Canola Council of Canada

Policy Positions

The Canola Council of Canada is a national, non-profit association funded by stakeholders in the canola industry. As a value-chain organization, the Council includes members from all segments including canola growers, seed developers, grain handling/exporter organizations and oil processors. Our mission is to enhance the industry's ability to profitably produce and supply seed, oil and meal products that offer superior value to customers throughout the world.

 

The Canadian canola industry has 50,000 farmer decision-makers that plant canola across roughly 14-16 million acres. They rely on canola to generate between 30-50% of their revenues on an annual basis. Canola was Canada’s largest cash crop by value in each of the years 2004-2008.

 

In addition to the farm-level, canola carries a real value-added sector that processes canola seed into oil and meal in 13 processing plants in five provinces. Approximately 214,000 people are directly and indirectly employed by the canola industry including many highly skilled and professional jobs. As a whole, canola contributes $14 billion annually to the Canadian economy.

 

Domestically, canola enjoys roughly 50% of our edible oil market. From that market, canola produces $1.3 billion in economic activity in Ontario and Quebec, and $11.8 billion in Western Canada.

 

While the domestic market is incredibly important to our industry, the fact remains that it uses only 10-20% of our annual production. The world is our market, and canola exports bring well over $4 billion back to our Canadian economy, along with the thousands of well paid employees needed to make international trade happen. Canola is an essential component of Canada’s overall trading relationship with our key partners within North America (both the United States and Mexico) and in Asia - especially Japan.

 

Canola is Canada’s only “Made-in-Canada” crop created here in the 1970s. Ongoing canola research and development is centered in Canada bringing with it not only the employment benefits for our scientific community, but also the opportunity to continue to build new products and markets for the future.

 

With the healthiest profile of any of the commercially available oils and fats, canola is well-positioned to be a healthy choice for concerned citizens. It is also in the envious position of being the feedstock of choice for biodiesel given its quality characteristics. Canola will continue to be a major force in the marketplace for both food and fuel.

 

Canola currently has approximately 50% domestic market share for plant-based edible oil, representing around 10% of our production. This means that roughly 90% of our production must be sold abroad each year. This reality, in conjunction with the highly distorted world market for oilseeds, demonstrates why successful trade negotiations are so important for our industry.

 

Government policy and government programs to support the agricultural sector will continue to have a major impact on the health of the canola industry. As such, the Canola Council of Canada is an active advocate for the industry on most aspects of government activity.

 

A summary of the CCC Policy Positions and the background for the policy is presented so that the industry and the Canadian government can understand and can assist in creating a domestic and international regulatory environment beneficial to the preservation and enhancement of this uniquely Canadian crop.

 

Principles Governing CCC Action With Respect to Policy Advocacy

 

The Canola Council of Canada is non-partisan. Our goals are to:

    • Increase the overall awareness of the size and importance of the canola industry to Canada among politicians and within government bureaucracy;
    • Support legislation and regulation that promotes growth and prosperity for all segments of the canola value chain;
    • Advocate science-based regulatory regimes both domestically and internationally;
    • Preserve and enhance the reputation and safety of our commodity; and
    • Aggressively defend against policies that reduce competitiveness and/or market access.

  • Policy 1: The Canola Council of Canada supports an open, transparent and commercially competitive environment for all participants

    The canola industry is built around competitiveness and all government regulations, policies and programs must be transparent and open to all interests in the industry. Canola seed development, growing, crop protection, marketing, handling, transportation, processing, shipping are all based on commercial enterprises. In order to remain competitive, there must be no impediments to competitive commercial business operations.

  • Policy 2:  The Canola Council of Canada supports the free and unencumbered use of canola and its products in the Canadian industry.

    Canola products face regulatory barriers or potential government program/policy barriers to trade and competiveness within the Canadian marketplace. These may take the form of technical barriers to trade as a result of unnecessary and discriminatory regulation, programs and policies being implemented or being considered at both the provincial and federal level.

  • Policy 3: The Canola Council of Canada supports equitable quality oriented canola grading standards, as well as domestic and international trading standards.

  • Policy 4: The Canola Council of Canada supports an accountable, open, competitive, and commercial system of oilseed, oilseed product and grain transportation in Canada.

  • Policy 5: The Canola Council of Canada supports a timely and flexible registration system that is responsive to industry needs.

  • Policy 6:  The Canola Council of Canada supports a canola variety registration system based on quality only for merit with evidence of collection for agronomic performance and disease resistance.

  • Policy 7: The Canola Council of Canada supports a level of 7% or less saturated fat in canola oil. It is recommended that the variety registration requirements be set to meet that objective for the commercial crop.

  • Policy 8: The Canola Council of Canada supports variety regulations that allow for contract production of specialty canola varieties.

  • Policy 9:  The Canola Council of Canada supports a voluntary option for products to be eligible for a three year interim registration based on one or more years of Private trial data from at least 12 trial sites:
    • Information on agronomics and disease resistance must also be submitted.
    • All such registered products will be submitted to the Public Coop trialing system for verification of quality data.
    • The WCCRRC should remain the official recommending body and oversee the implementation of these changes.
  • Policy 10: The Canola Council of Canada encourages improvement in consistency and dependability of official statistics on Canadian canola.   

  • Policy 11: The Canola Council of Canada will support composition of matter patents only if they are released to the industry under non-exclusive commercial terms.

  • Policy 12: The Canola Council of Canada supports the government’s objective for voluntary reduction of trans fat from all sources, but not at the expense of overall public health by allowing saturated fat levels to sky rocket in the Canadian diet. 

    On June 20, 2007, the Minister of Health announced that Health Canada adopted the recommendations of Trans Fat Task Force with respect to the amount of trans fat in foods. These recommendations from Trans Fat Task Force were two-fold:

    1. Limit the trans fat content of vegetable oils and soft, spreadable margarines to 2% of the total fat content; and

    2. Limit the trans fat content for all other foods to 5% of the total fat content, including ingredients sold to restaurants.

    The Minister called on the food industry to achieve these limits within two years and if significant progress has not been made in the next two years, Health Canada will develop regulations to ensure that the recommended levels are met. In doing so, companies and food manufacturers are encouraged to replace trans fats with healthier alternatives such as monounsaturated and polyunsaturated fats and to not replace trans fats with saturated fats.

    To ensure that the industry is making progress in meeting the 2% and 5% limits of the total fat, Health Canada is closely monitoring the actions of the industry over the next two years via the Trans Fat Monitoring Program. By publishing the results, it will also inform Canadian consumers of the progress that is being made.

  • Policy 13: The Council supports the Health Canada mandatory labeling guidelines for novel trait products when it is shown substantial equivalence is not present or when it is shown an allergen has been introduced to the product. Furthermore, the Council supports the labeling of such novel trait products on the basis of the product change, not on the process employed to develop the change.

    The Canadian canola industry believes that it is appropriate and necessary to label foods to ensure that they present no health hazard to those who consume the product and/or to advise consumers of any substantive change to the nutritional quality of a food or food ingredient they consume. There is no need to label canola oil from GM plants because canola oil is identical irrespective of   whether it is produced from GM or conventional seed. Therefore, the canola industry does not support, either domestically or internationally, the mandatory labelling of GM canola oil.

    The Canola Council of Canada supports the voluntary labelling of GM foods since this provides an option to food manufacturers to make this information available if customers request it and are willing to pay the costs. We are opposed to process-based GM labelling on anything other than a voluntary basis. 

    Under the Canadian General Standards Board “Voluntary Labelling and Advertising of Foods that Are and Are not Products of Genetic Engineering” canola can be labelled as “Canola oil. Product of genetic engineering. Contains no genetically engineered material.”  We supported the voluntary standard on the basis that it provides food manufacturers with the choice of whether they want to label what is, in the case of canola oil, a product that is safe and that is identical irrespective of the type of canola from which it was produced.

  • Policy 14: The Canola Council of Canada advocates for the following regulatory and policy instruments to support the development of a biodiesel industry in Canada that maximizes its
    impact on the domestic economy:
    • Biodiesel specific “Renewable Fuel Standard” of 2% for 2010 and a 5% target for 2015;
    • Investment incentive parity with the USA (e.g., $1/gallon blender’s credit, faster capital depreciation, etc.);
    • Quality parameters to ensure end user acceptance and therefore long term success of the industry; and
    • Encourage grower participation in value-added production.

    Governments from around the world are introducing national renewable fuel strategies to meet public policy objectives related to issues such as energy security, the environment and rural development. There has been massive capital commitments for biodiesel production in the EU, US and South America in particular, corresponding to those governments’ aggressive policy changes to encourage the production and consumption of biodiesel in their jurisdictions.

    The global demand for renewable fuels, including biodiesel, has moderated in the last two years, as governments shift from incentives and tax credits for biofuel production to renewable fuel standards that mandate the amount of biofuel that must be used within a country.

    Biodiesel has the ability to create significant demand signals in a very short period of time that will produce long term inelastic markets for canola. In a biodiesel market driven by oil, canola is extremely competitively positioned with its high oil content, not to mention its quality characteristics (e.g. low in saturated fat) making it the feedstock of choice for this industry, especially in colder northern climates.

    While the Canadian canola industry welcomes the economic benefits new export markets for foreign biodiesel production will bring for both canola seed and oil, there is also an incredible opportunity for canola to capture a high value domestic biodiesel market through the development of production infrastructure in Canada.

    In 2007, the Government of Canada announced an incentive program with a commitment for $1.5 billion to push-start the biofuels industry in Canada. 

  • Policy 15: The Canola Council of Canada supports Canadian trade policy that seeks to secure an open, unencumbered and predictable international trade environment for canola and canola products.

    Our trade objectives are:

    • An end to higher tariffs on canola products in comparison to our competitor oils and oilseeds such as soybeans, soy oil, palm oil, etc. 

    • The elimination of tariff escalation which discourages value-added canola exports and differential export taxes, and;

    • Drastic reductions to subsidies that have had a negative impact on canola prices. 

    • The elimination of any sanitary and phytosanitary issues that prevent market access.

The Canola Council of Canada prefers multi-lateral trade agreements, because of their comprehensive scope and inclusion as the preferred vehicle for agriculture trade rules reform and as such endorses the World Trade Organization as the central international forum for negotiating trade rules and processes between nations.

 

The Canola Council supports bi-lateral trade agreements between Canada and other nations which are consistent with WTO guidelines and deal with tariff and non-tariff issues thereby securing market access for canola and canola products. Effective dispute resolution mechanisms are also necessary. Canada’s bi-lateral trade agenda must ensure that canola’s interests are not compromised by trade policy and bi-lateral agreements between other nations. 
 

As the primary exporting nation of canola, Canadian trade policy must seek to secure an open, unencumbered and predictable international trade environment for canola and canola products. No one else will speak for canola except Canada. In order to remain competitive, the canola industry in Canada needs the elimination of trade distorting export subsidies and domestic support, national treatment, elimination of tariffs and non-tariff barriers that limit trade, elimination of tariff escalation and effective dispute resolution mechanisms.

 

Multi-lateral trade agreements, because of their comprehensive scope and inclusion are the preferred vehicle for agriculture trade rules reform. Therefore, the Canola Council of Canada endorses the World Trade Organization as the central international forum for negotiating trade rules and processes between nations. Any country accession to the WTO must be negotiated with the objective of ensuring equitable treatment of canola and canola products compared to competing products.

 

The Canola Council of Canada supports a Canadian negotiating position on oilseeds of zero for zero within a level playing field for World Trade Organization negotiations.

 

Based upon the draft agriculture texts in the Doha Round that have been prepared to date, we advocate:

  • An end to higher tariffs on canola products in comparison to our competitor oils and oilseeds such as soybeans, soy oil, palm oil, etc. 

  • The elimination of tariff escalation which discourages value-added canola exports and differential export taxes, and;

  • Drastic reductions to subsidies that have had a negative impact on canola prices, notably commodity specific subsidization (e.g., soybean subsidies in the United States) and trade distorting domestic programs.

The Canola Council supports bi-lateral trade agreements between Canada and other nations which are consistent with WTO guidelines, deal with tariff and non-tariff barriers which secure market access for canola and canola products and provide effective dispute resolution mechanisms.

 

Many countries around the world are negotiating free trade agreements that could disadvantage Canadian products, including canola. It is important the bi-lateral trade agenda ensures that Canada’s interests are not compromised by trade policy and agreements between other nations. 
 

  • Policy 16:  The Canola Council of Canada supports food, feed and environmental safety regulations based upon proven scientific need. The foundation of regulations related to the introduction of innovative products, including those produced using biotechnology, must be based on food, feed and environmental risk assessments that utilise internationally accepted science-based standards.  

    The Canola Council of Canada supports innovative canola products, including those produced through biotechnology. Increasingly the Canadian canola industry is dealing with intended and unintended potential barriers to trade, particularly in the form of regulations governing food safety and/or environmental safety (Sanitary/Phyto-Sanitary) via foreign domestic policy and/or international agreements. The canola industry fully understands and supports regulations to ensure the safety of both the food supply and the environment within Canada and in the countries to which we export. 

    The Canola Council of Canada supports innovative canola products, including those produced through biotechnology. Increasingly the Canadian canola industry is dealing with intended and unintended potential barriers to trade, particularly in the form of regulations governing food safety and/or environmental safety (Sanitary/Phyto-Sanitary) via foreign domestic policy and/or international agreements. The canola industry fully understands and supports regulations to ensure the safety of both the food supply and the environment within Canada and in the countries to which we export. The Canola Council of Canada supports innovative canola products, including those produced through biotechnology. Increasingly the Canadian canola industry is dealing with intended and unintended potential barriers to trade, particularly in the form of regulations governing food safety and/or environmental safety (Sanitary/Phyto-Sanitary) via foreign domestic policy and/or international agreements. The canola industry fully understands and supports regulations to ensure the safety of both the food supply and the environment within Canada and in the countries to which we export. 

  • Policy 17: The Council takes a lead role in the efforts toward harmonization of pesticide residue limits between Canada, USA, Japan and Europe. For the USA, until pesticide harmonization between Canada & the USA is complete, the Council will not support a new Canadian pesticide registration for use on canola if the new pesticide does not have a registration or import tolerance level approved in the USA. 

  • Policy 18: Canola Industry Policy on Innovation in Seed of Canola and other Brassica spp. and Market Access for Canola. The Canola Council of Canada requires the following: 

    Species

    Non-transgenic

    Transgenic

    B. napus

    B. rapa

    B. juncea

    Any company wishing variety registration in Canada to produce products with profiles or distribute seed outside the “traditional” canola profile (food, feed, non-food and/or non-feed) must:

     

    • meet canola industry criteria for variety recommendation - through the Western Canola/Rapeseed Recommending Committee for canola for western Canada, or alternate requirements for registration for the rest of Canada;

     

    • develop a commercialization plan using Market Analysis Principles/Biotech Canada Product Launch Stewardship Policy; and

     

    • use appropriate risk management tools to protect current uses and markets.

    Any company wishing variety registration in Canada to produce or distribute transgenic canola seed, must, before seeking registration in Canada:

     

    • meet the canola industry criteria for variety recommendation - through the Western Canola/Rapeseed Recommending Committee for canola for western Canada, or alternate requirements for registration for the rest of Canada;

     

    • develop a commercialization plan using Market Analysis Principles/Biotech Canada Product Launch Stewardship Policy; and

     

    • obtain the appropriate regulatory approvals in Canada, U.S.A., Mexico, Japan, China, South Korea and the European Union.

     

    Innovation is critical to the continuing growth and profitability of the canola industry. The Canadian canola industry strongly endorses stringent assessment of new technologies to ensure that they are safe for human and animal consumption and for the environment.

    The Canadian canola industry fully supports the notion that an industry needs to consider the potential impact on existing markets of any new technology that may be introduced. Our industry has successfully advocated the implementation and/or retention of science-based evaluation in our key importing markets.

    Recognizing that in many countries, crops developed using biotechnology are regulated, the canola industry must pay particular attention to the regulatory requirements in our export markets. Currently, countries with an operational regulatory system have a zero tolerance for transgenic events not approved in their countries. Recognizing that zero tolerance is not feasible for commercialized transgenic canola, the canola industry supports and is actively involved in the development of a global approach to regulation of transgenic crops that would allow innovation and be non-trade restricting. These include the development of systems for coordinated approvals and the establishment of a global safety assessment policy through Codex for the low level presence of transgenic plant material.

    The canola industry encourages the development of Brassica napus, B. rapa and/or B. juncea for food, feed, non-food and non-feed uses. Products that would meet the canola definition and could be used for both food/feed and non-food/non-feed uses would offer maximum flexibility in optimizing market value. For example, high yield and high oil content varieties or high stability profiles would be optimal for both food and non-food uses like bio-diesel.

    The canola industry will retain a policy of non-segregation for canola with the “traditional” oil profile. Segregation would be required for functional or specialty canola outside of the traditional canola profile. If appropriate, developers should consider using contract registration, appropriate identity preserved protocols, quality assurance systems, segregation systems and/or appropriate approvals in export markets. Whereas closed loop segregation or geographic isolation can be effective for non-transgenic canola, under the current situation of zero tolerance for any transgenic event not approved in canola export countries, closed loop segregation does not provide adequate confinement of transgenic canola to meet export market requirements. Therefore, segregation for transgenic functional/specialty canola would only be effective if regulatory approvals are obtained in all export markets identified by this policy.

    In order to ensure that market issues are evaluated and that new technology can be introduced effectively and economically, the CCC encourages developers to use the Market Analysis Principles (MAP) developed by CropLife Canada and the Product Launch Stewardship Policy from Biotech Canada.

    The Council encourages early dialogue, while respecting the need for confidentiality of innovative new research and intellectual property, to address potential risks and appropriate regulatory approvals to protect canola food uses and markets. A guidance document on the issues that should be addressed is available from the CCC.

  • Policy 19: The Council supports the negotiation of agreements with importing countries that protects biological diversity. However, the Biosafety Protocol must be based on science and must not disrupt the movement of LMOs, particularly for food, feed and processing where there is no intended environmental release.

    Under the UN Convention on Biological Diversity, the Cartagena Protocol on Biosafety was adopted in 2000.The Protocol seeks to protect biological diversity from the potential risks posed by living modified organisms (LMO) resulting from modern biotechnology. Its primary focus is the trans-boundary movement of GM crops (seed only as defined as Living Modified Organisms) for intended release into the environment and unintended release (i.e. use in food, feed or processing). Canada is a signatory to the Protocol.

    Countries that have, or intend to ratify the protocol and to which Canada currently sells canola, include Japan and Mexico, Pakistan and the European Union countries. The Canadian canola industry will fully comply with all requirements of these countries.

    The industry needs time to implement the documentation and further the discussion at the BSP meetings, including the discussion on adventitious presence and liability and redress before ratification. The Council works in Canada and internationally through the International Grain Trade Coalition on meeting the requirements while minimizing the costs and liability impacts on the industry.

    As of March 2006, the requirements for seed for food feed and processing include:

  • The invoice as the vehicle for documentation.
  • The wording will be “may contain” followed by a listing the GM events or unique identifier for those events in commercial production.

The Canola Council does not support Canada ratifying the Protocol at this time. If Canada chooses to ratify the Protocol, domestic regulations are required to regulate exports of GMO’s. Decisions on the scope of the documentation requirements, position on adventitious presence (GM in non-GM shipments or non-approved events in GM shipments), potential need for certification of shipments, and potential use of unique identifiers are yet to be concluded. Critically, as a major exporter, Canada may be liable for adventitious presence if adventitious presence is included in the scope of the Protocol. We are also concerned that Canada is the ONLY exporter country that intends to ratify the Protocol. 
 

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