Importantly, the rules of the CBD and the Nagoya Protocol do not apply retroactively. This means that Access and Benefit-Sharing obligations do not apply to genetic resources that were in your possession before 28 December 1993, but may apply to all genetic resources acquired thereafter. If the country providing you with the genetic resources had or introduced rules or regulations for ABS after 1993, you have to comply or should have complied with them.
The compliance measures laid down in the Nagoya Protocol and implemented through EU Regulation 511/2014 do not apply to genetic resources already in your possession before 12 October 2014. The EU rules only apply to genetic resources that were obtained and used on or after 12 October 2014. In other words, Access and Benefit-Sharing obligations exist since the coming into force of the CBD, but EU-obligations only since 12 October 2014.