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What we heard: Public consultation on Framing competitiveness and innovation for success

Executive summary

The Canadian Food Inspection Agency (CFIA) has a mandate to safeguard food, animals, plants and support international trade and market access. As such, it plays an essential role in facilitating competitiveness, innovation and inclusive economic growth in the agriculture and agri-food sector.

Through feedback gathered from the 2018 Economic Strategy Tables, the 2019 Agri-food and Aquaculture Regulatory Review Roadmap, and the Standing Senate Committee on Agriculture and Forestry's 2020 report: Made in Canada: Growing Canada's Value-Added Food Sector, stakeholders have expressed the need for CFIA and other departments to consider the impacts of regulations and regulatory decisions on sector competitiveness and innovation.

In addition, the new challenges of the COVID-19 pandemic have shown us that more flexible, agile regulations could help facilitate interprovincial trade and economic recovery in the sector, while building resiliency and enhancing preparedness for the future.

Given this context, CFIA held a 60-day public consultation from January 18, 2021 to March 19, 2021 on Framing competitiveness and innovation for success to examine how to further strengthen its regulations, programs, and services to help enable competitiveness and innovation in the agriculture and agri-food sector.

This report sets out the 5 thematic areas that have been identified by stakeholders for future investment by the agency.

  1. International alignment and harmonization: Increasing alignment of regulations and programs to facilitate market access and supporting innovators to compete globally
  2. Domestic coordination: Working with all levels of government to address interprovincial trade barriers and achieve domestic equivalency, employ a whole of government approach to regulation and promote and protect the Canadian brand
  3. Program and service delivery: Reducing administrative delays, digitizing services, collaborating with trusted third parties to deliver programs and clear, consistent compliance and enforcement
  4. Pre-market requirements and approvals for new/ novel products: Clarifying and streamlining pre-market regulatory requirements, and prioritization of approvals of new/novel products in Canada
  5. Tailored programming for small, medium, and Indigenous businesses: Supporting Canada's small and medium-sized enterprises (SMEs) and developing culturally competent approaches to advance reconciliation and support Indigenous businesses

Consultation purpose and methodology

Objective

To meet this objective, CFIA asked stakeholders the following 4 questions:

  1. Where do you see the greatest need for the CFIA to examine cumulative economic impact of incremental regulatory requirements on the agriculture and agri-food sector?
  2. Where do you see that the CFIA would best support the agriculture and agri-food sector in gaining market access?
  3. To what extent do you support prioritization of regulatory activities to facilitate market access of new/novel products given the CFIA mandate and the need to promote a level playing field for regulated parties?
  4. How do you see the CFIA positioning itself to support small and medium-sized enterprises (SMEs) and Indigenous peoples with agriculture operations?

Who we consulted

What we did

The CFIA reached out to an estimated 3,000 stakeholders to request their feedback through the following channels:

Results

During the 60-day consultation between January 18 and March 19, 2021, the CFIA received:

The feedback summarized in this report was gathered from all of these sources, in addition to comments received at webinars. It appears in no particular order, and is presented as it was received from stakeholders to minimize misinterpretation.

Main themes

5 main themes emerged from feedback received during this consultation, which is further organized into sub-themes. These are displayed below, and are discussed in detail in the next 5 sections.

Theme 1 – International alignment and harmonization

Stakeholders were clear: Canada's regulatory system for agricultural and agri-food products must be better harmonized with those of key trading partners, including the elimination of non-tariff trade barriers.

Deepening international partnerships to promote science-based decision-making and alignment of standards, procedures, and enforcement was also highlighted as the key to gaining market access.

Increase alignment of regulations and programming to facilitate international market access

The regulatory environment in different jurisdictions and related costs of compliance have an impact on business decisions, especially for small and medium-sized enterprises (SMEs).

There was a strong push to better align and coordinate Canadian requirements with those of key trading partners and to more closely consider the international landscape, such as using globally-accepted requirements and standards when making new regulations.

Stakeholders recommended the following distinct areas of focus to promote alignment with international regulations and programming and to help the Canadian agriculture and agri-food sector to gain market access.

Agreements and technical cooperation
Regulatory harmonization: general

"Increasing market access includes aligning to other countries for both exported and imported products, specifically with key trading partners. This provides increased confidence throughout the food industry to sell goods with ease in either jurisdiction and helps minimize product development costs."

an industry association
Regulatory harmonization: specific requirements

The following, specific areas were highlighted as priorities for harmonization:

Regulatory approvals
Program delivery

Support innovators to compete globally

Many comments spoke about approval processes for new plant breeding technologies and new/novel feed ingredients. We heard that our approval processes are not supporting innovators to keep pace in these highly competitive areas with competitors around the world.

For example, asymmetrical approvals of new/novel products, whereby these products are approved in other jurisdictions but not in Canada, can lead to trade barriers and increased costs for Canadian businesses.

Improving partnerships to address these barriers and accepting decisions made by trusted foreign regulators were mentioned as key ways to promote innovation, growth and competitiveness.

Suggestions to further facilitate international market access for new/novel products included the following:

These suggestions focus on international alignment, however we received significant comments on all aspects of pre-market approvals. Additional feedback on this topic is summarized in Theme 4.

"Canada is the only country in the world to subject conventional plant breeding to the same type of pre-market safety assessments that other countries apply only to genetically-modified organisms. Not only does this lack of alignment place Canadian innovators at a disadvantage, it makes it more difficult for Canada to partner with like-minded countries to advocate for global regulatory alignment in support of predictable trade."

respondent from a provincial government

Theme 2 – Domestic coordination

To foster a clear, predictable regulatory environment for industry that is conducive to growth, further coordination across all levels of government and between federal departments is needed.

Feedback received consistently emphasized the importance of addressing interprovincial trade barriers, reducing duplication between federal, provincial and territorial (FPT) requirements, and working together to highlight the quality and value of Canadian-made products.

Work with all levels of government to address interprovincial trade barriers and achieve domestic equivalency

There were strong calls for federal, provincial and territorial governments to:

Comments emphasized eliminating duplication and redundancies, ensuring equivalence of foreign standards against Canadian standards, and working together when developing and implementing policies and regulations to reduce the burden on industry.

More specifically:

"Domestic food producers are held to a higher standard, yet have to compete against food produced in jurisdictions that have lower regulatory burdens and that have access to lower input costs and inputs not available in Canada."

a consumer association

Employ a whole of government approach to regulation

We heard that fully enabling greater competitiveness, innovation, and inclusive economic growth in the agriculture and agri-food sector requires greater coordination amongst numerous federal departments and agencies that regulate and deliver programs and services to the sector.

Emphasis was placed on taking a whole of government approach to enhance collaboration with other regulators and departments when developing new requirements.

Specific suggestions are as follows:

Coordination at the federal level

"The CFIA needs to work across government to ensure that regulatory requirements being imposed are consistent and fall within similar timelines."

a manufacturer
Coordination within the federal agriculture portfolio
Coordination between CFIA and Health Canada

"To reduce the burden and associated costs, the timeframe to comply with new regulations should be appropriate not only in duration but must also minimize disruption to the supply chain. Both considerations are essential to reducing burden on industry..."

an industry association

Promote products made in Canada and protect the Canadian brand

There were calls for more action to promote and protect Canada's high food safety standards and support increased capacity for processing more products domestically to facilitate market access. Suggestions received were as follows.

"… [CFIA should] collaborate with other agencies and highlight the superior quality (from farm to table) as well as the nutritional value of Canadian grown grains, oilseeds and crops."

a small business

Theme 3 – Program and service delivery

There is an urgent need to continue to improve CFIA's services and program delivery, including increasing responsiveness, digitization, streamlining program delivery and enhancing the consistency of compliance and enforcement.

For example, stakeholders clearly stated that the CFIA occasionally takes several weeks or months to respond to their questions. This delay acts as a deterrent, and was cited as a key cost that impacted business opportunities both within Canada and internationally.

In addition, increased momentum to adopt more modern business and information management practices caused by the COVID-19 pandemic must be sustained, or increased. CFIA has been called upon to continue to implement electronic platforms to increase the accessibility and transparency of its processes.

Reduce administrative delays

We heard about the need to reduce administrative delays linked to manual, paper-based processes, improve response times to questions from stakeholders, and:

"One of my own requests for clarification took eleven months for a response, and the response was "no, we don't do that", causing additional consternation."

a member of academia

Digitize services

There was strong support for CFIA to continue to increase its offering of online services, especially digital delivery of documents required to gain market access. More specifically:

"Paper hard copy phytosanitary certificates are still provided to seed companies, and the receipt of them by the seed company is still manual."

an industry association

Collaborate with trusted third parties to deliver programs and services

Many comments requested more clarity around private certifications, trusted trader programs, alternative service delivery, and their resulting impacts on the frequency of CFIA oversight.

Specific suggestions are to:

Clear and consistent compliance and enforcement

Several comments emphasized the need for CFIA to address existing issues related to consistent and fair compliance and enforcement. We received the following recommendations:

Theme 4 – Pre-market requirements and approval processes

Pre-market requirements and approvals, including prioritization of approvals for new/novel products, were areas highlighted as requiring immediate attention.

Significant feedback received underscored the need to further streamline and clarify regulatory requirements, seek consistency with international partners, and create a clearer, more predictable regulatory environment to support the research and development of new/novel products.

Improving service standards and predictability

Regulators need to provide certainty to industry on their service standards for new/novel products and work to clarify and streamline burdensome pre-market regulatory requirements.

To achieve this, we heard there is a need to:

Prioritizing approvals of new/novel products in Canada

Stakeholders said that approval processes, especially for new plant products and new/novel feed ingredients, need to keep pace with the marketplace and investments are needed to speed up these processes. They mentioned that in their view, the COVID-19 pandemic has made existing issues with slow approvals even more difficult.

We asked whether stakeholders would support prioritizing approvals of certain new/novel products that CFIA regulates, while considering the need to maintain a level playing field for industry.

Support for regulatory prioritization

In general, we learned that there is moderate support for prioritization.

Specific areas mentioned where it could be considered were:

In addition to support: caution

While there were general, strong expressions of support for prioritization of new/novel products, especially those that are registered and have a history of safe use in other countries, some stakeholders cautioned that market access for existing products should remain a priority.

Additional concerns were raised that prioritizing new/novel products could mean that genetically modified organisms (GMOs), Clustered Regularly Interspaced Short Palindromic Repeats (CRISPR) gene editing technology, and other targeted breeding techniques would be prioritized over traditional methods of food production.

If prioritization is pursued, we heard it is important to continue to:

Levelling the playing field

Stakeholders expressed the need for further engagement to confirm what the third consultation question meant by a "level playing field"; noting that in their view, a level playing field means that regulatory prioritization efforts should:

Development of a mutually-beneficial approach would ideally be undertaken as part of open, collaborative discussions between the CFIA and regulated parties on criteria for prioritizing new products and developing a mutually-accepted definition of a "level playing field."

Theme 5 – Tailored supports for small, medium-sized, and Indigenous businesses

Throughout the consultation, stakeholders representing small and medium-sized enterprises (SMEs) frequently expressed views that they greatly contribute to innovation in the agriculture and agri-food sector but face challenges due to their resources, which are more restricted than larger producers. Therefore, SMEs need more engagement, guidance, education, and support from the CFIA and key exporting partners to better understand regulations and trade policies.

Supporting Canada's small and medium-sized enterprises (SMEs)

We heard the need for CFIA to provide more guidance to industry to help clarify and improve understanding on various regulatory requirements and programs, and engage meaningfully with stakeholders to find new ways to reduce the regulatory burden on industry.

There was strong support for helping SMEs with understanding trade, regulations, and regulatory requirements as they often lack in-house resources and expertise. Ensuring that they have a voice during CFIA consultations is also important in order to reflect their needs in the agency's programs and services.

We heard that providing this support and increasing services for SMEs both online and from CFIA offices across Canada would significantly help reduce barriers to growth and innovation for these companies.

Specific suggestions were to:

"Be an ally for small companies on the world stage. This can be done through transparency and an effort to build mutual trust with trading partners and consumers."

an industry association

Culturally competent approaches to advance reconciliation and support Indigenous businesses

Stakeholders mentioned that CFIA needs to improve outreach and engagement with Indigenous peoples, many of which face unique barriers and are relatively new to commercial agriculture.

To ensure proper understanding, it was emphasized that this engagement would need to be conducted at the community level, and approaches should be co-developed with Indigenous communities, businesses and entrepreneurs.

Specific recommendations received are below, and are grouped under 2 main areas: creating opportunity through reconciliation, and providing culturally-competent support for Indigenous businesses.

Creating opportunity through reconciliation
Culturally-competent support for Indigenous businesses

"Working within risk frameworks takes "Two Eyed Seeing", understanding that traditional knowledge and traditional food gathering methods can interface in a safe and compliant way when proper dialogue and understanding takes place…"

a member of academia

Participant demographics

Survey participation by stakeholder profile
Flowchart - Survey participation by stakeholder profile. Description follows.

Figure 1. Bar chart showing participation in the online survey by stakeholder profile. The graph shows that 2/3rd of online participants who completed the demographics questionnaire identified as businesses and industry associations.

Description for Survey participation by stakeholder profile
Stakeholder percentage
Industry association 34.9%
Business 30.2%
Member of the general public 18.12%
Government 6.04%
Academia 4.03%
NGO 2.68%
Other 4.03%

n=149 (number of responses to the question)

Survey participation by business type
Flowchart - Survey participation by business type. Description follows.

Figure 2. Bar chart showing business type of participants who identified as representing a business. Nearly half identified as agricultural producers.

Description for Survey participation by business type
Business type percentage
Agricultural producer 46.67%
Manufacturer 28.89%
Processor 26.67%
Organic sector 17.78%
Other 15.56%
Exporter 15.56%
Retailer 11.11%
Importer 11.11%
Farm organization 8.89%
Restaurant/Food service 6.67%
Seed company 6.67%
Commodity or goods transportation 2.22%
Crop marketer or handler 2.22%

n=90 (number of responses to the question)

Survey participation by geographical location
Flowchart - Survey participation by geographical location. Description follows.

Figure 3. Bar chart showing participation in the online survey by province or territory.

Description for Survey participation by geographical location
Geographical location percentage
Ontario 50.34%
Alberta 19.46%
British Columbia 8.05%
Manitoba 7.38%
Other 4.7%
Saskatchewan 3.36%
Quebec 2.68%
Nova Scotia 1.34%
New Brunswick 1.34%
Yukon 0.67%
Prince Edward Island 0.67%
Nunavut 0%
Northwest Territories 0%
Newfoundland and Labrador 0%

n=149 (number of responses to the question)

Business survey participants by number of employees
Flowchart - Business survey participants by number of employees. Description follows.

Figure 4. Bar chart showing number of employees of participants who identified as representing a business. Almost 80% of participants who answered this question represented a small or medium-sized enterprise (SME).

Description for Business survey participants by number of employees
Number of employees percentage
1 (self-employed) 8.89%
2 to 4 employees 17.78%
5 to 10 employees 15.56%
11 to 99 employees 26.67%
100 to 499 employees 8.89%
500 employees or more 17.78%
Don't know 0%
Prefer not to say 2.22%
Not applicable 2.22%

n=45 (number of responses to the question)

Next steps

All feedback summarized in this report will be analyzed and used to inform future efforts to further enable competitiveness and innovation in the agriculture and agri-food sector.

Thank you

The CFIA would like to thank all participants who contributed their time, resources and insights to this process. Your contributions during the current COVID-19 pandemic, a time of unprecedented hardship for many Canadians and Indigenous peoples with connections to the Agriculture and Agri-Food industry, is recognized and appreciated. With your assistance, the CFIA is committed to helping build an even stronger, more competitive, and more resilient sector that will continue to serve Canadians and stakeholders internationally.

Feedback about this report

Write us at: cfia.programpolicy-politiqueprogramme.acia@inspection.gc.ca

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