The National Farmers Union (NFU) welcomes the opportunity to comment on the proposal by the Canadian Food Inspection Agency (CFIA) to amend the Seeds Regulations. Specifically, the CFIA seeks to allow variety registrants to cancel the registration of seed varieties on request, to move all forage crop kinds from Part I to Part III of Schedule III and to move soybeans from Part I to Part III of Schedule III.
The NFU strongly opposes the proposal and urges the CFIA to retain the seed regulations that currently exist.
The proposed changes are significant and would cause harm to farmers and to Canadian agriculture. The regulatory impact analysis (http://www.gazette.gc.ca/rp-pr/p1/2013/2013-03-09/html/reg1-eng.html ) indicates that the consultation was primarily with seed developers and sellers (commercial plant breeders, university research programs, seed companies, public and private plant breeders, major industry associations, the Canadian Seed Trade Association, the Canadian Seed Growers’ Association). The National Farmers Union participated in the 2009 consultation process that sought input on proposed changes to the variety registration system. We did not support moving crop kinds out of Part I, and we clearly stated our position during the meetings. We were not alone in our position, yet the regulatory impact statement says “Participating stakeholders indicated support for movement to Part Ⅲ, citing faster producer access to new varieties and reduced regulatory burden for variety developers.” In fact, the regulatory impact analysis says that only 56 stakeholders will be affected by the amendments, and each stakeholder is expected to save $1,956 per year. According to the Census, there were over 27,000 farms growing soybeans and nearly 125,000 growing tame hay in 2011. Clearly, the interests of farmers as seed users have not been taken seriously.
The seed variety registration system was set up to ensure that seed sold in Canada meets quality standards to protect farmers from unscrupulous sellers and to protect Canada’s national interest by ensuring that crops are not at risk due to disease susceptibility and other losses that can be prevented through public interest seed regulation. The CFIA, as the public regulatory body, has a duty to protect the public interest and a duty to ensure that the interests of the less powerful are protected. The proposed seed variety regulation and the CFIA’s regulatory impact analysis indicate it is prepared to abandon these duties.
The proposed regulation will significantly change the variety registration process by moving soybeans and all forages from Part I to Part III of Schedule III and by allowing the owner of a variety to cancel the variety’s registration.
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