OFA supports the efforts of CFIA to update and modernize seed regulations with the goal of reducing complexity, strengthening existing rules to further protect producers and consumers and adapting to technical advances and innovation. OFA is encouraged by this next step in modernizing Canada’s current seed regulatory framework, and provides the following feedback:

Variety Registration

• OFA does not support registrant ability to request variety cancellation, as this creates the potential to reduce choice for farmers, and results in producers unable to receive fair returns on deregistered varieties.
• It is critical that CFIA maintains an active role in consulting with producers and other stakeholders to ensure deregistration decisions are informed through adequate public consultation.
• OFA supports CFIA assuming the responsibility of the Form 300 process only if this added responsibility allows CFIA to maintain the expediency and efficiencies currently afforded through the existing approach delivered by Canadian Seed Growers Association (CSGA).
• OFA also supports the Variety Registration Task Team recommendations to harmonize eligibility determination processes and consolidate existing systems into one to register a variety or list a variety as eligible for certification, however, adequate funding is critical for establishing and maintaining the new system and making necessary improvements to the timeliness of CFIA’s variety registration system.

Sampling, Testing and Grading of Seed

• Since seed can be a conduit for the spread of weed seed, OFA recommends that seed imported or sold in Canada be tested by competent individuals to ensure compliance with minimum standards.
• OFA believes unadvertised sales of common seed between farmers should not require testing by accredited laboratories.
• Confidence in the seed system is due in part to the accreditation of graders, ensuring knowledge of the regulatory requirements and confirmation that minimum standards are met, therefore OFA supports measures that ensure producers can continue to trust in the quality of the seed they use.
• OFA notes that further testing is required to ensure seed mixtures clearly identify and communicate the presence of weeds and crop types in each mixture, and that claims regarding the efficacy and performance of such mixtures should also be closely monitored by CFIA to ensure they are not misleading or inaccurate.

Import, Export and Sale of Seed

• OFA recognizes that there is opportunity for non-compliance, confusion and delays with post-clearing of seed, and therefore supports the Import Task Team recommendation that all imported seed be pre-cleared with an exemption of seed imported by an Authorized Importer, with continued ability to pre-clear and post-clear imported seed.
• OFA supports the Import Task Team recommendation that imported small lots of seed for personal use be tested to verify standards for seed purity are met prior to import.
• However, OFA recognizes that there must be an exemption for small seed lots for research purposes to support ongoing small plot tests in Canadian conditions.

Other Concepts

• OFA recognizes value in establishing a stakeholder-led Advisory Committee with representation from across the seed value chain to advise government and co-regulators on strengthening existing processes and contributing to ongoing improvement of Canada’s seed system.
• OFA understands that CSGA’s SeedCert system provides a unique, digital platform that enables real-time oversight of the entire seed crop certification program to support essential regulatory functions through mandatory collection of data.
• OFA believes transparency and access to information on the seed certification system and broader seed program are critical in meeting the needs of diverse commodities with equally diverse information needs.