The Tribune Review reports that nonprofit seed libraries do not need a license.  Neither are they subject to the labeling and testing as required by commercial distributors.

In 2014, the Joseph T. Simpson Library had been told it was in violation of the Pennsylvania Seed Act of 2004 ; however, the next year, the Pennsylvania Department of Agriculture “clarified that seed libraries are not subject to the regulations of Pennsylvania’s seed law, but noted the benefits of following the department’s seed library guidance: limiting the liability of libraries that host seed exchanges, ensuring the quality of seeds circulated, and providing greater security for the local food supply.”  Read more.  Here’s an article from the Sentinel.