In recent years, Health Canada's natural and non-prescription health products directorate has asked representatives of the chemical industry to take part in confidential discussions on a regulatory framework for biocides.
ADICQ is a non-profit organization, an NPO, that pursues the following objectives: to promote, develop and encourage the chemical industry in Quebec by paying particular attention to SMEs; to bring together businesses in the industrial chemical sector, manufacturers and formulators, in particular, in order to represent their common interests, promote foreign market development, trade and strategic and technological alliances; and, lastly, to ensure regulatory oversight and to inform members on all issues pertaining to their industrial activities.
Despite ADICQ's representations, Health Canada turns a deaf ear to our requests for political reasons and continues to threaten the Canadian chemical industry, especially its SMEs, and particularly in Quebec. In our view, the recognition of foreign approvals of disinfectants and biocides will harm Canadian manufacturers. Health Canada's proposed biocides regulations provide for the exclusive recognition of American approvals in Canada, which would amount to the equivalent of a form of American protectionism imposed on Canadian businesses by the Canadian government. The proposed regulations also provide for reduced fees and shorter approval timelines for foreign products, which would benefit American multinationals, and that could in turn preempt Canadian manufacturers.
Furthermore, by streamlining review during the approval process, Health Canada cannot ensure the public's protection or guarantee product quality. The proposed regulations provide for less content to be supplied in applications for American products. As a result, Canadian products would have to meet a greater burden in order to be approved as the proposed regulations do not set forth the same criteria as for American products. Health Canada has to date refused to define how public safety from foreign products will be assured.
The creation of a new category of regulated products will clog the file review process, particularly for food-contact surface sanitizers. In 2004, Health Canada began implementing the Natural Health Products Regulations, a process that took seven years. Implementation of the Safe Food for Canadians Regulations is still unfinished in 2023, five years after the process was announced in 2018. Experience therefore shows that the proposed regulations will generate red tape that will take up at least two years and involve costs estimated at some $20,000 per product for Canadian manufacturers.
In the meantime, foreign products could be recognized and approved without review, more quickly and at lower cost. Health Canada claims that the proposed regulations are part of an equity- and transparency-based process, but, contrary to Health Canada's allegations, there is no consensus in the Canadian industry.
Since 2018, ADICQ has attended all meetings and expressed its opposition to the proposed regulations on behalf of Quebec businesses. We have even sought a moratorium. The Canadian government must remind Health Canada that we can't rob Peter to pay Paul. SMEs in the Canadian industry, and the Quebec industry in particular, would be subject to a frontal attack that would benefit the American industry. There can be no double standards in an international free trade context.
ADICQ in no way disagrees with free trade policies, particularly with the United States. The same is true of the Canadian Federation of Independent Business, an associative partner of ADICQ. We remain receptive to any regulatory framework designed to protect the health of Canadians and the economic health of Canadian businesses.
Thank you.