I'd like to correct that.
Within the Canadian Wheat Board you can use variety names. They buy on variety names right now, and it doesn't have to be certified seed. Only Warburtons does that.
In respect of misrepresentation, I think the answer to your question is in Australia. I asked the Australians this question, and they talked about possible problems with an affidavit system. They said problems arise occasionally, but they've been able to deal with them. Rather than try to reinvent the wheel, as we do all the time in this country, it would be worth our while to go and take a look at some of the systems that are working in other countries.