Thanks for the question.
PMRA is currently in the latter stages of re-evaluating the three classes of neonicotinoids that are registered here in Canada. It's part of their statutory requirement to do so, which we support. We also have concerns, though, that if the European Union bans a product using a hazard-based assessment, it sparks a special review in Canada. Now, each of those three neonicotinoids are undergoing three different reviews at the same time.
Our default position is that the PMRA is the only body that's really capable of making these decisions. It is a very specific science. Either you're working for a crop protection company or you're working at PMRA, or perhaps a university in Canada. It's a very specialized area. We do think that interprovincial trade barriers are a significant issue. We always remind our provincial counterparts that there is in fact a Canadian Free Trade Agreement.
Currently in Ontario, there are the class 12 pesticides. Small seed companies and farmers can use neonicotinoids, but it requires a mountain of paperwork and reporting to get that done. Quebec has introduced a 3A pesticide classification, which is arguably more onerous than Ontario's.
What we see is that the way farmers operate in Manitoba, Alberta and Saskatchewan means that they are at a competitive advantage against farmers operating in Ontario and Quebec, and it's not based on science. There have certainly been a number of interventions from interest groups in Ontario and Quebec, but the Ontario government is looking at the class 12 regulations, I believe, as part of their red tape reductions. It is a concern when the cost of doing business changes from province to province. We believe that all decisions on pesticides should be made federally by Health Canada's PMRA.