Thank you.
La Filière biologique du Québec would like to sincerely thank the Standing Committee on Agriculture and Agri-Food for agreeing to meet with us so that we could express our serious concerns about the proposed Organic Products Regulations (2009) and its negative impact on the competitiveness of the Canadian organic industry.
La Filière biologique du Québec is an organization that began its activities in 1994 and that represents 12,000 organic operators in Quebec. Filière is also a member of the Organic Federation of Canada.
Filière believes that the proposed regulations should be amended as soon as possible, since, not only do the regulations not meet the Canadian organic sector's objectives, we also believe that they completely stand in the way of its development. Here are the main arguments on which the request for a committee review is based.
The Canadian organic sector wanted to have organic products regulations to ensure a credible monitoring system for companies that use the organic designation for their products. Accreditation is the police for the organic products control system. However, the current proposal delegates the monitoring of organic products to accreditation bodies outside the country. Such a delegation of public authority to foreign organizations is improper and will have a negative impact on the Canadian industry's competitiveness.
Under the Quebec provincial law that controls the intra-provincial trade of organic products, the Conseil des appellations réservées et des termes valorisants—the CARTV—is responsible for accreditation and monitoring. The Quebec industry highly values CARTV's accreditation system and continually refers to it when assuring consumers of the credibility of Quebec organic products.
Filière hopes that the Canadian industry will acquire similar means to increase its competitive edge on domestic markets, like the United States and the European Union have done in their own markets.
The organic sector wanted the regulations to effectively control the export of organic products. Unlike the 2006 version of the regulations, the current proposed regulations no longer require products that are exported from Canada to be certified to Canadian standards.
Canadian companies lose the added value associated with uniform quality certification for all Canadian products. Furthermore, Canadian processors will have supply problems, since they will not have access to products that are certified only to the standards of the countries to which these Canadian products will be exported.
Here are the reasons to exclude export products from federal regulations. To accurately assess the scope of the negative impact resulting from the lack of regulations on the Canadian industry's development, it is important to understand why certain operators would choose not to request certification to Canadian standards, even if this deprives them of access to interprovincial trade. The main reasons to exclude export products from regulations and Canadian organic standards are as follows: costs associated with purchasing standards; costs associated with additional certification; costs associated with becoming familiar with standards; free trade and competitiveness on export markets (to this end, it should be noted that several points in the Canadian standards are similar to the European standards, both of which are stricter than the U.S. standards); and, the impossibility of obtaining imported ingredients that comply with Canadian standards.
For these reasons, certain operators have clearly indicated that they will not adopt the Canadian standards for the certification of their products. Moreover, since the provincial regulations to control intra-provincial trade will not be in force on June 30, 2009, these operators will also be able to market their products on the intra-provincial markets.
The combination of the lack of regulations for export products and intra-provincial trade could prove to be disastrous for Canadian companies, whose development and survival depend on the supply of organic products certified to Canadian standards that are traded on the intra-provincial market.
Important players in the grain and oilseed sector vigorously opposed compulsory certification to Canadian standards. After the implementation of the regulations on June 30, 2009, these crops will not be accessible for livestock production, processing and retail sale in Canada.
The maple production sector has been waiting for nearly 10 years for the implementation of federal regulations that would eliminate disparities in the organic certification of products exported to the EU. The sector will thus have to deal with the negative impact of these disparities which, if the regulations are unchanged, will become a permanent reality in the sector and may even become more widespread.
In the market gardening and livestock sectors, if a Canadian producer believes that it is in its best interest to split up production according to various standards to serve the U.S. market, for example, it will have to plan in advance the proportion that will be intended for Canadian and U.S. markets. The surpluses certified to Canadian standards, which will also be mostly certified to less strict U.S. standards, could be sold on the U.S. market, but not the contrary; hence the loss of access to surpluses certified to U.S. standards for Canadian processors, distributors and retailers.
The Canadian organic industry, which intends to serve the Canadian market by certifying its products to Canadian standards, is also concerned about the high risk of fraud associated with the sale of a portion of the surpluses certified to U.S. standards on the Canadian market. This will result in unfair competition for companies that mainly serve domestic markets.
The organic sector wanted the regulations to allow for the proper monitoring of imported organic products. The current proposed regulations entrust the monitoring of imported products to the jurisdictions of other countries.