Preview your letter to the CFIA
Dear CFIA Seed Regulatory Modernization Team,
My name is [FIRST]
[LAST] and I live in
[CITY],
[PROVINCE]. As a proud member of Canada’s agricultural value chain, I know how important a strong seed system is to our farms, food security, and exports. That is why I am writing to support the Canadian Seed Growers’ Association’s (CSGA) recommendations on the CFIA’s Seed Regulatory Modernization (SRM) Policy Paper.
You can read CSGA’s analysis and recommendations here.
The CFIA’s SRM initiative is a once-in-a-generation chance to improve service delivery, strengthen the integrity of our seed system, and use public resources more efficiently. Throughout the SRM process, CSGA has consistently put forward a clear and forward-looking vision for a modern and responsive seed system built on three core recommendations:
- Make CSGA the Main Administrator of Canada’s Seed Certification System
- Implement a Digital End-to-End Certification System
- Establish a Seed Sector Advisory Committee
I fully endorse this vision and encourage the CFIA to adopt CSGA’s recommendations in full.
Many of the CFIA’s SRM proposals support and complement CSGA’s vision and recommendations, including establishing a formal advisory committee with balanced representation (3.2.1), modernizing seed tags (3.2.14), working with CSGA to streamline OECD export certification (3.1.18 and 3.1.21), and expanding alternative service delivery for seed tag administration (3.1.8). As Canada’s national seed crop certification authority, co-regulator of Canada’s seed certification system, and Canada’s AOSCA representative, CSGA has the public trust, proven track record, capacity, and expertise to assume additional administrative duties, including many of the ASD opportunities outlined.
However, several proposals, as drafted, risk taking Canada in the wrong direction on enabling productivity, traceability, and efficiency. These include the lack of a national strategy to monitor total quantities of seed certified and changes that could undermine the sustainability of our third-party inspection capacity.
Requiring mandatory reporting of total quantity of seed certified could have huge positive impact and unlock value beyond oversight. A national, anonymized data set could be a key strategic data source and allow for better decision-making, forecasting, benchmarking, improved productivity, and stronger transparency and market confidence.
More broadly, I am concerned about the CFIA taking on more administrative and enforcement responsibilities at a time when the public service is facing significant resource constraints. Without more strategic delegation to a partner like CSGA, which has the experience, infrastructure, and capacity to deliver, we risk future bottlenecks, slower service, and gaps in enforcement.
Transferring appropriate functions to CSGA creates opportunities to improve business processes and service delivery, eases the burden on government resources, and maintains rigorous oversight, quality, and compliance.
Many of the priorities outlined above, and those that CSGA supports, can be implemented through administrative or policy updates within the CFIA’s existing authority. Because they do not require changes to the Seed Regulations or other legislative instruments, the CFIA should move these priorities forward without delay to cut red tape and reduce administrative burden immediately. I am also not supportive of opening up the Seeds Act at this time.
Canada’s seed certification is a critical public-good service and a key enabler of a productive and competitive agriculture sector. The CFIA’s SRM process, and the recommendations outlined above, represent a unique opportunity to modernize regulatory oversight, improve service delivery, and reduce reliance on government resources.
With proven capacity and broad sector support through the SRM process, CSGA stands ready to serve as a trusted partner in delivering faster services, lower public sector costs, and sustain confidence in Canada’s seed certification system, both domestically and internationally. It is time for the CFIA to move SRM from debate to action.
[YOUR OPTIONAL STAKEHOLDER COMMENTS]
This is a rare opportunity to build a modern seed system that works for farmers, the seed sector, and Canadians. I urge you to adopt CSGA’s vision in full.
Thank you for your consideration.
Sincerely,
