Agriculture committee  Thank you. First of all, on those 35,000 SKUs, we're only talking about a few hundred SKUs out of that vast array of what you'll get in a supermarket that actually deals with this “Product of Canada” issue. So let's drill down now to where this is really relevant. Let's take juice.

Agriculture committee  The problem is that he was talking about jam. Jam is unique. Jam, like meat, is unique. You have to get pre-market approval of that label.

Agriculture committee  Interestingly enough, one of the reasons Americans prefer Canadian jam is that we have different standards for jam. We have to have a higher fruit content. One of the reasons they like it down there is that it's probably a higher-quality jam if it's made in Canada. In going down this road—and this was what I was saying about the “Product of Canada”—be careful that you don't end up having all kinds of unintended consequences, where you're dealing with the quality of what you can call a jam, how much fruit, how much sugar, how much pectin, etc.

Agriculture committee  That's simply because the 51% rule is based on cost, not content. It was never designed for food. It was presumably for something like importing T-shirts from Asia and then putting on some crests or doing some embroidery. If 51% of the costs are incurred here, you can call it “Product of Canada”--rather than the basic T-shirt or the cotton.

Agriculture committee  We can talk after this.

Agriculture committee  I'll say it again. I'm not saying that the way we do food labelling is acceptable. It is awful. It significantly undermines innovation in Canada. It significantly undermines competitiveness, and it significantly hurts investment in the food industry. I said that if you want to make a difference on the “Product of Canada” issue....

Agriculture committee  That problem was not with “Product of Canada”.

Agriculture committee  I didn't argue for no changes; I argued for no regulatory change. If you recommend regulatory change to the Government of Canada, you won't see it for a couple of years from now, minimum. You won't have had an impact on Canadian consumers, because the regulatory change process is so slow and sporadic.

Agriculture committee  Sure. You don't have all morning, but I could spend all morning, because I do this for a living--help people work their way through this maze. Maybe I'll build on the one the gentleman just mentioned. The real solution to that problem is to not have pre-label approval for jams.

Agriculture committee  I remember I used to use the number 30,000 to 40,000, so yes, 35,000 SKUs. There are 99.9% of those that are labelled properly as far as “Product of Canada” is concerned, so let's keep this in perspective, ladies and gentlemen. My second point is that we can easily change your recommendation to help the Food Inspection Agency do this.

Agriculture committee  I'm here today in my own personal capacity at the invitation of the clerk, so I'm not representing anyone. I assume that part of the reason I'm here is because my primary practice in law is agriculture and food law. I write widely on issues of food law, and I'm a former president of the Canadian Food Inspection Agency.