Annex B: Policy Paper Proposals to Modernize Canada's Seed Regulatory Framework (Part II: Seed Potatoes)

(December 6, 2025)

On this page

• Section 1: Introduction and purpose of the document
• Section 2: Description of proposals by theme
  • Section 2.1: Reducing red-tape and administrative burden
  • Section 2.2: Supporting the well-being of industry
  • Section 2.3: Protecting farmers, consumers, markets and the environment
• Section 3: Table of proposals by theme

Section 1: Introduction and purpose of the document

Potatoes represent Canada's fifth largest primary agriculture crop contributing approximately $2 billion in farm cash receipts in 2023. In the same year, Canadian potato growers produced approximately 5.8 million metric tons of potatoes making it the largest vegetable crop grown in Canada. The objective of Canada's Seed Potato Certification Program is to supply Canadian growers of seed, table stock and processing potatoes with certified seed which is of high varietal purity.

The need for a Seed Potato Certification Program (SPCP) first emerged in 1914 following the discovery of powdery scab, a fungal disease that creates leasing with pustules containing powdery spores on potatoes. By 1920, certification programs had been established in eastern Canada and they were in effect across all provinces by 1924. Today, the legal foundation of the SPCP is set out in the Seeds Regulations (the regulations), Part II which include:

• the requirements for seed potato classes
• disease tolerances
• grade standards
• tuber standards
• crop inspection requirements
• conditions for the shipment of seed potatoes

The requirements to register a new variety are contained in Part III of the Seeds Regulations.

As part of the Agri-food and aquaculture targeted regulatory review roadmap, the Canadian Food Inspection Agency (CFIA) has undertaken a seed regulatory modernization initiative to review the Seeds Regulations, Parts I, II, III and IV. Given the unique disease and pest challenges in the seed potato sector, the CFIA carried out a separate pre-consultation and engagement process focussed on Parts II and III. While a separate consultation process for seed, Future-proofing Canada's Seeds Regulations for a stronger tomorrow – Proposals to modernize Canada's seed regulatory framework, was undertaken to review Parts I, III, IV and Schedule III.

In 2019, the review process for Parts II and III as related to seed potatoes started with the establishment of an overarching working group comprising the CFIA, the Canadian Potato Council, provincial industry representatives and seed potato growers. To support the review process, 8 task teams were formed (CFIA, potato growers and industry associates) to examine the regulations and the SPCP. The CFIA acknowledges and appreciates the dedication and contributions of industry representatives and other stakeholders who actively participated in this multi-year consultation process.

In February 2025, industry members from the working group submitted an independently prepared set of recommendations to the CFIA. The submission aimed to:

• enhance industry practices
• improve disease management
• streamline processes
• ensure the continued competitiveness of Canada's seed potato sector

In total, 30 recommendations were provided, grouped into 5 key areas:

• potato certification (16)
• variety registration (6)
• grading (4)
• field inspection (3)
• traceability (1)

In parallel with the work conducted by the working group and task teams, in 2024, CFIA undertook a full internal program review of the SPCP, including a detailed cost assessment. This review identified a series of proposed changes aimed at establishing a consistent national program, supporting new digital service, enhancing enforcement tools and strengthening biosecurity measures. The CFIA presented these proposed changes during 2 in-person meetings held with industry stakeholders; the first in Quebec City in March 2025 and the second in Ottawa in August 2025.

The CFIA is pleased to present this policy paper, which outlines the CFIA's recommended changes for seed potato requirements in Part II and III of the regulations. The 14 proposals herein were developed through:

• a detailed review of the industry recommendations
• feedback obtained from the working group
• task teams and the outcome of the CFIA's internal program review

The policy paper is structured into 3 themes and outlines how the CFIA's proposed policy decisions will aim to:

• 1) reduce red-tape and administrative burden (2 proposals)
• 2) support the well-being of industry (5 proposals)
• 3) protect farmers, consumers, markets and the environment (7 proposals)

The proposals are described under themes in section 2. The table in section 3 provides additional details and presents current as well as anticipated future states of each proposal.

The CFIA is seeking feedback on the proposed decisions outlined in this document. All comments received on these proposals will inform the next steps in the seed regulatory modernization process.

Your feedback on these policy decisions is most appreciated.

Section 2: Description of proposals by theme

2.1: Reducing red-tape and administrative burden

The CFIA is committed to:

• reducing red tape and modernizing its regulatory system to better serve Canadians
• support innovation
• strengthen the competitiveness of the agriculture and agri-food sector

As part of its review, the CFIA is proposing changes aimed to:

• simplify the rules governing seed potato production
• reduce administrative burden
• provide stakeholders with greater clarity and flexibility so that businesses can innovate
• adapt more easily to changing market conditions and find efficiencies

2.1.1 Reducing administrative burden through incorporation by reference

The CFIA is proposing to incorporate by reference several standards to be better able to respond to future innovation and to reduce administrative burden.

Incorporating a document by reference allows the information contained in the incorporated document to be considered part of the regulations and enables the text of the document to be amended following consultation. This removes the need to go through the Governor in Council regulatory amendment process. This means that standards could be reviewed by the CFIA with the help of appropriate subject matter experts to simplify and revise them within a shorter timeframe than could be achieved if the standards were written directly in the regulations.

Consultations on proposed changes would be consistent with CFIA's incorporation by reference policy and the Treasury Board of Canada Secretariat's guide to incorporation by reference in federal regulations to ensure transparency and opportunity to seek feedback.

In support of several industry recommendations, the CFIA will incorporate by reference the following technical standards into Part II of the Seeds Regulations:

• seed potato class tables, including breeders' selection
• tuber grade sizes
• tuber standards tables

These technical standards would be maintained in a separate document, to be updated by the CFIA as needed, following stakeholder consultation and based on a clear rationale and consensus. Guidance on amending incorporated documents, including consultation processes, would be developed and made available for stakeholder input prior to implementation.

Consistent with recommendations by industry, the descriptions for seed classes nomenclature (Elite based system) will remain in Part II of the regulations and the certification documents used for nuclear stock potatoes (tissue culture plantlets and mini tubers) will be aligned closely with those used for field-grown seed classes to improve clarity.

As part of the recommendations related to Future-proofing Canada's Seeds Regulations for a stronger tomorrow, CFIA will also incorporate by reference the list of crop types subject to variety registration (Schedule III), in which seed potatoes are included.

2.1.2 Improving services and service standards by streamlining processes, using digitalization and third-party service providers

The CFIA is committed to finding efficiencies and improving services and service standards, as these are crucial for businesses to succeed and meet market demands. This includes:

• streamlining inefficient or complex processes
• reducing excessive paperwork and forms
• increasing the use of digital tools and alternative service delivery models to make it easier for businesses to comply with regulatory requirements

This approach would ensure that regulations continue to support a competitive and productive economy. In alignment with industry recommendations and several proposed changes by the CFIA, the Seeds Regulations will be amended to:

• enable the use of new technologies to support disease and virus identification (once verified and approved for use) and recognize the use of new technologies to support product traceability, such as QR Codes or bar codes
• remove prescriptive operational guidance that should remain at the discretion of the grower (for example row spacing and general caretaking practices)
• transition toward a fully digital system, Digital Service Delivery Platform, including digital CFIA forms and self-issuance of shipping documentation, such as record of bulk movement documents, application for crop inspection, permits to repack seed potatoes
• authorize growers to print their own seed potato tags or to transition to a single third-party service provider for tag printing; and permit the printing of tag information for product identification and traceability on small bags intended for retail sales

Under the new system, growers will either be licensed to print their own tags or be required to obtain them from an approved supplier. The CFIA will maintain oversight by verifying proper tag use and formatting during facility inspections.

The modernization of tag printing is intended to:

• eliminate outdated printing technologies
• reduce wait times
• enable CFIA inspectors to focus on core plant health activities such as verifying and enforcing compliance

To further reduce the complexity of tag printing, the CFIA will reduce the number of tag formats from 4 (Nuclear, Elite, Foundation and Certified) to 1 tag (white) while maintaining the same product identity and traceability information.

2.2: Supporting the well-being of industry

The Government of Canada is committed to supporting the well-being of industry by fostering a competitive, innovative and sustainable business environment.

The CFIA is seeking to:

• reduce barriers to growth
• strengthen resilience
• ensure that Canadian industries remain well-positioned to compete in domestic and international markets

2.2.1 Maintaining the CFIA potato variety registration system

The variety registration system, outlined in Part III of the regulations, is designed to:

• verify that varieties of major agricultural crops are fairly and accurately represented in the marketplace
• verify that information related to their identity is available to regulators to prevent fraud and to protect consumers
• facilitate seed certification
• support international trade
• enables the tracing of varieties in commerce

The movement of registered seed potatoes and garden variety seed potatoes from a seed potato farm requires product identity and traceability information for recertification (for example seed potato tags or records of bulk movement). These potatoes will be considered certified seed potatoes following the issuance of a crop certificate indicating that the seed potatoes have met all the standards of the class.

Making variety registration decisions in a timely manner is critical to getting new varieties to market faster. In response to this need, in 2009, seed potatoes were added to Schedule III to simplify registration requirements. Crop types listed on Schedule III do not require a recommendation from the recommending committees or Canadian merit testing data. The mandatory grow-out and evaluation steps were eliminated, reducing the burden on applicants and improving the timeliness of submissions. Industry has proposed several recommendations to further streamline and clarify the registration and deregistration process, including a transition to a simplified registry:

• A review of the current variety registration process used for Schedule III crop types and the proposed seed potato registry system was conducted by the CFIA. The 2 processes would operate in parallel, with the same registration information collected by the CFIA Variety Registration Office:
  • contact details
  • pedigree
  • variety description
  • digital images
  • name verification

Since the existing system has demonstrated flexibility and adaptability to industry needs and has proven to be efficient, the current variety registration system will be maintained. Once a variety has been registered, it will be maintained on the database of varieties registered in Canada. The registrant will retain the right to register, cancel or transfer their varieties registration to another entity. With incorporation by reference of Schedule III, the potato value-chain could decide to eventually exist variety registration altogether. With the use of incorporation by reference, the process is more agile to achieving the end-state outcome.

• The CFIA is supportive of the future use of molecular evidence for distinctness of varieties to complement the traditional information used for this purpose and is examining ways to expedite variety registration decisions for Part III of Schedule III crop types when the variety has already been recognized in a foreign jurisdiction.
  While these initiatives do not require a regulatory amendment, they could further streamline the decision-making process and reduce administrative burden for applicants.
• The regulations will be amended to clarify the requirements governing the movement of unregistered seed potato varieties.
  A Certification of Authorization will continue to be required for the purposes of multiplication and evaluation; however, as proposed by industry, the number of permitted generations will be limited to 4. Shipments of unregistered seed potatoes will not be accompanied by seed potato tags or records of bulk movement. However, a letter of authorization from the breeder or the CFIA will be required during the application process for the Certification of Authorization to be issued. A seed potato lot of an unregistered variety grown in the field may only be recertified for a maximum of 4 field generations. If the lot meets the certification requirements, the fourth generation will be deemed Certified class seed potatoes to prevent further recertification.

2.2.2 Removing Total Glycoalkaloid (TGA) testing requirement in potato variety registration

As part of the variety registration process, applicants are required to submit a Description of Variety for Potato form, which must include the results of Total Glycoalkaloid (TGA) testing. The analysis should be conducted by a laboratory accredited by the Standards Council of Canada using the testing methodology identified by Health Canada. TGAs are naturally occurring compounds present in all potato varieties, with levels influenced by factors such as:

• cultivar type
• storage conditions
• physical damage

The Canadian industry recommended removing the requirement for TGA testing as part of the potato variety registration application.

• This change will not require a regulatory amendment.
  The application process will be amended by the CFIA to remove the TGA testing requirement from the application form

Under Part II of the regulations, the intended purpose of seed potatoes is for planting and for recertification within a seed potato farm unit and not for the purpose of safety. Therefore, removing this requirement during the application is not required. However, the Health Canada food standards and guidance to minimize exposure to TGA in potatoes intended for consumption will remain in effect, as will any existing animal feed requirements.

2.2.3 Streamlining requirements for tuber grade standards

The Part II of the regulations provides standards for tuber grade size as well as disease and defect standards for tubers. The grade size is prescribed as the minimum and maximum tuber size based on physical measurements, whereas the disease tolerances for scab and Rhizoctonia are expressed as the percentage of tubers in a lot showing symptoms of disease. These standards ensure that growers receive seed potatoes that are:

• high quality
• healthy
• uniform
• safeguarding the integrity of Canada's seed standards

Canadian industry recommended 2 changes related to these standards to allow more flexibility:

• physical measurement remains the most practical and widely accepted method due to its simplicity and low cost and the regulations already permit buyer/seller agreements to deviate from prescribed tuber sizes. The CFIA will amend the regulations to provide an allowance for weight-based sizing within buyer/seller agreements. In such cases, buyers and sellers will be responsible for documenting their sizing process within a preventive control program. They will also be required to provide a certified scale, along with calibration records, for use by inspectors in resolving potential disputes, ensuring accountability without adding regulatory complexity.
• tuber symptoms such as scab and Rhizoctonia do not progress after harvest or during storage. The CFIA will amend the Standards for Tubers section of Part II of the regulations to expand the provisions for buyer/seller agreements, allowing adjustments to the percentage of disease tolerances, if seed quality and reliability are not compromised. The current grading tolerances will remain in effect, but the use of buyer/seller agreements will provide some flexibility for growers who wish to purchase seed potato tubers with higher than the prescribed disease tolerances.

2.2.4 Supporting niche markets through variety registration exemptions for garden varieties

All Schedule III crop types, including tubers from seed potatoes, must be registered to be sold in Canada for commercial purposes; this includes garden variety (GV) seed potatoes sold in the marketplace. Stakeholders have highlighted the need to better accommodate garden seed potato varieties, which tend not to be registered, but serve niche markets and contribute to biodiversity and food security.

The CFIA has maintained a long-standing exemption from registration (Policy D-98-04) for GV, which are non-commercial seed potatoes that are typically grown by home gardeners and small-scale producers. These varieties are often older, unregistered cultivars with limited commercial value, but significant ecological, nutritional and cultural importance.

• To support niche market development and maintain regulatory clarity, the CFIA will define GV potato varieties in Part II of the regulations to formalize this exemption.
  This will ensure their continued availability while maintaining disease-free standards. This approach supports stakeholder recommendations and is aligned with the CFIA's commitment to:
  • enable innovation
  • reduce regulatory burden
  • preserve Canada's agricultural diversity

2.2.5 Supporting farmer's choice to access the seeds/varieties they want

True Potato Seed (TPS) refers to the botanical seeds produced by the potato plant, which are found within the small, tomato-like berries that develop on the plant after flowering. It provides an alternative means of propagation to the more traditional method of vegetative propagation. TPS has traditionally not been popular as a production method due to its high genetic diversity, which can lead to non-uniform crops in terms of tuber shape, yield and dependability. However, industry has advocated that TPS does continue to offer several potential benefits:

• it is naturally free of most seed-borne pathogens of commercial concern, including many quarantine pests
• it is much lighter than tubers, reducing costs associated with transport, storage, distribution and trade

Part II of the regulations will be amended to:

• provide a formal definition of TPS
• establish national disease testing standards
• implement certification protocols through approved laboratory testing

These changes will support its domestic use and enable future trade harmonization with other markets, such as the United States.

2.3: Protecting farmers, consumers, markets and the environment

Under Part II of the Seeds Regulations, seed potatoes must meet the following while minimizing the risk of pest and disease transmission through seed:

• established standards for identity
• varietal purity
• quality

These objectives are achieved through robust regulatory oversight, including:

• field inspections
• laboratory testing
• certification systems that form the foundation of the Canadian Seed Potato Certification Program

While upholding the integrity and sustainability of Canada's potato production system, it is through these measures that the CFIA safeguards:

• seed potato producers
• consumers
• markets

CFIA is committed to building a regulatory system that is:

• modern
• responsive
• outcome-based

This system aims to:

• simplifies rules
• reduces administrative burden
• provides stakeholders with greater clarity and flexibility

2.3.1 Licensing of seed potato growers and specialized operators

CFIA is proposing to use the licensing provisions under the Seeds Act to establish a new regulatory framework for seed establishments and operators. Licensing has proven effective in providing growers with confidence that the seed they obtain is:

• of high quality
• true to variety
• compliant with regulatory standards

Building on the added value of the Seed Potato Tuber Quality Management Program, the CFIA is proposing to expand this program to include nuclear stock producers, seed potato growers and operators of specialized services such as:

• custom seed cutting
• off-farm potato storage
• seed potato repacking, to reflect changing operational and business practices in Canada

The following changes would strengthen product identification, traceability and consistency across the national certification program, while creating a level playing field for all participants:

• Part II of the regulations will be amended to introduce terms and conditions to establish standards for operations.
  Growers and operators will be required to develop and implement preventive control programs (PCPs) in alignment with the terms of their licence. This will enable compliance with regulatory standards through documented procedures, which will be verified by regular CFIA audits.
• these changes would enable the implementation of several industry recommendations and CFIA proposals, including:
  • self-issuance of records of bulk movement
  • printing of seed potato tags
  • enabling a digital system to improve on-farm logistics
  • accommodations for buyer-seller agreements on seed grade specifications
  • the use of new technologies such as optical graders, printing of certification details on small bags for retail sales
  • documenting alternatives to using blank rows to prevent varietal mixtures
• terms and conditions would include a domestic program to support specialization in key service areas, including:
  • custom seed cutting
  • off-farm potato storage
  • seed potato repacking

  This would be achieved through the implementation of PCPs under a licensing agreement, establishing rigour in sanitary practices, product identification and traceability activities. These changes would enable independent operators to participate in the seed potato sector without the requirement to become a seed potato grower or to maintain a minimum planting acreage.

• compliance and enforcement provisions would be scaled to risk, ensuring proportionate responses to non-disease-related infractions and minimizing unnecessary disruptions to certification.

2.3.2 Strengthening the management of Bacterial Ring Rot (BRR) and Potato Spindle Tuber Viroid (PSTVd)

The CFIA and the Canadian potato industry agree on the importance of maintaining a zero-tolerance policy for Bacterial Ring Rot (BRR) and Potato Spindle Tuber Viroid (PSTVd), 2 of the most serious pests affecting potato production. These pathogens have long been regulated in Canada due to their potential to cause significant economic and agronomic harm. All seed potato classes, from nuclear stock to certified, must meet this zero-tolerance standard to ensure the health and integrity of Canada's potato sector. The following changes would further strengthen the mitigation of these pests in seed potato production:

• Part II of the regulations will be amended to require additional BRR testing for all Elite 1 class seed potato lots prior to movement from a farm unit, using CFIA-approved laboratories.
  This measure would enhance confidence in Canadian seed potatoes and further prevent the spread of BRR between farm units.
• Part II of the regulations will be amended to clarify the definition of a certified seed potato grower to ensure that only those meeting the standards are officially recognized. Entry requirements for new seed potato growers will be reinforced, including:
  • mandatory testing
  • documentation
  • sanitation protocols to prevent the introduction of BRR

2.3.3 Post-harvest testing (PHT) remains voluntary under federal regulations

Under the current federal regulations, there are no standards for post-harvest disease testing (PHT). Once a lot has met the disease standards related to field crop inspection (for example virus tolerances), the lot is considered certified. While PHT can provide additional verification of seed lot health and quality, the CFIA does not support recommendations to create a mandatory PHT program for domestic purposes under Part II of the regulations.

The CFIA recognizes the value of PHT in supporting trade and certification and will continue to facilitate its use through the issuance of the North American Certified Seed Potato Health Certificate, in accordance with the Canada-United States Agreement on the management of tuber necrosis diseases. However, making PHT mandatory at the federal level would impose a significant regulatory burden on growers in provinces where it is not currently required under provincial regulations.

Therefore, the CFIA will maintain the current approach, which supports voluntary post-harvest testing and certification for export purposes, while ensuring flexibility and fairness for growers in all regions of Canada.

2.3.4 Laboratory verification before decertification of a seed lot

Canada's seed potato certification system is built on decades of experience and has meet industry needs, using trained inspectors to conduct visual assessments, which remains the trusted and effective standard for determining seed lot eligibility.

Under Part II of the regulations, a seed lot must meet all crop inspection and tuber grade standards to be certified. The CFIA offers a formal appeal process, allowing growers to request a re-inspection by a second trained inspector if they disagree with the initial findings.

The CFIA is not in favor of supporting the recommendation to incorporate a laboratory protocol into the regulations to verify the visual assessment results of a crop before it is decertified. The CFIA will continue to provide an appeal process as a means of verifying visual inspection outcomes related to crop decertification, when requested by a grower. The CFIA will also ensure the laboratory testing is recommended only in exceptional circumstances, such as suspicion of PSTVd, BRR or a quarantine pest. A lab test may also be used to verify unusual crop damage (such as pesticide damage) observed during the visual inspections.

The CFIA will maintain visual inspection as the primary method of certification. Two field inspections (such as percentage of plants showing visual symptoms of disease) are used to confirm the seed potato class and to complete the certification documents necessary for trade.

2.3.5 Preventing varietal mixture in seed potato fields

Maintaining the varietal integrity of a seed lot is essential to ensure the genetic consistency and varietal uniformity of a potato variety within a given lot of seed potatoes. Under Part II of the regulations, varietal purity is achieved by maintaining 1 blank row between adjacent fields. While blank rows have traditionally been used in potato production, they can present challenges for growers using alternative planting systems, such as planting beds and may inadvertently attract pests due to open field spaces. The following changes would respond to industry's request for alternative options to the use of blank rows:

• The regulations will be amended to create an option for maintaining physical separation or the blank row requirement between adjacent fields to prevent varietal mixtures.
  Growers will be required to document their alternative methods for preventing varietal mixtures within a PCP. For those who do not wish to use an alternative method, the existing requirement for blank rows will remain in place.

2.3.6 Prohibiting planting of seed potatoes in fields infested with quarantine pests

The presence of quarantine pests, such as soil-borne nematodes or fungus, in potato production can cause significant economic consequences, including loss of market access. These pests tend to be highly persistent and difficult to detect at low levels and to eradicate, especially those capable of remaining dormant, yet viable, for extended periods. Their management requires long-term phytosanitary actions and control of critical pathways for their spread, such as the movement of seed potatoes and contaminated soil. The following changes would help enhance confidence in Canada's seed potato system and support continued market access for Canadian potatoes:

• Part II of the regulations will be amended to prohibit the planting of seed potatoes in fields that are infested or have previously been infested with key soil-borne quarantine pests such as:
  • potato wart
  • potato cyst nematode
  • potato rot nematode

  This policy is intended to strengthen the link between the Seeds Regulations, Part II and the Plant Protection Act and Plant Protection Regulations, reinforcing Canada's commitment to safeguarding plant health.

By prohibiting the planting of seed potatoes in infested fields, the CFIA is aligning domestic certification standards with national and international phytosanitary programs, including the National Potato Wart Response Plan and the Canada-United States Guidelines to manage potato cyst nematode.

2.3.7 A grower's duty to report the occurrence of certain pests of potato production

BRR and PSTVd are not listed as quarantine pests under the Plant Protection Act and Regulations, but their management as regulated non-quarantine pests is critical to maintaining the integrity of Canada's seed potato system. These 2 pests are among the most significant threats to potato production due to their high rate of transmission and spread through seed potatoes.

Canada is free of PSTVd and the seed system is maintained functionally free of BRR. However, the presence of BRR in Canada and its occasional detection in non-seed fields poses a risk of cross-contamination through shared equipment and storage facilities. The following changes would help enhance confidence in Canada's seed potato system and support continued market access for Canadian potatoes:

• Part II of the regulations will be amended to require seed potato growers to report the detection of BRR and PSTVd on all potato farm units under their control.
• By requiring mandatory reporting, the CFIA would harmonize the approach to managing BRR and PSTVd with existing protocols for quarantine pests. This measure would:
  • strengthen traceability
  • enhance early detection
  • reinforce Canada's reputation for producing high-quality, disease-free seed potatoes

Section 3: Table of proposals by theme

For each proposal, refer to the description of the current and future states, the rationale for the proposed change or for maintaining the status quo and an indication of whether it will require an amendment to the Seeds Regulations.