Thank you, Mr. Chair.
The Consumers' Association of Canada is pleased to have this opportunity to present its views to the committee. For over 60 years the CAC has represented the interests of ordinary Canadians in their role as consumers of goods and services, as provided by both the public and private sectors. Our mandate is to inform and educate consumers on marketplace issues, advocate for consumers with government and industry, and work to solve marketplace problems in beneficial ways.
Canadian consumers are being misled by inappropriate and inaccurate use of labels such as “Product of Canada” and “Made in Canada”. During the course of these deliberations I suggest that the committee consider these basic questions: What is the purpose of these markings? Why do we have such markings?
Consumers have two prime interests in knowing where the items they purchased were made and the source of the ingredients or components. One obviously is economic. When given a choice, many would prefer to purchase the product that has the greatest economic benefit to Canada, all other things being equal. However, this is not usually something that they think about right off the top of their mind, unless they've been prompted to do so by some promotional campaign. The other consumer interest relates to a feeling of security or safety, which is affected by knowing the source of their purchases, particularly with regard to foodstuffs.
There is no standard defining “Made in Canada” or “Product of Canada”. There are guidelines. Even though these terms are frequently used synonymously, they do have somewhat different meanings for most consumers. The situation is further confused by the use of grading terms such as “Canada Choice”.
Twenty or so years ago I managed to chair a committee of the Canadian General Standards Board, which was attempting to define “Made in Canada”. The formation of that committee was prompted by the introduction of a federal government campaign inducing consumers to buy Canadian-made products. At that time, while the group came to agreement on what elements could be considered Canadian content, based primarily on work being conducted and/or benefit to the Canadian economy, it became quite clear that it was impossible to achieve consensus on what percentage of the cost would be required to qualify for a “Made in Canada” designation. Some said 51%, while others felt it should be much higher, as high as 80% or 90%. As a result, that committee developed two standards--one defining Canadian content, how you would measure Canadian content, and the other called “Think Canadian”, which skirted the issue but allowed products to be so marked in support of the government efforts. If memory serves, it was out of this process that the phrase “substantial transformation” was developed.
I made a distinction between “made” and “product of”. The term “made” implies a manufacturing process where many things are brought together to form a new item, or that indeed a substantial transformation had taken place. However, even that can be problematic.
I have an example with respect to the “made in”. Even though we are dealing with agricultural products, there is considerable overlap in the two problems. For example, a man's tailored-to-measure suit made of cloth imported from Italy would probably qualify for “Made in Canada” under the guidelines because of the significant labour component. Certainly the cloth has been transformed. Should a distinction be made between that suit and one that has been crafted from cloth woven in Canada, probably from wool sheared from foreign sheep.
The term “product of” implies having been brought forth from, yielded from, grown. The affinity with the term “produce”, which is what we normally refer to as farm products, is clear and that is what is understood by consumers. When we are referring to foodstuffs, the expectation of a “Produced in Canada” or “Product of Canada” label is that the product was grown or raised in Canada. The concept of Canadian value-added is usually alien to consumers in this context.
Thus, it is completely inappropriate, and we submit should be illegal, to label as “Product of Canada” a can of, say, apple juice that is full of a liquid comprised of a concentrate from China to which has been added Canadian water, I guess, and that is placed in a can in Canada. The situation becomes significantly more complicated when we're dealing with a multi-ingredient product such as ice cream or indeed just about any processed food product. With a product of this type, we are starting to see a blurring of the two interests I mentioned at the start. Is there a safety or security factor, an economic issue, or neither or both?
In the interests of providing to consumers truthful, useful, and non-misleading information with respect to food products, we make the following general recommendations, recognizing that they would need more work to provide detail.
With respect to canned or packaged items containing only one or two major ingredients, if those ingredients were grown or raised in Canada and the processing and packing were done here, then the item could be labelled “Product of Canada”. If an item contains multiple ingredients that can be uniquely identified by the consumer, such as a bag of mixed vegetables, the label could state “Product of Canada” if, say, 75% or more of the weight or volume is grown or raised in Canada. Ideally, the source of the remaining percentage should also be shown.
In a blended product, such as ice cream, if the source of the major or most significant ingredient is known to be Canadian, then it could be labelled “Product of Canada”. Conversely, if the major ingredient is known to come from a specific source, consideration should be given to marking that source, and if the major ingredients come from mixed sources or if the blend varies over time, then perhaps there should be no source designation at all.
In order to avoid confusion, the terms “Canada Choice” or other similar grade designations should be replaced by a term that does not include Canada as part of that designation.
Those are my comments for the moment. I'd be pleased to try to answer any of your questions.