Thank you, Tia.
My name is J. Wallace Hamm, and I am the founder of Pro-Cert Organic Systems, a pan-Canadian organic certifier in its 27th year. I'm also a grain farmer in Saskatchewan, though it's not in the script.
Canada's organic industry is flourishing despite the fact that its eight-year-old Canada organic regime, or COR, is in need of a major overhaul. Much of that overhaul involves the removal of self-imposed, non-tariff trade barriers from the COR. This panel is therefore a serendipitous opportunity for the Canadian organic industry to ask for change. Yes, I said, “self-imposed, non-tariff trade barriers”.
In the next few minutes, I will outline several of these trade barriers gleaned from a draft document, a white paper, entitled—and it's a long title—“COR Enhancements Needed to Ensure Organic Integrity, Increase Consumer Confidence in the Canada Organic Logo and Reinforce our Equivalency Arrangements”.
This is a work-in-progress document, and it is capturing the main organic industry needs for a more competitive and less cumbersome regulatory future as the organic products regulations or OPR, moves from the Canada Agricultural Products Act, CAP Act, to the Safe Food for Canadians Act, and becomes part 14 of the latter, of the regulation. It will be distributed to all and sundry in the very near future, but before the April 21, 2017 deadline for comments on that recently gazetted regulation.
Here are some examples of self-imposed equivalency trade barriers. First is the U.S.- Canada equivalency arrangement, 2009. Certification to the USDA NOP, national organic program, in Canada is no longer allowed at the Canada organic office's request. There was ongoing negative impact on Canadian organic exports to countries that recognize the NOP but not the COR. NOP certification is required for out-of-COR-scope products such as health food products and pet food. There is no practical rationale for this self-imposed trade-restricting rule.
Second is the Canada-European Union organic equivalency arrangement, 2011. Certification to EU standard is also not allowed, at the request of the Canada organic office. There is similar negative impact on Canadian exports to the EU and other countries that want to see the EU logo. Again, there is no practical rationale for an arbitrary trade restrictive rule.
Actions needed include immediate elimination of the COR prohibitions against certification to the U.S., the EU, and other national organic standards, as well as increased consultation with and involvement of organic industry experts before and during equivalency negotiations.
Another example of a self-imposed trade barrier is the lack of sanctions for fraudulent organic claims. The organic products regulation, OPR, does not specify any penalties or fines for organic fraud. Likewise, the proposed part 14 of the safe food for Canadians regulation, SFCR, does not specifically impose penalties and fines for contraventions. It is unclear whether section 39(1) of the Safe Food for Canadians Act applies to part 14 of the regulation. Neither the OPR nor the proposed SFCR specify a cancellation period before fraudulent organic operators can reapply for certification.