Thank you.
Indeed we have concerns about both paragraphs (a) and (d) with respect to the potential violation of Canada's international trade obligations. Under those obligations, which exist under the WTO GATT agreement and under NAFTA, Canada is free to impose restrictions on imports, but only for specified purposes, and one of those narrow purposes would be for the purpose of a scientifically justifiable health or environmental concern.
By comparison, these two provisions—and I'm reading the words “shall make regulations”—would oblige the Governor in Council to prohibit all genetically modified grains, oilseeds, or trees produced after 2008 and would oblige the Governor in Council to prohibit all importation, whether there's an environmental or health concern or not. This is in stark contrast to the way in which Canada currently regulates seeds, and indeed all genetically modified products, which have to go through a market pre-assessment administered by CFIA under the Seeds Act, on a case-by-case, feed-by-feed, seed-by-seed, substance-by-substance basis to determine whether there is a specific environmental health risk that warrants, for example, the imposition of a trade restriction.