Thank you, Mr. Chair.
A regulatory system that does not impose unnecessary burdens is important to our international competitiveness. Your study is very timely, because there are many things facing our industry from abroad. Yet, what we do here in Canada to enable our competitiveness is completely within our control.
I'm here representing the soybean value chain. Soy Canada brings together members from across the value chain, including our seed developers, our farmers, our processors and exporters—from the Atlantic all the way to the Rockies. We are the third most valuable crop in Canada, and we produce world-leading food-grade soybeans to produce soy milk, tofu and miso, as well as commodity beans to process into animal feed, oil for humans and biofuel.
With more than 70% of our production exported, we're very focused on global markets and what our sector needs to be competitive.
I'd like to highlight three areas where action and direction could make a real difference for our sector.
First, we suggest the committee recommend the PMRA consider food security and economic impacts in their regulatory decisions without compromising on health and safety.
This is important, because it would lead to processes and decisions that deliver better outcomes for farmers while upholding health and safety.
There are many voices in the conversation about regulating crop protection products, but ultimately, we need to think about why we need these products in the first place: food security and competitiveness.
In the soybean sector, we're living a real example of how this renewed focus would create real benefits. The recently proposed decision to remove all post-emergent uses of dicamba herbicide on soybeans would take away a valuable tool for our farmers. If food security and economic impact were priorities, the PMRA could consider that this crop protection tool has real value for farmers to control weeds resistant to other herbicides, and there would be an ability to consider that the most valuable and practical time to use this tool is after the soybean crop emerges. This is the very use the proposed decision is set to take away. How was removing the most valuable use pattern considered by the PMRA?
Second is that the committee recommend that the CFIA's ongoing seed regulatory modernization effort must not make processes slower or more expensive.
We're seeing a real risk of the process to list soybean varieties becoming slower and more expensive.
For food grade soybeans, currently the Canadian Seed Growers' Association provides a variety listing service that processes applications within a few days. The CFIA is proposing to take over this process.
We're concerned that this will mean a slower and costlier registration process for our soybeans.
Last is that the committee recommend that the CFIA expedite the rollout of electronic phytosanitary certificates. Canada is an international laggard in electronic documentation, significantly behind our U.S. competitors, who can use these electronic phytosanitary certificates for more than 100 countries. This frustrates our customers and imposes costs on our sector that our competitors just do not have.
For example, consider our soybean exports to Japan, where almost 3,000 paper phytosanitary certificates are required. This creates an extra burden in time and in courier costs. We estimate these costs to be about $1 million per year, just for our soybeans to Japan. There are also added risks and financing costs that come with that.
It's a self-imposed cost in Canada that's hurting our competitiveness and frustrating our customers. It's embarrassing to have our customers repeatedly ask why we can't do this. We were able to send emails 30 years ago, but today we are sending 3,000 paper copies of phytosanitary certificates to Japan.
We must do better, and the committee has an essential role to play in motivating change.
Thank you for your interest in how your political leadership can have a real impact on improving the regulatory environment and our competitiveness.