seed should be at least the minimum size for a noxious-weed seed 

examination as set forth in the FSA Regulations Section 201.52 (and shown in Table 1 of 

Section 201.46) and a file sample of vegetable seed should consist of at least 400 seeds. A 

sample kept by a seed laboratory may be considered as a seed company's file sample provided 

the sample is available for inspection upon request. A seed company who arranges for a seed 

laboratory to keep their file samples should always submit a sample at least twice the size 

required for the tests requested so that ample seed will remain on file after the test. 

 

X. RECORD CHECK LIST 

 

If your records show the following information, you can rest assured that your records comply 

with the FSA and FSA Regulations and they will supply you with sufficient information to 

trace the history of any seed lot handled. 
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1. Receiving Records 

 Lot number assigned 

 Purchased from 

 Name and address of carrier 

 Invoice number 

 Invoice date 

 Transportation record or bill of lading number and date 

 Date shipped 

 Date received 

 Amount received 

 Type(s) of receiving records represented by the supplier, such as: 

 Supplier’s analysis tag, which should reveal: 

 Kind and variety 

 Lot number 

 Origin 

 Date of test 

 Analysis results 

 Supplier’s laboratory report, which should reveal: 

 Name of laboratory 

 Laboratory number 

 Lot number 

 Supplier who obtained laboratory report 

 Date 

 Analysis results 

 Suppliers invoice, bill of lading, or other document, which establishes: 

 Supplier of seed lot, date, and amount received 

2. Variety and/or Origin 

 Copy of Grower's Declaration of Origin, Kind, Variety, or Type 

 Supplier’s invoices 

 Other documents necessary to establish the origin, kind, variety, or type labeled 

3. Conditioning/Blending Records 

 New lot number assigned 

 Date conditioned 

 Lot number(s), source, and weight of each lot blended 

 Rough weight 

 Cleaned weight 

 Number of cleaned seed bags 

 Kind of bags and how marked 

 How conditioned (clipper mill, gravity separator, blended, scarified, dried, etc.) 

 Description, label, or other document showing the name of applied treatment substance 

or inoculants, and application date 

 
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4. Shippers Test Records (obtained by the shipper) 

 Name of laboratory 

 Laboratory number 

 Lot number 

 Shipper who obtained laboratory report 

 Date 

 Analysis results 

 If labeling is based on analysis of component lots, each lot should have complete 

records as indicated above 

5. Sales and Shipping/Disposition Records 

 Invoice number 

 Invoice date 

 Kind and variety 

 Lot number 

 Number bags 

 Weight shipped 

 Quality represented on invoice 

 Date shipped 

 Shipped from (consignor/shipper) 

 Date delivered 

 Shipped to (consignee) 

 Transportation record or bill of lading number and date 

 Name and address of carrier 

 

6. Labeling Records 

 Actual label from the shipment 

 Copy of the label 

 Container (seed packet or lawn seed container) showing the labeling of the seed 

 Copy of the container showing the labeling of the seed 

7. File Sample 

 At least 400 seeds of vegetable seed; for minimum size of agricultural seed see the FSA 

Regulations Section 201.52 and Table 1 in Section 201.46 

 Lot number 

 Sample number 

 How and where sample was obtained 

 

8. Correspondence 

 Correspondence relating to seed shipment, records, or reports relating to official tests 

made by State enforcement agencies