Thank you, Mr. Chair and members of the committee, for having me here today.
My name is Mark Walker. I'm the vice-president of markets and trade at Cereals Canada.
Cereals Canada is the national industry association for wheat, durum, barley and oats in Canada. We represent the full value chain from farmers to crop development companies, grain handlers and exporters. Our members are focused on the benefits of export-led growth facilitated by access to diverse global markets. Canadian cereals are a staple food exported to every corner of the globe and over 80 different countries. In an average year, Canada's wheat, durum, barley and oats sectors generate $68.8 billion in economic activity, including more than 370,000 Canadian jobs.
I appreciate the opportunity to appear before you today to provide input into the committee's study regarding border carbon adjustments, or BCAs, as well as reciprocity standards on Canadian agriculture. BCAs are a new and developing area of environmental policy with some certainties and significant uncertainties.
At the outset, it's important to note and highlight how a BCA and associated reciprocity might function, but also the structure required to achieve that function.
A BCA and associated reciprocity must apply a price on carbon on imported products from jurisdictions that do not have a price on carbon and provide reciprocal relief to entities exporting to jurisdictions that do have a price on carbon. In creating a BCA that would apply to jurisdictions that do not have a price on carbon, the government would have to assign carbon intensities to the harmonized system or HS codes of products that are imported into Canada, aligned with the carbon intensity of the life cycle of that product in the exporting country's production system.
Some thought would also have to be given to the carbon intensity of comparable domestically produced goods, and whether the carbon price assigned to that domestically produced good is higher or lower than the imported good. What this would do is take the work of ECCC's carbon markets bureau and replicate it on a global scale. For example, in order to assign a price on carbon to north African or North American fertilizer, the scope 1, 2 and 3 emissions of that product would need to be properly verified.
The concept of a reciprocal structure is somewhat more straightforward. However, one must consider exempt jurisdictions with a price on carbon that are subnational, like California; national, like China or the United Kingdom; and supranational, like the EU. This reciprocal structure would need to be spelled out in treaties that seek to avoid double taxation, like the kinds Finance Canada already currently administers. These treaties would provide relief to exporters sending products to markets with a price on carbon and their importers shipping products to Canada.
Again, thought would have to be given to the carbon intensity of comparable domestically produced products and whether the price on carbon assigned to that domestically produced good is higher or lower than the imported good when assessing the appropriate quantum of relief.
In addition to administering the noted treaty regime, the government would need to be properly resourced to collect and refund taxes as necessary.
These are the considerations related to a BCA and associated reciprocity that are well understood. However, there are other considerations that I must flag which, while far less clear, are also critically important.
In addition to the significant government resources required to set up and administer this initiative, it would also burden private companies and individuals with new reporting requirements, processes and costs. It would create an entirely new school of accounting in Canada akin to GST and capital gains.
The Canadian cereals industry is export-oriented but reliant on imports of key inputs. A BCA could increase the cost for Canadian farmers of things like imported fertilizer products from some of our largest import sources. Specifically, these are north Africa and the U.S. Furthermore, the carbon intensity of various agriculture inputs varies across the country, whether they be kilowatt hours, BTUs or fertilizer. This policy runs a significant risk of creating and exacerbating regional discrepancies due to the varied carbon intensity of available products.
Over 70% of Canadian cereals are exported around the world. It is unclear what impact associated reciprocity would have on our primary production and domestic end products. Certainly, some domestic consumers of some products would be better off, while some exporters of other end products could be worse off. In seeking to realign economic equilibria from existing government intervention, this policy could in fact exacerbate existing economic disequilibria.
I would note the government's efforts through this policy to place value chains on more equal footing with international competitors. However, the outcomes of that effort are far from certain at this time.
Given the uncertainty regarding possible outcomes, Cereals Canada would ask that this policy not move forward until its administrative and economic impacts have been comprehensively studied and addressed by the government.
Thank you for your time. I look forward to any questions you may have.