Boehm is the vice-president of the National Farmers Union.
The Canadian Food Inspection Agency is conducting a 60-day internet-based consultation that is scheduled to end Dec. 2.
Changes to the system of registering crop varieties for production in Canada are being contemplated.
These proposed changes will have major consequences for Canadians in the kind of food they will eat and for farmers in terms of markets and the degree of control exerted on them in terms of how they use, reuse and exchange seeds.
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The new proposal is being touted as a modernization and streamlining of the current system. It is intended to facilitate more and quicker registrations through three categories of registration.
The first category of seed registration, or Tier 1, would be similar to our current system, where varieties are registered after an assessment of merit, agronomic characteristics and third-party independent field trials whereupon a recommending committee evaluates the results and decides on its suitability for Canadian production. This system varies somewhat for different crop kinds.
Tier 2, as proposed by the CFIA, would be a simple listing of varieties. There would be no merit requirements or testing against benchmark varieties.
Varieties would have to be distinct, uniform and stable as is also the case in Tier 1. Tier 2 registration would bypass independent testing and would lead to rapid registrations.
Faster variety registration has its advantages and, in some cases, potential disadvantages. For instance, fast-tracking the registration of genetically modified Roundup Ready wheat, a possibility under the CFIA’s proposal, could mean the wheat variety is approved and in the ground before farmers have time to fully understand the consequences in terms of market loss and other economic damages.
The third category would be an expanded contract registrations system. We have nine varieties grown in Canada under contract registrations. These are crops designated as too harmful to be comingled with ordinary crops and commodities.
There are strict segregation requirements. An expansion of this system into a so-called “risk-based assessment” model would mean increased possibilities for the problems through simple increases in numbers.
It is also a model associated with closed-loop production systems. Closed loops will mean no seed saving and strict control on production methods. A farmer would most likely produce under strict contractual requirements.
Expansion of this system would further normalize a situation where a farmer loses autonomy in relation to seeds.
It is a model exemplified by contract chicken production in the United States. If a grower questions the conditions imposed, then he or she is simply excluded as an eligible producer and is left unable to sell their production.
Contained in the proposed changes is the creation of Crop Specific Consultation Groups, which would come under pressure to move their crop kind to the least onerous registration tier.
Seed companies would argue that in order to be competitive and for them to invest in research, they cannot comply with the time and expense of Tier 1 registration requirements and need to move to Tier 2 or contract registrations. These groups are already being looked at as a vehicle for grain company and seed industry dominated commodity associations to extend their influence.
What are the likely results of all of this?
Initially more crop kinds would move to simple listing or Tier 2. One would see more GM varieties being registered with their restrictive and expensive Technology Use Agreements.
Farmers will increasingly lose their rights to save, re-use and exchange seeds. Farmers will be reliant on company-released information with less availability of independent testing and evaluation.
More contract registrations will take place, increasing seed companies’ control of production systems and farmers. Higher seed costs and regular purchases will flow out of this.
Variety Recommending Committees will lose their importance over time and their expertise will be lost in the consideration of crop varieties for Canada.
Farmers will likely see themselves on a variety treadmill with new varieties being offered while good varieties are deleted.
New varieties will generally have more restrictions built in or constructed around them. This variety treadmill is a likely consequence of this system coupled with the CFIA’s policy allowing companies to deregister varieties as they feel like it.
For example, in canola, we have seen over 100 varieties deregistered recently.
If a seed company obtains privileges under Plant Breeders Rights for a fixed term (17 years or more) it should be incumbent on them to leave the variety in the public domain when those protections expire.
To remove it and force people to buy new varieties that offer little or no advantage is incredibly unfair and an abuse of privilege.
Seed contains incredible wealth. Companies that control those seeds can extract additional dollars from ordinary farmers.
We need to immediately write letters to the CFIA, minister of agriculture, MPs and the prime minister, demanding an extension of the consultation period and move it beyond the internet with public hearings.
Let opposition MPs know about your concerns also. People need much more time and information to discuss and understand the implications of these proposals.
There is no need for the CFIA to hurry this process.
