Good morning everyone. Thank you for the opportunity to appear before you today and present our position.
I would like to point out, right from the beginning, that CTAC has already provided its feedback on the food and consumer product safety action plan to the Department of Agriculture and Agri-Food, as well as the Department of Health. Therefore, we will be covering the same points relating to the identification of products of Canada.
On the one hand, we believe it is now essential, in a globalized world where there are more and more questions being asked about the origin of products, to provide credible information. Processors are aware that consumers want to be better informed with respect to the origin of the food products they purchase. The current definition of the designation used to identify products of Canada must be reviewed, because it does not identify the origin of the content of the products consumers purchase. At the present time, when 51 per cent of the production costs are Canadian, a product can be labelled “Product of Canada”. That is the reason why many processed products are labelled “Product of Canada”, even though, in reality, the primary raw materials come from outside the country.
The same applies to designations of grades in the processed food and vegetable sector. Apples imported from the United States are processed into apple sauce that is then labelled both “Canada Fancy”, and “Product of Canada”, based on the 51 per cent rule. This term relates to the grade, but its interpretation can lead to confusion. Identification of the grade should also be revisited, in order to ensure consistency with new regulations relating to the designations “Product of Canada” and “Prepared in Canada”.
Furthermore, it is our belief that, when food safety problems occur or a food product is recalled, it is important for products that have been processed in Canada to be easily differentiated from imported goods, the raw materials of which do not come from Canada. Consumers have to be able to more easily identify Canadian products, and not confuse them with imported ones. A credible and consistent policy would reassure consumers and encourage them to make enlightened choices. For example, contamination of carrot juice produced in the United States should not have repercussions for all carrot juices produced and sold in Canada.
How are processed products identified? With respect to agricultural products that are sold as is, it is simple enough to distinguish between something labelled “Product of Canada” and something that is not a product of Canada. The situation becomes more complicated when products from different countries are mixed together in a single package. There the proportion of Canadian content must be identified in order for the product to be labelled a “Product of Canada”.
The problem is no different for products processed in Canada. What products are allowed to be labelled “Product of Canada”? Based on what percentage of Canadian content should foods processed in Canada be authorized to use that designation? As regards “Product of Canada” and “Prepared in Canada”, we are proposing definitions similar to those used for “Product of Quebec” and “Prepared in Quebec”, which are accepted by the food industry.
The “Product of Canada” designation should be used for any product that is entirely Canadian or 80 per cent of the main ingredients of which are of Canadian origin, and for which all the processing and packaging are carried out in Canada. We believe that the standard of 80 per cent Canadian content is both an accepted and realistic one, considering that most blended foods contain exotic ingredients, such as olive oil, wine or other ingredients not available in Canada. The 80 per cent standard also comes from a consumer study. That study concludes that 80 per cent Canadian ingredients is an acceptable threshold for a food to be identified as “Quebec food product”.
One could consider a food to be “Prepared in Canada” when at least 50 per cent of its ingredients are of Canadian origin and at least 80 per cent of the costs associated with its manufacture are incurred in Canada, and the processing and packaging of the product also occurred in Canada. If the raw materials are not available in adequate quantities or are not of adequate quality in Canada, they may come from somewhere else. In that case, all the processing, preparation and packaging must be carried out in Canada.
In order to arrive at a realistic identification concept, certain conditions have to be set before a new policy for identifying Canadian products can be introduced. To begin with, a guarantee of the origin of the ingredients is absolutely essential in order for product origin to be traced.
That means ensuring that processors have comprehensive and functional systems for retracing the origin of all ingredients. That way, country information on packaging would be verifiable.
Producers who use the designations “Organic” and “Controlled Designation” are already required to ensure the validity of their claims through traceability mechanisms. The same should apply to claims related to origin.
Another point is extremely important: the identification of the source of imported ingredients. A very wide variety of ingredients purchased by Canadian companies transit through many different countries. As a result, it is not rare for ingredients, sub-ingredients of ingredients, or a proportion of ingredients purchased in the United States to actually come from China, Mexico or other countries, even though it is not mentioned on the package. Identification of their origin would allow processors to make enlightened choices and would facilitate proper enforcement of the designations “Product of Canada” and “Prepared in Canada”
Thank you.