:
Thank you very much for inviting us to present to you this morning. As you'll recall, we at the Canadian Meat Council have been here before. We represent the largest of Canada's agrifood sectors, with gross sales over $20.3 billion. In fact, last year Canada exported $1.24 billion worth of beef and $2.39 billion worth of pork to over 60 countries.
I presented to you last in November, when I was expressing our concern about the challenges to the industry, and those concerns remain. We're still faced with a very strong Canadian dollar, labour shortages, rising fuel prices, and with an increase in the amount of pork and beef that's being sold here in Canada, directly at retail, from the United States.
As well, according to Agriculture Canada, the pork imports from the United States so far, year to date, are up 16%, to 22.5 thousand metric tonnes. Last year, at the end of the year, imports from the United States were up 8.4%, at 94,000 metric tonnes.
Imposing or looking at any new regulations makes us nervous. We saw that, because last year we were faced with the new specified risk material regulations for the beef sector. On April 1, Gencor announced that they were closing their doors and declaring bankruptcy protection.
Looking at this particular regulation makes us want to make sure that we're looking at this properly. It's our understanding that you're looking at the recommendation you made of implementing a minimum 51% domestic agrifood content rule that would provide better protection for the integrity of “Product of Canada” designation.
Let me begin by pointing out that Canada's meat industry is the most heavily regulated of all Canada's food sectors. We have a very good record of compliance with these rules. And not only do we comply with domestic rules, but many of our members comply with export rules, various rules in different countries, that differ from our own.
We also know a lot about labels. I've got several meat samples here I'm going to pass around, and hopefully I'll have time before my ten minutes run out.
In Canada, all labels intended for immediate containers of prepared edible meat products are required to be pre-approved by the Canadian Food Inspection Agency before the product is sold in the market. Currently the label registrations are required for all pre-packaged meat products and processed vegetables and fruits only. Other food products, such as dairy, honey, bakery, egg, fish, etc., here in Canada do not require pre-registration. They're still subject to relevant labelling regulations, but they don't have to wait for label approval as the meat industry does before we can market our product. This has serious implications for the competitiveness of our sector compared with other Canadian food industries that are not constrained by these regulations.
That approval costs us money. Each and every food label.... For instance, for Piller's sausages and delicatessens--and they have a lot of product--each and every new label costs them $100 for registration and $45 if they want to make a minor change to something on this label. It's $45 for a minor change. So take all of the meat companies in Canada, multiply it by all the labels that we produce, and that's a problem.
We understand, as well, that competitors in the United States wait no longer than seven days and that they have a generic system of approvals for labels that allows them to make minor changes without government approval. Our label approval process has been frustrating our members for years.
Introducing new legislation or regulations on “Product of Canada” makes us wonder how it will affect our businesses. Now all products that are pre-packaged for sale by Canadian meat processors must carry the meat inspection legend. When I started in this job four years ago, I didn't really quite know what it meant either, but what it means is that it is inspected by the Government of Canada. That's what it means. It's got this crown on it, and the establishment has to put their number either immediately on the logo or somewhere on the package.
I'll pass this one around, and you can see that here's Piller's pepperoni, an excellent product. It's got the logo here. They've actually put their establishment number up here in the corner, establishment 522, but they've got all the information, totally bilingual, and it shows the best before date. We'll pass that around. We'll open it at the end of the session and you can have some of that.
Of course, the meat inspection legend is the national trademark, and unauthorized use of that national trademark is subject to prosecution under section 21 of the Meat Inspection Act. Only meat processed in a Canadian federally inspected facility may use the trademark, but we are not required to use “Product of Canada”.
You'll see on the various products that we pass around.... And I'd better start passing these around, or you'll be looking at them while Robin or someone else speaks. That's an example of a fully cooked chicken product. In all of these products you'll find the crown, but you will not find the declaration “Product of Canada”. It's not required.
Actually, our association raised the issue of “Product of Canada” late last year with the Canadian Food Inspection Agency because we saw an increasingly large number of large cuts of meat, especially at the warehouse club stores, that in the past have been cut at retail, appearing for direct sale with several labelling violations, such as lack of bilingual labelling, lack of a meat inspection legend, no code dates, no “packaged on” dates, and especially non-compliant U.S. meat with no “product of” information.
We got a response from them in writing on February 11, 2008, and they said to us:
Section 123 of the Meat Inspection Regulations requires the words “Product of” followed by the name of the country of origin on the labels of all pre-packaged, imported meat products. In addition, Section 31 (2) of the Consumer Packaging and Labelling Regulations requires that pre-packaged products that are wholly manufactured or produced outside of Canada be labelled with the identity and principal place of business in Canada for which the pre-packaged product was manufactured or produced for resale. The identity and principal place of business shall be preceded by the words “imported by” or “imported for”, as the case may be, unless the geographic origin of the pre-packaged product is stated on the label. Meat products that are cut or otherwise processed and re-packed at the retail level are not required to provide an indication of the geographic origin of the product or that they are imported.
I'm just going to reach for another product. Here is a product I picked up yesterday at Costco here in Ottawa. It's a Hormel product. It's clearly identified “Product of the United States”. This particular package is actually fully compliant.
But this one, interestingly enough, unlike Canada.... And in my mind--this is my personal opinion--the United States label is clearer. Here they say, “U.S. inspected and passed by Department of Agriculture”. That's what their stamp says. Our says “Canada” with a crown and a number, and theirs says “U.S. inspected and passed by Department of Agriculture”. I'll pass this around. It's fully cooked, so we can have some of that too.
So if a retailer sells an intact muscle cut, such as a pork loin, from the United States in a vacuum-packed plastic bag and simply attaches a price on it, he's in violation of the current meat inspection regulations if they don't indicate “Product of the United States” on it. We brought this to the agency's attention because we feel this is a current regulation and it should be enforced. However, if the store takes that loin out of the plastic packaging and they cut it up into ten pieces and put it out for retail, they do not have to put “Product of the United States” on it.
We have to be careful, though. There is a growing “case-ready” market here in Canada where retailers, for food safety and efficiency reasons, no longer have an in-house butcher who cuts up the meat. Instead, the retailer is supplied daily by a specialized meat cutter who wraps, cuts, weighs, and labels the meat for the retailer.
This actually often results in a superior product with longer shelf life. One of our members, for instance, who specializes in this is a veal processor who has production farms and meat processing facilities on both sides of the border. He sometimes needs to bring in meat from just across the border from his own farms and processing facilities just to fill his product orders here in Canada because he can't get enough veal here. How will his business be affected by the proposed rules?
As well--and I'll be wrapping up shortly--how does a company like Piller's,which has been in business for a great many years as a family-owned business with really high-quality product.... They have been sourcing meat from Canada, the United States, Australia, New Zealand, and Uruguay. How will these regulations affect their business?
Of course, as we debate this issue here in Canada, we can't forget that the Americans are putting in place country-of-origin labelling in which they have taken no regard for international regulations. It's been a long process; it's been a clear process. We don't like the process, and we don't like what's happening, but we're going to be severely disadvantaged probably around September of this year.
We fully supported the Government of Canada's opposition to this. Nevertheless, of course they're moving forward.
In wrapping up, of course there are several rules and regulations that are affecting the meat industry. There is the Uruguay Round of WTO harmonization of rules of origin. There is the Canada Customs Tariff Act of 1997. There is the Consumer Packaging and Labelling Act. There is the Meat Inspection Act, the meat inspection regulations, the meat hygiene manual of procedures, which is about 1,200 pages long. So if you are ever bored and can't sleep at night, you can read that.
So it's a very complicated issue. It sounds simple, but we urge you to do an in-depth review of all this and to take into consideration what real life things are happening before the decisions are made.
I will pass around a few other products. There is a fully cooked pork product made right in Toronto, a fantastic product. Here are some wieners, some Maple Leaf bacon. What could be more Canadian than that? Pass that around and see if you see any “Product of Canada” on it.
There is some lovely ham kielbasa. Again, it has the meat inspection legend on it but no “Product of Canada”.
Thank you very much. I look forward to your questions.
:
Thank you, Mr. Chairman.
Thank you for the opportunity to present our views on this important subject. We certainly agree it's worthy of a look at this whole issue, and I agree with what my colleague has already given you in terms of some of the issues surrounding it.
I don't think I need to remind committee members of the importance of the food industry to Canada, but given what's happened to the dollar recently, I just want to remind you that this is our second-largest industry in Canada. It has tremendous opportunities. We're in a golden age of agriculture right now, and certainly we're as nervous as anyone about making any wholesale changes to labelling regulations that could add costs while we're in this opportunity around the world and with Canadian consumers as well. The landscape is definitely changing, but we always have to keep our eye on the cost side when we're doing things.
Current Canadian labelling regulations support a variety of widely accepted practices, which for the most part are well understood by consumers. The labelling regulations that we have in Canada today are based very much on international practices, and often Canadian labelling regulations are copied in other countries. So Canada is a bit of a leader when it comes to labelling, and that's good.
These labelling practices are not unique to agriculture and food. Another important fact to understand here is that a lot of the things we're talking about when it comes to labelling, the principles that underline our labelling legislation, are very much founded somewhat in our tax laws and in our tariff codes and those kinds of things. So what you find in food, you would also find in furniture, for example, and automobiles. So this 51% business really didn't come from the food industry; it really came from the automobile industry and the furniture industry and some of the other industries where foreign content was a big issue and became a policy issue.
For example, if you look at “Made in Canada”, the general perception is that at least 51% or more of the content by value or material is Canadian, and that's widely understood. Just because you say “Made in Canada” or “Made in China”--all the gifts that we get at Christmas-time made in China--doesn't necessarily mean that all the ingredients came from China. I can understand consumers wanting to know where the ingredients come from, but that's not exactly what we're talking about here.
The “Made in Canada” label or statement on the label, the claim on the label, is simply saying that it's manufactured in Canada, and I think most people understand that. Tariff rules are based on this concept. And similarly, if a food--and I think Jim's already talked to you about that--has 51% foreign content, it's usually labelled that way, and it should be labelled that way. If it isn't, it's an enforcement issue.
Then you look at that grade A inspection stamp that appears on a lot of products, or Canada grade of some kind, and the Canada inspection legend, which all of you have seen on these packages that Jim's been passing around--that indicates there's been some Canadian oversight to that particular product. That Canadian oversight means the product met the Canadian rules or there was a Canadian inspector in the plant where the product was produced. So that gives consumers confidence that there's Canadian oversight, but it doesn't convey the idea that it's Canadian content in terms of 100% Canadian content. It may very well be, but that isn't what this is trying to say.
Imports can become Canadian. You've recognized that, and certainly that happens in our plants all the time. This again is a very well-established international kind of approach where we, in the food industry at least, have some kind of understanding internationally now that when you have a chapter change in the harmonized code, so you bring in your meat in a fresh form, uncut, maybe in big chunks, and you then put it in a Canadian plant and you cook it, you wind up cutting it, you wind up processing it, you wind up putting it in pieces and bags and all those wonderful products that you've just seen, that becomes Canadian in the sense that it now can bear the Canadian inspection legend and it can be called a product of Canada, but in most cases we don't bother with that claim. It is simply produced with the inspection legend on it and as a result imported product can appear to be Canadian, at least to some people.
“Product of Canada”, the just-revised chapter 7 of the manual of procedures--and I mean “just”, like last week, so I encourage you to take a look at it, because that chapter is the labelling chapter--encourages federal plants to show the words “Product of Canada”. So CFIA is now telling us to please start using these words “Product of Canada” because a lot of importing countries are demanding that you do this, and of course it's up to the exporting country to meet the importing country's rules. And of course our plants will start to do that, because you don't want to have one label with “Product of Canada” on it and the other label not with the “Product of Canada”.
One of the most expensive things we can do in our industry is to segregate, so if you're forced to make two labels for two markets that's a huge cost for a plant. Segregation means big problems. So we definitely want to avoid that.
You've been recently hearing a lot, certainly from the Canadian Federation of Agriculture and grassroot agricultural organizations, that maybe we need something called “Grown in Canada”, and certainly the U.S. is now looking at “raised” and “born” in the U.S. We're going to see more and more countries start to work in that area, and we certainly have no difficulty if you want to look at a new label, a new claim that says “Grown in Canada” or something to that effect, communicating 100% Canadian.
We would urge you to use the organic labelling exercise, which took three years to get to. This organic label that Canada now has and is now being used is an excellent example of how you can go. What it means is that we have a voluntary organic label and we've got a third-party verification backing it up so that you know as a consumer that the word “organic”, when it comes on the label like that, has something backing it up.
It's the same thing here. If we want a 100% or 95% or 80% Canadian label, we need something to back that up, especially if you want to start saying this is a good quality product, it's a safe product. You can't make those kinds of claims on there if you don't have something backing it up. So you need that third-party verification, and we would think that's a good way to go, but it will take certainly some good thinking to get there.
I think the other thing that is very clear from you having to have hearings on this subject and the kind of input that you're getting from various organizations is that no matter what we have as labelling right now, and what we're going to try to do in the future, it needs an effective communication strategy along with it, because we need to let the consumers know what we're doing and what the labels mean. I don't think we've done a good job in that area.
I'd leave it there, Mr. Chairman.
:
Thank you, and thanks very much for this opportunity.
I would like to relay to you that there's a lot of interest and debate within the Canadian poultry processing sector about this issue. In fact, I received two e-mails this morning as I was sitting in the chair behind me, one from a chicken processor in Newfoundland and one from an egg grader in Nova Scotia. I guess they are first up, so I'll probably get some more during the day.
I just relay this so that you understand there's a lot of interest within our group, and also to let you know that as of now I don't have consensus as to where we should actually go. I understand the position you're in, but we will need more discussion. We will need more debate. We will need to stay engaged.
Briefly, I'll describe who the Canadian Poultry and Egg Processors Council is. We're the national trade organization that represents the interests of more than 170 Canadian poultry processors, egg processors, and hatcheries. In addition, our membership includes over 60 national and international industry partners who have joined us as associate members.
Representing some of the largest agrifood corporations in Canada, our member companies process over 90% of Canada's chicken, turkey, eggs, and hatching eggs. This economic activity generates approximately $5 billion in retail sales. To accomplish this, our members have invested over $1.5 billion in plant and equipment and directly employ more than 17,000 Canadians.
Our poultry and egg processing members purchase the majority of their agricultural raw inputs, the live chicken, the live turkey, the eggs, from Canadian farmers who operate in a supply-managed industry. In addition, though, our members supplement these inputs with imported chicken, turkey, and egg products in amounts that are limited by Canada's WTO and/or NAFTA commitments.
Now I want to quickly discuss the current “Product of Canada” labelling, at least as we understand it. And it will be very much a high overview, because I don't want to just repeat what my friends here who have preceded me have said.
Canadian poultry and egg processing companies understand that the basic requirements for the current “Product of Canada” label are really twofold: one, at least 51% of the total direct manufacturing or processing costs must be Canadian; and two, a final significant processing must have been done in Canada.
For example, in our egg sector, if one of my members brings in ungraded eggs from the United States, washes, candles, grades them, sizes them and packages them and puts them into retail, although that's covered the 51% hurdle, it has not covered the final significant processing cost issue, and therefore it cannot be labelled “Product of Canada”; it must be labelled “Product of the United States”.
If he takes those same eggs, brings them in, breaks them, further processes them somehow into mélange or dried product or whatever, that now can become a product of Canada. That's our understanding.
There are varying levels of support for the current “Product of Canada” labelling from within my group--from the definition of significant processing is too strict, some people believe; to support for the current regulations the way they are, because they are understood and they make sense; to a belief that there should actually be a requirement for the chicken, turkey, or eggs to have been grown or produced in Canada. That's where I am.
However, it is important that the current labelling rules be strictly enforced. Mr. Laws explained that. We would like to reinforce that. Whatever is there has to have integrity and it has to be enforced.
Supporting arguments from among CPEPC members for the current “Product of Canada” labelling requirements include the argument that our imported chicken, turkey, or egg raw material is subject to equivalent standards for food safety. When we import from countries that are allowed to send product to us, that is equivalent product for food safety--not equal, but equivalent.
The ability to import additional product to augment our domestic production within the supply management environment is critical. Putting it through our processing and further processing systems with our HACCP, our own company QA systems, CFI federal inspection, etc., and then labelling it as product of Canada is consistent with Canadian and company food safety and quality goals. It dovetails with company and private label branding programs.
Our members have a big investment in their brands. That means a commitment to quality and food safety, and that's what it says when you've got a “Product of Canada” label. It is valuable for the protection of investment and jobs in Canada, particularly for the production of non-ICL products that are allowed to enter Canada without tariff in the poultry business.
Those are supporting arguments for continuing with the current “Product of Canada” labelling as we understand it, as I explained earlier.
Supporting arguments from among CPEPC members for a revision to the “Product of Canada” or alternative wording label regime based on the origin of the primary agricultural ingredient or the product--i.e., the chicken, turkey, or eggs must be grown in Canada--include that it gives an advantage to products produced with Canadian ingredients, which is the vast majority of what my members use. The vast majority of what my members buy are Canadian ingredients. This could become even more important, depending on the results of the current Doha round of negotiations at the WTO, future bilateral trade agreements that are always ongoing, fluctuations of the Canadian dollar, etc. So I've got both sides of the coin.
I'll turn briefly to the concept of a “country of origin” type of label. It appears that consumers place value on knowing where products are raised or grown. That's fine. An alternative that has been promoted by various organizations--as Mr. de Valk has mentioned--such as a “Grown in Canada” label could get industry support. The big question in my mind is, should it replace the current “Product of Canada” label rules, or should it be in addition to? Either way--just to stress this again--the importance of standards and label integrity must be preserved.
Mr. de Valk's idea of using a third party to establish this is a good idea as far as I'm concerned. It should be audited. It must be enforced. When Mr. Laws finds an example of a situation that is not enforced, that's not right. No matter how we use this label--over and above, or as a substitute for what we've got today--it has to be enforced. If it is to be in addition to the current “Product of Canada” label and rules, then it could be modelled after some existing provincial programs: Foodland Ontario, Taste of Manitoba, etc. We have models that we could use. It would certainly be voluntary.
We must be careful that it does not undermine the current “Product of Canada” label for poultry and egg products. We cannot allow it to make marketing claims regarding superior food safety or quality, because that's just not the case. It cannot either mislead or confuse customers. You cannot say it's superior food quality or food safety. As I explained before, our members put their brands on these products. The raw material coming in is equivalent. The product that is being produced today is safe, wholesome, and is of good quality.
It cannot add additional cost to Canadian food processing companies--the whole idea of segregation, etc., that's already been mentioned.
It can't confuse consumers either. The issue is if we have two labels--the “Product of Canada” label today and then a new “Grown in Canada” label--and they're side by side, is that going to be confusing? That's going to be a challenge. Therefore, another comment Mr. de Valk made that I would also like to support is that we're going to need a well-thought-out communication plan as we go forward on this.
At the end of the day, we appreciate the opportunity to engage in the discussions concerning this topic. We'd like to continue to be involved as the issue progresses. As I noted at the outset, there's a lot of interest and engagement by my members. We plan to fully debate this over the course of the next coming months, try to arrive at a consensus, and if we do, we'll certainly be back to let you know about that. Either way, we'd like to stay engaged.
Thank you very much.
:
So maybe I will be able to have 12 minutes, rather than 10. That's what I think. Okay, let's go for that agreement.
[Translation]
So, it is indispensable to review Canadian designations used in labelling, in order to adapt them to today's realities.
The current definition of “Product of Canada” is obsolete and leads to confusion as to the real origin of products identified with this designation.
Under current regulations, a product may be labelled “Product of Canada” if 51 per cent of the total cost of producing the product is Canadian. A multitude of products containing imported raw materials can thus be labelled “Product of Canada”, even though they may only be processed and sometimes only packaged in Canada. These regulations mean that there is no difference on grocery store shelves between cucumbers imported from Asia or produced in Canada. As long as they have been processed in Canada, imported products can be labelled “Product of Canada”.
As for products grown and processed in Canada, they will not necessarily be labelled “Product of Canada”, because it is optional for the industry to identify them as such, at least in the marinade industry.
How can the consumer figure all of this out? And, what about the hotel, restaurant and institutional sector? For example, the purchasing policy of several governments, including the Government of Quebec, is based on the purchase of foods identified as Product of Canada”. However, if the term “Product of Canada” is not well defined, people will be buying imported products labelled with an inaccurate designation.
In order to ensure that consumers have an accurate and clear understanding of the origin of a product, only products grown and processed in Canada should be labelled “Product of Canada”.
Moreover, under the current regulations, if there were to be a food safety problem with an imported product, all Canadian production would be affected.
The same is true for the grading regulations. Currently, frozen products imported in bulk and packaged in Canada are sometimes labelled with the real origin of the producing country, but also indicate “Canada Fancy (A)”, “Canada Choice (B)” or other grade. Once again, use of the term “Canada” to identify the grade may confuse consumers, who believe they are buying a Canadian product, when that is not at all the case, if they carefully check the label.
A product of foreign origin should be labelled “Fancy (A)”, “Choice (B)”, or “Other grade”, and not be associated with the term “Canada”. The changes requested to the definition of the “Product of Canada” designation and the use of “Canada” grading standards are intended to provide consumers with consistent and accurate information.
This proposal is in no way intended to diminish the economic contribution of Quebec and Canadian processors who process or package products containing imported raw materials. We are of the opinion that these products should be labelled “Prepared in Canada” or “Packaged in Canada”, but not “Product of Canada”.
We would like to make the following recommendations. To respond to consumer requests for credible and accurate information, our suggestion is that the designation “Product of Canada” be reserved for products whose raw materials have been grown and processed in Canada.
The designation “Prepared in Canada” or “Packaged in Canada” would be reserved for products whose raw materials come from outside Canada, but that have been prepared or packaged in Canada. Those products should also indicate the actual origin of the raw material.
Finally, we are asking that the grade “Canada” be reserved exclusively for products that meet the actual definition of “Product of Canada”.
We are also proposing a second step, which is to adapt the « Canada Brand » to the Canadian domestic market. This concept, which was developed for export markets, could serve consumers well by making it easier for them to purchase goods on store shelves. Once again, in order to respond to the needs expressed by consumers, we are recommending that the “Branding Canada” concept be adapted to the Canadian domestic market. The use of this identifier would be permitted only on products meeting the criteria for the redefined “Product of Canada” designation.
Furthermore, we are proposing that a consumer awareness campaign be undertaken. Surveys show that consumers want to encourage local industries and are asking that it be easier for them to choose products in the store, through better identification of Canadian products.
We are also seeking a partnership with the federal government, in order to carry out a Canadian consumer awareness campaign on the importance of buying products of domestic origin.
It is essential to make consumers aware of the advantages of buying locally: food quality and safety; job creation and the economy; protection of the environment and support for sustainable agriculture; and, maintenance of our food sovereignty.
I'm sure you will agree that the agri-food sector deserves special attention when it comes to the identification of its products. Our food, even our health, are at stake. Let's not forget that. The measures we are proposing are cost-effective for the government, beneficial for Canadian agriculture, and address repeated requests by consumers, who are demanding that it be easier for them to identify Canadian products on store shelves.
Our brief provides some examples that illustrate today's discussion. In the section entitled “Aberrations”, there are pictures of products with the “Canada A” label on them. If you look at the picture located directly to the right of that one, you will see that this product is actually from China. The same holds true for the second example. In this case, it is a bag of green peas with the label “Canada A”, although the product is actually from Poland. These kinds of aberrations confuse consumers when they are buying products. They don't take the time to study the labels. The last example is the most egregious one. These are olives that are supposedly a product of Canada. However, we have yet to find any place in this country where olives are grown.
I referred earlier to plant closures and the fact that products that were replaced by other products from elsewhere still use the private brand labels. That is the case for a variety of Canadian trademarks. If you look on the back of this jar of cucumbers, for example, you can see that the product is from India. The problem is the same in the retail stores. When consumers choose a product on the shelf, for them it is just another product, whether it's from Canada or Thailand.
The “branding” that we're proposing would be that Canadian products be sufficiently well identified on the visible part of the package for consumers to quickly identify them on store shelves.
On the last page, we are suggesting that Canadian products be better identified on store shelves, that the term “Product of Canada” be redefined, that the use of grades be limited to products that are really Canadian and that, finally, the term “Canada Brand” be used as well, although a consumer awareness campaign would be necessary in order to promote Canadian agriculture.
What I am suggesting here is not impossible. At my local grocery store, I found salmon products that use the term « Canada Brand ». The problem is that, because of the current definition, I have no way of knowing whether the salmon in the container actually comes from Canada. It may, but it may also come from somewhere else.
As regards the term “Product of Canada”, once we have cleaned things up, a designation such as this will ensure that no one makes a mistake.
Thank you for your kind attention, and hope that this will yield positive results.
:
Good morning everyone. Thank you for the opportunity to appear before you today and present our position.
I would like to point out, right from the beginning, that CTAC has already provided its feedback on the food and consumer product safety action plan to the Department of Agriculture and Agri-Food, as well as the Department of Health. Therefore, we will be covering the same points relating to the identification of products of Canada.
On the one hand, we believe it is now essential, in a globalized world where there are more and more questions being asked about the origin of products, to provide credible information. Processors are aware that consumers want to be better informed with respect to the origin of the food products they purchase. The current definition of the designation used to identify products of Canada must be reviewed, because it does not identify the origin of the content of the products consumers purchase. At the present time, when 51 per cent of the production costs are Canadian, a product can be labelled “Product of Canada”. That is the reason why many processed products are labelled “Product of Canada”, even though, in reality, the primary raw materials come from outside the country.
The same applies to designations of grades in the processed food and vegetable sector. Apples imported from the United States are processed into apple sauce that is then labelled both “Canada Fancy”, and “Product of Canada”, based on the 51 per cent rule. This term relates to the grade, but its interpretation can lead to confusion. Identification of the grade should also be revisited, in order to ensure consistency with new regulations relating to the designations “Product of Canada” and “Prepared in Canada”.
Furthermore, it is our belief that, when food safety problems occur or a food product is recalled, it is important for products that have been processed in Canada to be easily differentiated from imported goods, the raw materials of which do not come from Canada. Consumers have to be able to more easily identify Canadian products, and not confuse them with imported ones. A credible and consistent policy would reassure consumers and encourage them to make enlightened choices. For example, contamination of carrot juice produced in the United States should not have repercussions for all carrot juices produced and sold in Canada.
How are processed products identified? With respect to agricultural products that are sold as is, it is simple enough to distinguish between something labelled “Product of Canada” and something that is not a product of Canada. The situation becomes more complicated when products from different countries are mixed together in a single package. There the proportion of Canadian content must be identified in order for the product to be labelled a “Product of Canada”.
The problem is no different for products processed in Canada. What products are allowed to be labelled “Product of Canada”? Based on what percentage of Canadian content should foods processed in Canada be authorized to use that designation? As regards “Product of Canada” and “Prepared in Canada”, we are proposing definitions similar to those used for “Product of Quebec” and “Prepared in Quebec”, which are accepted by the food industry.
The “Product of Canada” designation should be used for any product that is entirely Canadian or 80 per cent of the main ingredients of which are of Canadian origin, and for which all the processing and packaging are carried out in Canada. We believe that the standard of 80 per cent Canadian content is both an accepted and realistic one, considering that most blended foods contain exotic ingredients, such as olive oil, wine or other ingredients not available in Canada. The 80 per cent standard also comes from a consumer study. That study concludes that 80 per cent Canadian ingredients is an acceptable threshold for a food to be identified as “Quebec food product”.
One could consider a food to be “Prepared in Canada” when at least 50 per cent of its ingredients are of Canadian origin and at least 80 per cent of the costs associated with its manufacture are incurred in Canada, and the processing and packaging of the product also occurred in Canada. If the raw materials are not available in adequate quantities or are not of adequate quality in Canada, they may come from somewhere else. In that case, all the processing, preparation and packaging must be carried out in Canada.
In order to arrive at a realistic identification concept, certain conditions have to be set before a new policy for identifying Canadian products can be introduced. To begin with, a guarantee of the origin of the ingredients is absolutely essential in order for product origin to be traced.
That means ensuring that processors have comprehensive and functional systems for retracing the origin of all ingredients. That way, country information on packaging would be verifiable.
Producers who use the designations “Organic” and “Controlled Designation” are already required to ensure the validity of their claims through traceability mechanisms. The same should apply to claims related to origin.
Another point is extremely important: the identification of the source of imported ingredients. A very wide variety of ingredients purchased by Canadian companies transit through many different countries. As a result, it is not rare for ingredients, sub-ingredients of ingredients, or a proportion of ingredients purchased in the United States to actually come from China, Mexico or other countries, even though it is not mentioned on the package. Identification of their origin would allow processors to make enlightened choices and would facilitate proper enforcement of the designations “Product of Canada” and “Prepared in Canada”
Thank you.
:
It makes no sense to consider a single label. You talked about jobs, and we also believe that the manufacturing industry generates significant numbers of jobs that need to be protected. That is why we think there should be several different labels. As far as we are concerned, Ms. Thi Lac, it is absolutely essential that the “Product of Canada” designation be redefined. When you sell a product labelled as a “Product of Canada”, the primary raw materials used to produce the product have to be Canadian.
Ms. Jean and Ms. Cloutier from CTAC said that at least 80 per cent of the raw materials should be Canadian. Our approach is similar, but slightly different. We believe that, when a consumer buys a jar of dill pickles, what he is interested in eating are pickles, rather than dill. If the dill comes from Holland, as agricultural producers, we will not be upset. However, a Canadian product must contain cucumbers that come from Canada. It is essential that the raw materials used to produce the product that the consumer buys be Canadian.
There are two steps here. In order to properly identify and differentiate a product from all the others, you absolutely must use the “Canada Brand” concurrently. If that is the case, consumers will no longer be misled. In addition, retailers will have an incentive to meet real consumer needs and include, among their private brand products, some that have that label.
I would just like to make one correction. It was stated earlier that, when a product is packaged in India, it says “Product of India”. However, it is rare for products to be placed on store shelves on the basis of their origin. We are more likely to organize displays based on the brand. There can be Canadian products and Indian products, but the consumer is not aware of their origin. That is precisely the reason why we would like the “Product of Canada” designation to be used hand in hand with “Canada Brand”. If the product is from India, it will not have that label. Consumers will make their choice based on the price. We will not be imposing anything on them, but they will be able to make an enlightened choice.
Having said that, we think it is appropriate to have several different designations, including “Product prepared in Canada”. In our region—I'm from the same region as you—a company like Les Industries Lassonde imports fruit juice from all across the globe, but produces a Canadian product that generates thousands of jobs. It is entitled to use the designation “Product prepared in Canada”, or something similar. However, I would not agree to the idea of this kind of product being labelled “Canada Brand”. I believe that designation should be reserved exclusively for Canadian products.
:
Thank you, Mr. Chair. I want to save a bit of time here for Ken, if we can.
I think what we're trying to get at here is truth in labelling. As Mr. McDuff said at the conclusion of his remarks, we're trying to identify what is in the package. I think you'll find, regardless of political stripe around this table, we all want to get there and find a way of getting there. So we're looking at truth in labelling.
First, on the COOL, the country-of-origin labelling, that's going to be the reality. There's no question. Both the previous government and this government have fought that issue hard. I'm a member of the Canada-U.S. committee. We fought that issue hard. We've lost it, and that's going to be the reality.
I guess we have to look not only at identifying for consumers what's on the shelves, but also at what we have to do in our industry to protect our interests on this North American continent when COOL is the reality. So if you have any suggestions on that, I'd love to hear them.
A lot of questions have been asked on the labelling side itself, but on the more technical side, there's no question that when you change a label it costs you money. Part of the problem with “Product of Canada” is that the very word itself, “product”, makes you assume it's what's in the package. So that labelling is altogether wrong, and I think we have to either go to “packaged” or “prepared” or whatever, and identify what's in the product somehow as Canadian.
On your end, what is the cost of labelling in Canada? How do we compare with our major competitors? Regardless, I want to see us buying Canadian product, but if we put a cost burden on the people who package or process that product, which makes a Canadian product more expensive when it ends up on the grocery store shelves, we're kind of shooting ourselves in the foot too.
So can you give us any idea what we need to do on that end to ensure that the cost burden of changing the labelling and making it work to identify a product does not make us less competitive?
Then we'll go to Ken.
:
You really hit the point that's going to bog this whole discussion down. Nutritional labelling was a very interesting exercise and very costly to the industry, but we're there now and we're doing it. But the allergen situation has also been very interesting and challenging.
We're very good as an industry right now, in Canada, in identifying the major allergens. You're probably wondering why we get so many recalls, and 50% of the recalls are related to allergens. We're finding that's because we're drilling down deeper and deeper, and we're now getting into flavours and into allergens that have 0.001% of something, an ingredient that we didn't realize came from a country that we didn't realize, because our flavour manufacturer forgot to mention it.
Where do you want to start with ingredient tracing? We're getting a heck of lot better at it as an industry in traceability, but we're finding out a lot of surprises still, as well. If the consumer wants to know where every identifiable ingredient to the 0.11% or detectable level comes from, you'll never, never get to that point.
In the codex, volume 2, we've decided we're going to cut the line. We're not going to use zero, we're going to use a trace. If you find a trace amount, we're not going to be worried about it, but if it's more than trace, then we are going to get worried about it.
We have to get pragmatic like this, so the key is going to be the definition. If we're going to have a “Grown in Canada” label, we have to define it, and it's going to be maybe a different definition for meat from that for vegetables, which is quite acceptable. I think that can be done. But I think the key is the definition, and if we keep that definition reasonable, we'll make a lot of progress quickly and keep the costs down.
:
Thank you, Mr. Chairman.
First of all, I am not a permanent member of the Standing Committee on Agriculture and Agri-Food. I am replacing Mr. Bellavance this morning.
I found this morning's discussions very interesting and I particularly appreciated the excellent brief presented by Mr. McDuff and Mr. Lacoste this morning. Not only do they demonstrate their concerns in this brief, but they even go so far as to make recommendations. I want to commend them on that.
I love the idea—and fully support it, Mr. Chairman—of identifying products that are grown or produced, processed and packaged in Canada by using a specific symbol, such as the maple leaf. As a member of the Bloc Québécois, I have to say I am not particularly keen on seeing a maple leaf on my cans of baked beans, cereal boxes and other items. At one point, the government would have paid a lot of money to companies to get them to use the maple leaf on their cans of baked beans, soft boiled eggs and pork tongue. In the bars, the maple leaf would have been everywhere. Some companies would have made a lot of money that way. You are offering them an absolute gold mine by allowing them to put a maple leaf on all Canadian products sold in grocery stores, at the meat counter and the fruit and vegetable counters.
Federalists have a golden opportunity here—namely, to endorse this idea wholeheartedly and include it in the report. We will support you, not because we love the maple leaf, but because it will be an opportunity for our Quebec and Canadian producers to create jobs, keep their businesses going, give work to people back home and encourage people to buy our own products.
If I have a choice between products made in Quebec, in the riding of my colleague, the member for , or products that come from Thailand, I will choose products that come from her area, without hesitation. Maybe one day, in a less distant future than some may believe, we will see—although we would have to find some room for it on the can—a small fleur de lys.
Thank you, Mr. Chairman.
:
Thank you, Mr. Chairman, and thank you to the witnesses for coming out today.
One of the things that was mentioned, and I believe part of why we're doing this, is that everyone has talked about the level of frustration and the complexity of doing it, and I think we need to be clear that this is why we're having so much discussion with those involved, because if we want to do this, it will not be a government solution; this is going to have to be a solution by the stakeholders, which the government will put forward. I think, as Mr. St. Amand mentioned earlier, the government needs to take a lead, and I think that's why this government is taking the lead.
Mr. de Valk, you mentioned one thing, and I may have heard you incorrectly, but you said that most people do understand the labelling. In my family I don't think they do. They believe they do until you explain it to them, and then they don't. Quite honestly, they now feel misled. So when we go through this process, not only is it going to be a process that has to talk about proper labelling, but it also has to be marketed so that the people of Canada understand what the labelling means.
I also believe, and I may be wrong, that if you were to talk to people here, they would say that our families are now more cognizant of labelling than I was when growing up. So why is that? The world has become smaller; products come in from all over the place. We used to have some confidence, because we grew so much more in Canada and we didn't have nearly the variety we do today.
You talked about it in terms of registration and the frustration we have in terms of our competitiveness with our largest trading partner, the United States, where they wait just seven days. In Canada there's been a frustration for years, you said, to get that type of registration for label changing. It costs you $100, and then every minor change it's another $45—and every time you do that it always rings of bureaucracy to me. So do you have some suggestions of what we can do to help or change that, Mr. de Valk?
:
Thank you very much, Mr. Chair.
I'd just like to raise a couple of issues.
I appreciate Mr. Easter's intervention on this. I would like to note two things, however. One, if Mr. Easter truly is concerned about our western producers and the $175 million that was reported from the Canadian Wheat Board as well as the Agriculture Producers Association of Saskatchewan and the Wild Rose Agriculture Producers, then he will realize that playing partisan politics with this is not the way to go.
I quote Mr. Easter: “A full examination into the costs railways are imposing on western...farmers...” is needed. This comes off his own website. If this is truly what he wants to do, then this motion will ascribe to that. He, as well as everybody else around this table, knows that playing partisan politics with this is not going to advance the cause of our western producers, so that is reason enough not to do this.
The second point I'd like to raise, Mr. Chairman, is that if you refer to Marleau and Montpetit, page 453, chapter 12, under “The Process of Debate”, any time an amendment “introduces a new proposition which should properly be the subject of a substantive motion with notice”, it is no longer in order as an amendment to a motion. This is something that is substantive.
If Mr. Easter really wants to get something done with this, we could have a motion come forward to have the Minister of Transport come here for whatever length of time he feels necessary in order to ask about the progress on this. But at the end of the day, we don't need to have partisan politics from the Conservative or Liberal side on this.