The objective of the Seed Program Modernization Initiative is to improve the policy,
regulatory and institutional frameworks that govern seed in Canada. To that end, the CFIA
undertook consultations over the last several years to elicit views on concrete proposals
for change and to identify additional issues that deserve consideration.
The document entitled Proposal to Facilitate the Modernization of the Seed
Regulatory Framework included the following elements:
1) a strengthened consultative framework, including the recognition of a national
stakeholder forum and crop specific consultative groups;
2) a more flexible (tiered) registration system;
3) amendments to the contract registration system to strengthen enforcement and compliance
provisions and to increase monitoring capacity through a third party auditing model; and
4) a call for issues requesting input regarding areas for further improvement within the
Seed Program.
What have we done to date?
Since October 2006, the CFIA has consulted on the Proposal to Facilitate the
Modernization of the Seed Regulatory Framework through an online workbook, five
regional seed regulatory workshops and two national meetings. The reports from these
meetings will be posted on the CFIA website in the near future. Shortly thereafter, the CFIA
will be making a second phase Seed Program modernization proposal, including changes to
the placement of crops within the new variety registration framework.
The call for issues included in the Proposal was particularly important for defining
the CFIAs second phase Seed Program modernization proposal and for setting
priorities beyond the planned changes to variety registration. These priorities and other
issues are captured in a draft three to five year strategic action plan that is being
prepared by the CFIA. The Agency plans to release this proposed draft strategic action
plan in the fall of 2007 to seek feedback and to validate the plan with a view to
developing a joint CFIA-stakeholders version that will guide our 2007-2008 workplan
priorities.
What has the initial analysis demonstrated?
Initial analysis of the online consultation and feedback from the regional workshops
and national meetings demonstrates that seed stakeholders are generally supportive of
regulatory changes to facilitate a more flexible (tiered) variety registration system and
a strengthened contract registration system, with some concerns expressed regarding third
party delivery of audits.
Initial analysis of the feedback regarding the proposed strengthened
consultative framework indicates that further analysis of options and a detailed
framework for implementation is required, with funding and recognition issues being the
major considerations.
There were concerns expressed by some groups of a more general nature, around the
themes of variety treadmills , globalization , corporate
control and profits , genetic engineering of plants and impacts of
current seed policy on the viability of organic production. Our initial conclusion is that
these particular concerns are rooted in much larger issues that for the most part go
beyond the scope of the variety registration changes to address.
What is planned for the future?
With respect to the Proposal, we are moving forward as follows:
The CFIA has initiated the regulatory impact assessment process for the creation of a more
flexible tiered registration system. The regulatory impact assessment process is
the starting point for regulatory change.
We have also started the regulatory impact assessment for the proposed changes to contract
registration to increase enforcement and compliance capacity. The proposal to
require third party delivery of audits is currently being assessed in terms of broader CFIA
policy regarding conformity assessment models and their use in the Agency.
Which outstanding issues need to be addressed?
There are a number of outstanding issues that need to be addressed before moving
forward with the proposal to establish/recognize Crop Specific Consultative Groups and a
national stakeholder forum. Examples of outstanding issues include resourcing and the
determination of what degree of recognition is required for this model to function.
This discussion has begun within CFIA as part of the development of a broader CFIA-stakeholder
engagement policy.
This will not, however, prevent us from moving forward with proposals on crop specific
policy and regulatory change. We will be doing this through workshops proposed for
November 2007 and March 2008. This book-end approach is part of the
establishment of a more predictable life cycle model for regulatory and policy change that
respects the Agri-Food Sectors off-season.
In parallel, we will continue to support the National Forum on Seed workplan which we
see as complementary to our own.
On the issue of crop tier placement within a modified variety registration framework,
the consultations over the last 5-6 years have provided us with accumulated insights and
feedback on crop placement preferences that will allow us to put forward an informed crop
placement proposal in the fall. This proposal will build upon the outcome of the March
2007 National Stakeholder workshop. Further input will be sought online and at the
November 2007 workshop.
The November 2007 workshop will also include discussion and validation of the Seed
strategic action plan which, as mentioned earlier, was generated from the call for issues
and related discussions.
For more information on the Seed
Program Modernization Initiative, please visit the CFIA Web site at
www.inspection.gc.ca and click on the Plant keyword on the main page.
