I would like to go back to the GROU program. Farmers--in Ontario just last week and I know in my part of the world as well--are really concerned that they have an effective own use import, or OUI, program in place. The farmers want it and they're calling for it. I think the new GROU program has some things in it that need to be addressed before it replaces OUI, and I'd like your comments on some of this.
On this proposal that things need to be materially identical, we're getting some concerns from producers and others that it does a number of things, including limit the scope of products registered to the same company on both sides of the border. I'd like you to comment on this, that the product needs to be registered on both sides of the border in order for it to be available.
There is a concern about the ease with which companies can alter the distribution within the U.S., to avoid sending the chemical here, by not making it available down there.
There is a concern about the fact that companies will be allowed to change the product in a minor way to avoid the program, so that it's not materially identical.
There is an issue about how easy it is for companies to change the labels so that the product does not meet requirements and then obviously can't be imported into Canada.
There is also a concern about companies manipulating to extend patent protection on products. That's something that happens fairly often now. They can use other processes or formulations of the product, extend the patent protection on it, and then it doesn't become a generic.
I guess the worry is that the pilot program is really just an attempt to eliminate the OUI program in the short term: we'll give you this dozen or twenty chemicals fairly quickly, but our real intent is to eliminate the OUI program.
Another comment is that if the generic is registered in Canada, Canadian producers can access it from the U.S., but if there is no generic register there, are we out of luck? For chemicals registered in both places, we can access it, but if it's not registered in the United States, what happens? Can we access it or not?
Another comment was that GROU succeeds where there is access, but it is not going to succeed in establishing access.
I'd like your comments.