The National Farmers Union submitted the following comments on the CFIA’s on-line survey regarding its discussion paper Crop Variety Registration in Canada: Issues and Options.
PDF version of the NFU’s submission
National Farmers Union comments on the Canadian Food Inspection Agency Questionnaire
“Crop Variety Registration in Canada: Options for the Future” – Fall, 2013
A: INFORMATION ABOUT YOU
1. Are the views expressed your own, that of a corporation, association or other?
The views and comments to follow are those of the National Farmers Union as prepared by Terry Boehm.
2. Please provide the name of the association/business you represent, as well as the association/business coordinates.National Farmers Union
2717 Wentz Ave.
3. What is your primary business or professional focus?
The National Farmers Union is Canada’s largest voluntary direct membership farm organization representing family farmers from across the country in all sectors of agriculture. We believe that small and medium sized family farms should be the primary food producers in Canada. We work to promote the economic and social betterment of farmers. In addition we work through numerous mechanisms whether marketing, education, research, or legislation to promote a higher standard of rural community life.
We would be pleased to correspond further in any follow up that flows from this process.
Responses to Questions for Discussion:
1. What advantages and disadvantages does the current variety registration system bring to the Canadian crop sector, nationally and internationally? To the particular crops that you are most involved with? Please specify crop (if applicable) and explain.
Our current variety registration system, which has been modified in 2009 to include 3 parts, brings a fair degree of oversight and protection for farmers in those crop kinds that are under Part 1 of the this system. The problem with Part 1 is that under the new regulations even in Part 1 merit can be reduced to as little as one criteria. This has been done with canola at present, where the only merit requirement is quality, which has been defined as oil quality and content. We feel that this is too narrow a definition for merit in canola. However, in general having canola in Part 1 is superior to having it in Part 2 or Part 3 where no merit criteria are required. Where other crop kinds are in Part 1 where a more extensive merit assessment is required for new varieties to be registered we favour the current system. It provides us with new varieties that meet our marketing concerns along with providing farmers with the assurance that varieties will perform well in their fields. Part 1 also retains a role for recommending committees with additional field testing at multiple sites over 2 or 3 years, on which they base their recommendations. We feel that test data as supplied by canola developers should not be a substitute for the first year of independent co-op field trials.
2. Given the changes to the crop production sector in Canada highlighted in the engagement document, should Canada’s approach to variety registration also change?
We feel that Canada’s approach to variety registration should not be changed, but could be made more robust within its current structure.
Please explain why or why not:
3. Please explain why Canada's approach to variety registration should not change.
While we feel that Option 1 is the best of the options offered in this survey, which is a maintenance of the status quo in our current system, we vehemently call for any changes that are possible in that system to reflect the original intent of the variety registration system — which was to protect farmers from fraudulent claims about variety performance and to give them reliable varieties that have independent field testing to verify claims.
4. If none of the proposed options meet the requirements or objectives you view as critical to the performance of Canada’s crop production system, what changes would you or your organization propose?
We would like to reiterate the concerns expressed in our other points that the variety registration system must reflect its original intent to protect farmers. It cannot be used to strictly facilitate the interests of an increasingly privatised seed industry to maximize profits at the expense of farmers. In addition we feel that variety developers should not have the sole discretion to deregister their varieties once registration is granted. For them to be able to do so would place farmers on a variety treadmill forcing farmers to buy new varieties when old varieties would meet their needs as well as the needs of the general grains sector. The registration system makes varieties valuable once registration is granted because farmers can grow them without penalty when they sell their crop. In exchange, those varieties should remain available to farmers as long as they wish to use them unless a plausible reason for not maintaining them, such as the variety hosting a disease or pest, becomes known.
5. If your position is that Canada should not have a formal variety registration system, what, if anything, should take its place? In your view, what would be the benefits/risks?
We think that recommending committees’ roles should be retained in the system, but that in the case of the introduction of a commercially harmful variety, a market harm test should be added to the criteria to be considered. In addition should this fail, we would like to see a public appeals mechanism where widespread public concern could prevent a commercially or environmentally harmful variety from being registered.
6. Please provide any additional viewpoints or considerations concerning Canada’s crop variety registration system (e.g. role and operation of Recommending Committees). Please explain your answer with examples, as appropriate.
We will be attaching our comments on the last variety registration changes as a background document to our comments here.
Thank you on behalf of the National Farmers Union.