On May 7, 2013 the National Farmers Union issued an action alert asking concerned farmers and allies to submit comments about regulatory changes to Seed Variety Registration.
The notice of public input on Regulations Amending the Seeds Regulations was published in the Canada Gazette Part 1 Vol. 147, No. 10 – March 9, 2013.
Deadline for submissions is May 23, 2013.
All submissions must:
- cite the Canada Gazette, Part 1 and the date of the publication of notice, March 9, 2013 (link above)
- be addressed to:
National Manager, Seed Section,
Canadian Food Inspection Agency
59 Camelot Drive
What are the proposed changes:
- to move registration of soybeans and all forages (including alfalfa) from Part I of Schedule III to Part III of Schedule III under the Seed Regulations and;
- to permit registrants to cancel a variety’s registration without providing any reasons or public notice.
What is the difference between Part I of Schedule III and
Part III of Schedule III?
Under Part I before a new variety is registered it must:
- meet certain merit criteria, ( e.g. perform as well as or better than reference varieties)
- be recommended by a Recommending Committee of experts familiar with the crop
- assessed for performance and disease susceptibility through multi-year field trials at multiple locations.
Under Part III a variety can be registered without field-testing or proof of merit. The registering company can submit basic variety registration information directly to the Canadian Food Inspection Agency (CFIA). CFIA’s role essentially changes to processing paperwork provided by the seed companies.
What are some of the concerns for ecological farmers with the move of soybeans and forages from Part I to Part III?
- the variety registration field trials provide farmers with fair, transparent, multi-year, scientific performance data which is evaluated by an independent committee of experts (the Recommending Committee);
- since forage plantings are expected to produce for several years it is important to have access to reliable information on performance and disease susceptibility of new varieties prior to planting a new variety;
- the change to Part III will place more responsibility (risk) on farmers to decipher the performance claims made by seed sellers;
- the change could allow quicker registration of GM alfalfa.
What are some of the concerns for ecological farmers with the change to allow registrants to cancel a variety’s registration?
Currently, the CFIA suspends a variety’s registration, based on criteria in the Seeds Regulation. The proposed changes will allow the variety’s registrant to cancel the registration without providing reasons or public notice and there is no mechanism in place for another entity to take over the responsibility for the variety to continue to make it available.
At present, farmers can grow, save, re-use and sell older varieties as ‘common seed’ without paying royalties or license fees. The proposed change will provide an incentive for seed companies to de-register varieties before the royalty period (18 years) is over. Farmers may lose access to varieties that work well on ecological and organic farms and to non-GM varieties. The number of varieties available to farmers who grow non-GM crops has declined over the past decade. Allowing seed companies to cancel registrations without cause or explanation will accelerate this trend. In addition, there will be an overall loss of agricultural biodiversity, as older varieties are de-registered.
What can you do?
- submit comments to CFIA at the address above; the Seeds Regulations were implemented to protect the interests of Canadian farmers and consumers. The CFIA should continue to serve the interests of the public, not seed companies;
- note the importance to farmers of multi-year field trials evaluated by an independent Recommending Committee. Rather than eliminating the requirement for these trials, the evaluation by Recommending Committees should be enhanced by including field trials under low-input conditions;
- note the importance of maintaining registration of older varieties which may be more adapted to ecological and organic farms, are not patented GM varieties and contribute to agricultural biodiversity;
- ask for an appeal mechanism which farmers and the public can use in regard to variety registration and de-registration.
For more information:
- The National Farmers Union’s submission to CFIA: http://www.nfu.ca/story/nfu-comments-regulations-amending-seeds-regulations
- The Proposed Regulations: http://canadagazette.gc.ca/rp-pr/p1/2013/2013-03-09/html/reg1-eng.html#reg
- The CFIA’s Regulatory Impact Statement: http://canadagazette.gc.ca/rp-pr/p1/2013/2013-03-09/html/reg1-eng.html#rias