also codified in Article 9 of the International Treaty for Plant Genetic Resources for Agriculture (ITPGRFA). Furthermore, peasants rights to seeds are also mentioned in the Convention for Biological Diversity and the UN Declaration on the Rights of Indigenous Peoples. UPOV standards violate this rights in the case of protected varieties, as farmers only are allowed to save seeds within very narrow limits and are not allowed to exchange or sell any seeds at all, according to UPOV 91. Furthermore, as implementation of UPOV is based on predefined standards, there is little room for member states to fulfill their obligation to take into account possible effects on the human right situation in their countries and to allow for participation of farmers. In many developing countries, small scale farmers have not beem informed prior to adopting and implementation of new plant variety protection laws and had no possibility participate in these decisions. As UNDROP and UNDRIP are part of Human Rights standards, they are higher order norms and therefore they prevail over property rights on seeds, according to human rights experts. As a consequence, states are obliged to revise regulations in national law that violate peasant's rights and adapt trade agreement or other intergovernmental obligations such as UPOV. In a report on seeds and farmers' rights to the Human Rights Council, Special Rapporteur for the right to food Michael Fakhri states that UPOV 91 violates farmers' rights. The report denounces pressures applied by industrialised countries on countries of the global South to join UPOV. It calls on UN member states to design and interpret seed policies and plant variety protection laws in a way that protects farmers rights and promotes farmers' seed systems rather than restricting them. Ethiopia, India, Malaysia and Thailand (all non-UPOV members) are mentioned as positive examples. Impacts of UPOV Impacts on development of seed sector and accessibility of seeds A study published by UPOV in 2005 evaluated the impact of UPOV compliant regulations in Argentina, China, Kenya, Poland and South Korea. The study found that in these countries the number of protected varieties of some crops has increased after these countries have joined UPOV. The report takes this as an indicator that farmers and the agricultural sector as whole has profited. However, the by far does not live up to the scientific standards for impact assessments and has been criticized being heavily biased. A report from 2005