Seed Regulatory Modernization (SRM) is happening now, with the Canadian Food Inspection Agency (CFIA) undertaking a full-scale review of the Seeds Regulations, excluding Part V. It is a comprehensive review of the Seeds Regulations designed to make the system simpler, easier to use, and more aligned with modern practices and strengthen consumer protection. This project will lay the foundation for a strong Canadian seed system for years to come.
CSGA’s mission is to advance the seed sector and, with its partners, deliver and promote a flexible, responsive, and cost-effective seed certification system supporting Canadian agriculture. However, Canada’s seed regulatory framework is complex and sometimes not well understood. Now is the time to talk with colleagues about what a modern seed system for Canada looks like. What is working? What isn’t? It is important to remember that a robust and resilient seed system is essential to all Canadians.
The CFIA March 2023 Pre-Consultation Survey
As you know, the Canadian Food Inspection Agency (CFIA) has released its Seed Regulatory Modernization (SRM) Task Team recommendations report and a pre-consultation survey (closing May 1, 2023), seeking your input on potential changes to the seed system.
While there was strong alignment between the Task Team recommendations and CSGA’s vision for a next-generation seed system, we need to keep working together to ensure that the seed sector and Canadian agriculture will continue to thrive and prosper.
Before you respond to the survey, we wanted to share how and why we are responding to the survey.
Let’s Not Miss This Chance To Make A Real Difference!
CSGA Answers to Key Survey Questions
We’ve created an outline of how CSGA will be answering the survey questions and why. To improve readability, we have shortened or paraphrased some questions.
We invite you to review our Complete Survey Q&A Framing Document.
The task team did a deep dive into our national variety registration process and potential pathways for heterogenous and heritage varieties. Of note, this Task Team did not reach a consensus on whether Canada should have a variety registration system – even though 16 of 20 representatives supported it, including CSGA. The complete final report is available here.
SURVEY QUESTION 1: In your opinion, should Canada continue to have a national variety registration system?
CSGA’s Response: Yes
Here’s Why: Canada has an international reputation for quality, and our variety registration system is a major reason why by providing an unbiased, third-party assessment of new varieties to let producers know how a variety will perform. The variety registration system continues to evolve and provides flexibility to the value chain to decide how varieties are assessed and approved. As a grain exporting country, Canada’s variety registration system also helps maintain market access and streamlines bulk grain handling.
Task Team Recommendation: No consensus, although 16 out of 20 representatives supported – including CSGA.
Read all our Responses to
the CFIA’s Variety Registration Questions
The Task Team looked at seed certification, crop inspection, crop certificates, and new technology. Of note, CSGA supports all of the recommendations coming out of this task team. The complete final report is available here.
SURVEY QUESTION 1: Should Canada continue to have one national body establishing and determining the seed crop varietal purity standards to issue a seed crop certificate?
CSGA’s Response: Strongly Agree (Option 5)
Here’s Why: One of Canada’s advantages in seed certification is that we have a single organization with a laser focus on seed crop certification. CSGA has delegated authority under the federal Seeds Regulations to set varietal purity standards and certify seed crops and has delivered this public good service for over 100 years.
Separating standards and service delivery not only worsens current inefficiencies but it also risks lower standards and higher costs. It will also transfer more risk to the seed producer, reduce transparency, and erodes trust in both the process and the production of Certified seed.
CSGA has the size, scale and proven track record to administer our program cost-effectively (certification costs less than 1% of the value of seed) and ensures that no producer or crop kind is left behind. Compare this to the United States, where each state has a different seed law and seed certification services, CSGA delivers a national seed crop certification program at a fraction of the cost.
Task Team Recommendation:
- There should be one national seed crop production rules and regulations
- CSGA should continue to set the national standards for pedigreed seed
- CSGA should remain as the single body issuing pedigreed seed crop certificates
Read all our Responses to
the CFIA’s Seed Certification Questions
The CFIA survey covers variety registration, seed certification, and seed standards. You need only answer those questions that apply to you and your business. You can also save your progress and return to the survey later. The consultation will be open for comments from February 15 until May 1, 2023.
COMPLETE THE CFIA
PRE-CONSULTATION SURVEY HERE
CSGA and CFIA’s SRM Update Webinar
Click here for the January 26 SeedTalk Prairies webinar which provides SRM updates from Wendy Jahn, National Manager, Seed Section, CFIA and Doug Miller, Executive Director, CSGA.
CSGA’s SRM Policy Position Paper: Our Recommendations for Change
CSGA’s full SRM policy position paper outlines CSGA’s recommendations for seed regulatory reform and why they are important. In some cases, the recommendations represent change; in others, they maintain essential aspects of today’s system.
Through in-depth discussions on regulatory modernization with seed growers, plant breeders, provincial advisors, and company representatives, a series of CSGA recommendations have been developed that focus on:
- Industry leadership and a renewed partnership with government
- The CFIA should continue to be ultimately responsible for the seed certification program.
- The CSGA’s delegated authority should be expanded to include certification of Foundation, Registered and Certified seed.
- The Seeds Regulations should recognize CSGA to establish technical requirements for seed certification in Canada.
- Digitalized services
- The seed certification system should be digital end-to-end to facilitate single-window access to seed regulatory services.
- Varieties
- Variety registration should be maintained, and the CFIA should continue to be responsible.
- Schedule III to the Seeds Regulations should be incorporated by reference and updated, with the CFIA as the responsible authority.
- The current requirements concerning the use of variety names should continue.
- The CSGA should administer the Variety Profile Platform in support of enhanced transparency for the agri-food system.
- Seed Quality Assurance
- Part IV of the Seeds Regulations should be incorporated by reference.
- Common seed of cereals, pulses, and oilseeds should be subject to strengthened regulation and meet minimum standards for purity and germination.
- Common seed of small-seeded agricultural crop kinds should be sampled, tested, and graded by people authorized to do so, as currently done for pedigreed seed.
- CFIA Commitments
- The CFIA should increase its investment in science support for the Seed Program, commit to continued engagement in international standards development organizations, and commit to succession planning to ensure that appropriate and adequate human resources are available.
These ideas are part of the CSGA 2.0 Business Plan which outlines the Association’s vision for the future of the seed system which depends on a reliable supply of high-quality, identity-assured seed. The Policy Paper provides a detailed rationale for each recommendation.
Get Involved!
Participate in CFIA’s consultation and express your views on seed regulations. Share what you value most in Canada’s seed system.
Reach out to us or your Branch if you have questions on the recommendations or if you would like to discuss CSGA’s positions on SRM.
Volunteer on an upcoming CFIA SRM Task Team on Import, Export and Information (records and labelling). Reach out to us to express interest.
Please email us or your regional branch if you have any questions or wish to discuss our positions on SRM.
Thank You for Supporting CSGA’s Vision for a
Stronger, Modern Canadian Seed System
