Good afternoon. I'm Ken Whitehurst, executive director of Consumers Council of Canada. The council is a not-for-profit working towards an improved marketplace for consumers in Canada.
Thank you for your invitation.
Canada's consumers face difficulties. They are worried about prices and the supply of goods and services, and they feel manipulated by business and unprotected by governments. They worry about those less fortunate than themselves and the hidden costs of deprivation.
The council's focus will vary from what you've heard so far. Our submission does not seek to pinpoint the causes of food inflation. Let's explore how governments and food retailers can soften the negative impacts of temporary food inflation using regulatory and other tools, and how to prepare for the future.
Canadians are now much more aware of global, national and local food supply risks. Improve the safety, security, diversification and productive capacity of domestic food sources.
Consumers feel gamed every way they shop. Raising food prices by offering less product for a similar price—shrinkflation—is common. Unfortunately, consumers are four times more likely to notice a price increase than a package size decrease. This practice erodes confidence in retailers, producers and government.
Make it easier for Canadians to shop. Mandate unit pricing like other major countries. Quebec is the one province that regulates unit pricing. Start by adopting its rules nationally, and improve and enforce them. Consider our report, “Unit Pricing: Time for a National Approach”.
The council has noticed eroded consumer protection enforcement. Health Canada's and CFIA's comprehensive inspections to detect misrepresentation and substitution are all but gone. Current risk-based enforcement methods are inadequate. Consumers cannot themselves identify food adulteration, short weight, substitution, uninspected foodstuffs, misrepresented origin, non-approved irradiated food, misrepresented retail meat cuts or repackaged food with fudged “packed on” dates. Please protect consumers when they cannot protect themselves, especially with prices rising sharply.
Because every cent counts, ensure price accuracy at checkout. Over 20 years ago, the Competition Bureau worked with retailers to introduce a scanner price accuracy code. Consumers are supposed to be compensated for inaccuracies, but this program relies on consumer vigilance and most don't know it exists. The code is based on a fantasy that expects a consumer accompanied by small children with a cart full of groceries to examine each item scanned and remember the shelf price. If a difference is noticed, they must inform and educate the clerk and sometimes debate with a store manager. The Retail Council of Canada arbitrates disputes. Finally, this does not guarantee the problem will be fixed. Include the code in government surveillance.
Require regulators to be alert to incidents of non-functional slack fill. Section 9 of the Consumer Packaging and Labelling Act prohibits deceiving consumers about the quantity and quality of what's inside a package. Health Canada and the Competition Bureau could jointly administer section 9.
The council told Measurement Canada's consultation on trade measurement that consumers need action to get what they pay for. It recommended consolidating federal responsibility for the accuracy of net quantity declarations on packaged consumer food and general merchandise. Canadian Food Inspection Agency is supposed to ensure net quantity for food products, and the Competition Bureau for general merchandise. Neither agency makes accurate weights and measures an enforcement priority. The bureau has not carried out net quantity inspections for two decades. Measurement Canada inspectors visit retailers to verify scale accuracy. They could also verify net quantity and unit price declarations and price accuracy.
Food insecurity raises the question of who within the federal government represents consumers at the policy table when issues like food inflation and security, or consumer protection and safety arise. The council felt encouraged when, in 2019 and 2020, the Prime Minister mandated three federal agencies to create a Canadian consumer advocate to oversee complaints in the federally regulated telecommunications, transportation and banking sectors. The council supported this and recommended that the advocate promote consumer interest in all sectors. Recent letters don't mention this mandate, but the council learned, through access to information, that Innovation, Science and Economic Development Canada proposed expanding it. Two House of Commons petitions, with signatures from every province and territory, support this. Petitioners await the government's response.
A consumer advocate would provide a centre of expertise for House of Commons committees seeking expert witnesses. The council supports the establishment of an independent federal advocate with the sole function to argue for consumers, support their voices through civil society and stress the relationship of consumers' needs to the decision-making processes within agencies of government.
You've been told that your search for the sources of food price inflation is complex, but these are straightforward measures to show Canadians that Parliament has their backs when they go shopping.