Canada’s two seed sector associations are expressing both agreement and differences in their vision for the future of Canada’s seed system.
Both the Canadian Seed Growers’ Association (CSGA) and Seeds Canada recently engaged their members regarding the Seed Regulatory Modernization (SRM) winter consultation survey, which opened for comments in February and closed on May 1.
Dealing with seed certification, variety registration and seed standards and grade tables, the survey asked seed sector stakeholders various questions about the pillars of Canada’s seed regulatory framework.
In their recommended responses to members, both CSGA and Seeds Canada expressed much agreement on the path forward (both support the use of Incorporation by Reference as a regulatory tool and the elimination of varietal blend standards). Still, they have somewhat different takes on the big-picture questions regarding seed certification and variety registration.
“There were two or three questions that were most important to us and our members and that we believe are ultimately crucial to the entire seed sector in the value chain. These questions include whether Canada should have a national registration system, whether there should be a single body issuing certificates and setting standards, and the concept of incorporation by reference,” says Doug Miller, executive director for the CSGA.
“Those are foundational elements.”
CSGA believes Canada’s variety registration system should carry on, noting in its recommended survey responses that “Canada has an international reputation for seed and grain quality, and our variety registration system is a major reason why by providing an unbiased, third-party assessment of new varieties to let producers know how a variety will perform.”
CSGA also believes it should continue to serve as Canada’s national seed certification body, noting in its survey responses that “CSGA has the size, scale and proven track record to administer our program cost-effectively… and ensures that no producer or crop kind is left behind.”
For Miller, the benefits of SRM don’t end there. He says their CSGA Learn program is a crucial building block for the seed sector that could be a hugely helpful tool in Canada’s post-SRM seed certification system. CSGA Learn is an online learning platform that he says equips the next generation of seed growers, seed businesses, and inspectors with the information they need to succeed in the evolving system.
Miller explains that CSGA Learn, if requested, could potentially be used to provide additional training options for licensed seed crop inspectors, a topic also raised in the survey.
Nuance and Complexity
Like CSGA, Seeds Canada immediately reached out to its members after the release of the survey in February, holding two webinars to unveil the survey questions and gather feedback in order to develop recommendations for member response that were released publicly in the spring.
Seeds Canada Regulatory Affairs Manager Lauren Comin says Seeds Canada appreciates the addition of open text boxes to the survey format, allowing the public a chance to provide specific answers to complicated questions.
“For instance, with only a black-and-white answer to the variety registration question, it is impossible to account for all the nuances and complexities involved in different crops and sectors,” she says.
“Each crop and sector have their own unique challenges and requirements, and we need to make sure that our regulations can address these differences in a thoughtful and effective way. Ultimately, we need to balance the desire to simplify regulation with the need for flexibility for future innovation, to create an environment that supports the success of our entire industry.”
For its intent and purposes, Seeds Canada believes participation/placement within a national variety registration system should be decided on a crop-by-crop and crop-by-use basis by the stakeholders of that crop value chain. When it comes to having one national body in charge of certifying seed, Seeds Canada supports separation of standard setting and service delivery by a single stakeholder group and has already proposed its idea for an Independent Standards Setting Body (ISSB) to allow for inclusive governance, better reflecting the diversity of the sector.
For Comin, the fact that the findings of two other SRM task teams — seed testing and common seed — have yet to be released means there are a lot more discussions yet to be had. Two other task teams relating to information and import/export of seed had yet to begin their work at press time. That’s a lot more work to be done before the process comes to its completion in 2025, Comin notes.
“We need to ensure that any changes we make will provide more flexibility and not less. While there is a lot of focus on removing red tape, we need to be cautious and understand the potential impacts of these changes,” Comin says.
