I remember I used to use the number 30,000 to 40,000, so yes, 35,000 SKUs. There are 99.9% of those that are labelled properly as far as “Product of Canada” is concerned, so let's keep this in perspective, ladies and gentlemen.
My second point is that we can easily change your recommendation to help the Food Inspection Agency do this. We can easily change the 51% rule to something higher, such as 80% or 90%. That could be done. It can be done quickly, and it's not complicated. But certainly, do not make it 100%; you've had submissions already on why that would be a silly idea.
Why is it important not to change regulations? Happily, this is one of those areas where we can remain fairly nimble, because we're not stuck with an out-of-date regulation. The Food Inspection Agency makes changes to the guide on food labelling all the time. Subsection 5(1) doesn't need to be changed. It's there now, and it makes it a criminal offence to mislead people.
Leave the statute alone. Leave the regulations alone. Recognize that you can easily have a dramatic impact on the issue of “Product of Canada”, if you want to, by tinkering with the guidance, the guide to food labelling, and by keeping it voluntary, not bringing in regulations.
The food regulatory system in Canada is huge. There are about 10 federal statutes, and each of these has in the order of 20 or 30 sets of regulations. The food regulations in Canada sit on my desk and they are this high. There are literally hundreds and hundreds of pages of regulations relating to the food industry. It is not a good idea to get into the position where you have to change those in order to achieve something, because you're going to get further change, and you'll still be stuck with Canada's sclerotic regulatory change system, which takes a couple of years. It has to go to government twice, for RIAS and gazetting, just to have some minor change. It is this sclerotic food regulatory system that undermines innovation and investment for the food industry, and it certainly undermines competitiveness.
My argument to you today, and my second point, is do not engage that black hole of Canadian food regulations; make your contribution by recommending guidance changes. This is based on my own sense, as I mentioned in my introduction, that the single biggest problem, and the law we need to think more about on the Hill, is the law of unintended consequences.
If you start to change one part of the regulation because the food commodities are all different--and there are literally dozens of pages about products relative to meat, as the Meat Council told you.... The unintended consequence of the American COOL provisions is that the origin labelling now has a fundamentally flawed system. It's completely unworkable, and it will hurt both Canadians and Americans. We know what it would do to weanling pigs, for example.
I noted in a brief review of your minutes that a lot of people have confused the quality standards. I urge you to leave that alone. We've talked about amending product regulations and quality standards for about 15 to 20 years, Mr. Easter. We still haven't, and there's a reason. It is so complicated and so detailed that if you get into that, you may not get out.
You want to retain things like “Canada Choice”, even if it's not a “Product of Canada”, in the sense that the fruit isn't. It seems to me that there's a big difference between a can of pears produced, packaged, and canned in China, shipped here in a great big ship, and where a struggling Canadian food processor takes Chinese pears, cuts them up, uses Canadians to put them in a can, and hires Canadians to label and sell them. We should be able to distinguish between those two things.
In the case of the Canadian product, we know there have to be very stringent rules about what it means to be “Canada Choice”. For example, we would have a very hard time enforcing some of that stuff with respect to imported product.
To conclude this second point, it's important to realize that while the solution to this problem is not complicated, you could get into a mess tinkering with the regulatory regime.
Here's an example related to juice. A significant Canadian juice company that has survived and done well used “Product of Canada” for anything that was 80% Canadian ingredients. All of the processing, manufacturing, and packaging is carried out in Canada. This is their own voluntary standard. If they're not using 80% Canadian produce, they call it “Prepared in Canada”. This is a product for which all activities of processing, manufacturing, and packaging are done in Canada.
It seems to me that this would be quite adequate to protect the Canadian consumer. The last thing you would want, though, is to specify the country of origin for these kinds of things. You can't source apple juice just from Canada all year long, and many juices have multiple ingredients.
My third point has to do with the “Grown in Canada” designation. It's remarkable to me that the farmers of Canada are still looking for funding from Agriculture Canada to do this. Why don't they simply do it? A voluntary “Grown in Canada” program funded by producers can be done right now. It doesn't need to go through the regulatory system. As far as I'm concerned, it's remarkable that we haven't built on the good programs that many of the provinces have.
So, Mr. Bezan, it's not a complicated problem, really. The solution is easy: raise the 51% guidelines and encourage the producers, who are anxious to use “Grown in Canada”. You have subsection 5(1) to back it up if somebody tries to be misleading. It's surprising it hasn't been done before now.
Thank you.