The current proposed regulations entrust the monitoring of imported products to the jurisdictions of other countries with which Canada has signed equivalency agreements.
To accept a product imported to Canada, the other proposed alternative is certification to Canadian standards. There is no clause allowing for the unilateral recognition of an organic production standard and a monitoring system as equivalent to Canadian requirements, without the signature of an equivalency agreement. By comparison, even the EU and the United States, two jurisdictions that have much more influence in imposing their own organic standards, have this type of flexibility in their regulations.
Such flexibility would allow Canada to have more leeway to facilitate the supply of imported products and ingredients that would comply with Canadian requirements. Moreover, Canada would certainly need this flexibility, since recent CFIA reports indicate that little progress has been made in negotiating the equivalency agreement with the European Union.
Furthermore, this flexibility would also put Canada in a better position during equivalency agreement negotiations with countries that have less strict standards. In fact, it would be much easier to withdraw from negotiations that yield unsatisfactory results, if there were other alternatives to control organic product imports.
Canada imports between 80% and 85% of organic products sold in Canada, and the lack of flexibility in accepting imported products will have a negative impact on the competitiveness of Canadian companies .
The lack of export product regulations and the lack of flexibility in accepting imported products falls in line with the lobby that is promoting the North American integration of the organic industry based on the adoption of U.S. standards.
Insofar as the organic product market is much more developed and stable in the European Union in comparison with the U.S. market, and while most representatives who established and developed this industry have serious reservations about certain U.S. organic standard provisions, it is essential to consolidate the basic principles on which the future of this industry depends.
To this end, Filière therefore requests that organic products exported from Canada be certified to Canadian standards by a certification body accredited by CFIA; that section 29(2) of the draft regulations be replaced by a section that will allow the import of an organic product only if this product is certified to standards equivalent to the Canadian standard by a certification body recognized by CFIA.
Regarding a proposed accreditation system, Filière also requests that the accreditation system proposed for Canada be brought into line with that in effect in other industrialized countries that regulate organic products; to have CFIA designate as an accreditation body any Canadian accreditation authority constituted specifically by virtue of a Canadian government regulation at the federal or provincial level.
During the consultation period on the Organic Products Regulations (2009), Filière also made certain comments on the logo design and the Canadian standards update, two other weak points in the Canada Organic Regime that will undermine the Canadian organic industry's competitiveness. Filière invites you to review this document. Thank you for your attention to this matter.