ACTION ALERT - Changes to Seeds Regulations - Deadline May 23, 2013
Deadline for submissions -- May 23, 2013
- Sample Letter (Quote "Canada Gazette Part 1 VOL. 147, NO. 10 — MARCH 9," and send to Michael.Scheffel@inspection.gc.ca . (Please send us a copy of your letter too)
- Instant Letter
The changes proposed will have two critical effects: move registration of soybeans and all forages from Part I to Part III of Schedule III under the Seeds Regulations; and permit registrants to cancel the variety’s registration. This will make seed sales of that variety illegal and require that crops grown from that variety be classified as sample or lowest price and quality.
Crop kinds under Part I will continue to be treated the way all varieties have been until now; before a new variety is registered it must meet merit criteria (i.e., it must perform as well as or better than reference varieties for one or more criteria established for that crop kind); and it must be recommended by a Recommending Committee of experts familiar with the crop. Under Part III, a variety can be registered without field-testing or proof of merit. The registering company only has to provide basic variety registration information to the Canadian Food Inspection Agency (CFIA).
The proposed change in regulation will also allow companies that have registered a variety to de-register it without giving reasons or notice.
The implications of these regulatory changes for farmers are far-reaching. If adopted, the regulation will:
- Permit companies to take varieties off the market whenever they like, which will increasingly force farmers to use only varieties subject to royalties under the Plant Breeders Rights Act or varieties with gene patents, and thereby pay more for seed.
- Empower companies to introduce new varieties of soybeans and forage crops – including alfalfa – that have not been field-tested for merit and which therefore may not provide any benefit to farmers.
- Allow seed companies to transfer to farmers’ shoulders all risks of poor seed/crop performance when planting varieties that have not been field-tested by independent third parties.
- Transfer decision-making about which new varieties are introduced, and when, from a transparent, publicly accountable process based on expert advice offered by Recommending Committees to a behind-closed-door process controlled by private seed companies.
- Letting companies de-register varieties will permit companies to unilaterally stop farmers from accessing and using perfectly good varieties developed through long-term collaboration among farmers, public plant breeders and international seed collections.
- National Farmers Union’s submission to CFIA
- National Farmers Union 2009 press release and backgrounder on the variety registration system
- Proposed Regulations (Scroll down to "REGULATIONS AMENDING THE SEEDS REGULATIONS")
- CFIA’s Regulatory Impact Statement
All submissions must:
1. cite the Canada Gazette, Part I,and
2. the date of publication of the notice (March 9,2013), and
3. be addressed to:
National Manager, Seed Section,
Canadian Food Inspection Agency,
59 Camelot Drive,
|Sample letter May 2013.doc||26.5 KB|
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