It isn't just a mater of terminology. Plant breeder's rights are different from patents and generally give much less power to the rightsholder. For example, the US has them via the Plant Variety Protection Act, but they only give protection to one single variety of plant, they allow researchers to use that variety without having to get a license, and they permit farmers to replant saved seeds. For this reason, US agribusinesses invested a lot of legal resources in convincing the courts to let them take out normal utility patents on plants, which had previously been considered unpatentable. (Plant patents were not the same thing, no matter what Monsanto's propaganda department have been claiming.)