Thank you, Mr. Chairman. I'll be providing the opening remarks. Mr. Leblanc is with me this morning. He is our labelling resource, and his expertise may be helpful to us all when it comes to the question time.
Thank you again, Mr. Chairman and members of the committee. I'm pleased to be here today to provide information to the Standing Committee on Agriculture and Agri-Food.
My name is Jeanne Cruikshank, and I am vice-president of the Canadian Council of Grocery Distributors. We represent the small, medium, and large grocery distributors on both the retail and food service sides. Our members annually contribute $72 billion in retail sales and $12 billion on the food service side to the Canadian economy. We service companies that you may know, such as Loblaws, Metro, Sobeys, and Safeway, as well as some of the smaller companies, like Thrifty Foods and Co-op Atlantic. You may also recognize our members’ private label products, such as Compliments, President’s Choice, No Name, Master’s Choice, and Safeway Select.
We have more than 428,000 employees in the industry and operate through 24,000 stores in every community in Canada. Our members account for about 85% of all the grocery products distributed in Canada to all of those 24,000 stores, hospitals, restaurants, institutions, and long-term care facilities. Each one of those products passes through a distribution or a retail network. CCGD’s mission is to advance and promote the economic well-being of its members and their efforts to deliver the best value to customers and the consumer.
Our role is to interface with consumers. CCGD members are the direct interface with consumers. We take very seriously the responsibility of providing information to consumers so they can make informed choices about the products they purchase. From the outset, let me be clear that the issue of “Product of Canada” is not considered a food safety issue by CCGD members. It is about country of origin. We recognize that we are dealing with a highly educated and discerning consumer in the very competitive world of food retailing. To that end, CCGD member products are labelled to comply with the current “Made in Canada” policy from the Competition Bureau. When CCGD members choose to promote products as “Made in Canada” or “Product of Canada”, we choose products that meet the requirements of the bureau.
There is always a better way. The food industry is an ever-changing business, and we recognize that there can always be a better way. We need to look at different scenarios for identifying products that are 100% Canadian, as well as products made in Canada with both Canadian and imported ingredients. Therefore, CCGD proposes considering a two-tier system similar to the CFA “Grown in Canada” proposal. Products that are “100% Product of Canada” would be labelled and/or branded with a unique logo and claim. A second designation would exist for products that are made in Canada with both Canadian and imported ingredients. It would allow enough flexibility to respond to the global economic realities of our industry in cases where ingredients are sourced from different countries.
Particular consideration will also have to be given to products that are processed in Canada with both Canadian and imported ingredients when they do not meet the 51% value-added criteria and therefore cannot display the “Made in Canada” claim. When destined for export, products that do not now qualify for “Product of Canada” are still required by the country importing the goods to declare a country of origin. The current “Made in Canada” guidelines do not address this scenario—yet another reason to review the current “Made in Canada” guidelines to address today’s reality of global marketing.
As for partnering with government, CCGD would be pleased to participate in the development of new claims for identifying products that are 100% Canadian content, as well as new claims to identify products processed in Canada with both Canadian and imported ingredients. These new claims would provide clarity to consumers and industry and must also work for both imported and exported products.
We strongly urge that any new guidelines and/or claims to identify products made in Canada be preceded by consumer surveys, so that it is well understood what message consumers would receive from these new claims. Once new guidelines and claims are established, we recommend that a consumer awareness component be undertaken on the part of government and delivered in partnership with industry. An example of this partnership would be the latest nutrition labelling TV ad campaign. In fact, perhaps part of the discussion currently around “Made in Canada” came about because there was no awareness campaign to explain its purpose, mandate, and criteria.
Opportunities and challenges. A challenge that will need to be addressed is that the claims and conditions that are developed to identify products made or processed in Canada will need to take into account the country of origin policies used by countries exporting food products into Canada. It is essential that there be a level playing field and that both products made in Canada and prepackaged products imported into this country meet the same criteria. To have products imported into Canada declaring, for example, “Product of Country X” when 90% of the product is from country Y would be misleading to Canadian consumers and would create an unlevel playing field. In other words, country of origin claims that are developed for the Canadian market must be compatible with those of our trading partners such that the relabelling of products would not be necessary.
The outcome of the standing committee discussion provides an opportunity to establish a forum to amend and revise regulations and guidelines for “Made in Canada”. This forum, a consultation with all stakeholders, would allow an opportunity for new definitions with clear parameters to be established, defined, and communicated to both consumers and industry.
A key element for the success of this review is the allowance of a considerable transition time for the industry to comply with any new guidelines for “Made in Canada”, thus minimizing the cost of relabelling products.
In conclusion, on behalf of the CCGD members, I would urge the members of the standing committee to establish a forum for full and thorough dialogue with appropriate stakeholders involved, many of whom have presented before you. CCGD members offer our involvement and expertise to what we hope will be a timely and efficient process that meets our mutual objectives.
Thank you.