Our submission raises very serious questions of governance, science, and the duty of the CFIA as public regulator to serve the public interest. We noted that in the process of developing the proposed guidance, the CFIA relied heavily on representatives of CropLife Canada, whose members stand to gain undue control of seed, and financially benefit from deregulation of gene edited products at the expense of farmers and the public good. This conflict of interest is at the heart of our concerns. The CFIA’s approach suggests it equates regulated parties with stakeholders. Regulated parties seek to avoid constraints on their business, while the public has a long-term stake in environmental safety and transparency.
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