Submissions

CFA recommends the following revisions to the proposed guidance:

– Modify the guidance document to ensure the common name and brand name of plantbased alternatives to egg products prohibit the use of the term “egg.”2
– Adopt an accurate and transparent approach to common names by implementing a structure that requires plant-based alternatives to egg products to use descriptive naming.
– Implement firm rules to prevent the use of terms typically reserved for and associated with eggs such as omelette, frittata, quiche, scramble and meringue on the label, packaging and
advertising of plant-based alternatives to egg products.
– Ensure any plant-based alternatives to egg products that includes “protein” in their common name and/or brand name, achieves a protein quality rating using PER (Protein Efficiency
Ratio) of at least 20 to remain compliant with Food and Drug Regulation (FDR) B.01.305.

A joint letter signed by 21 organizations was sent to the Minister of Finance with the following recommendations:

– We urge the government to simplify the Canadian Entrepreneur’s Incentive and broaden its eligibility to all sectors to support equity, simplicity, and transparency.

– We urge you to scrap the increase in the inclusion rate to 66.7%, which will affect many business owners who are part of Canada’s middle or aspiring middle class.

– The increase in the Lifetime Capital Gains Exemption and its indexation into the future are welcomed announcements and should be retained and protected.

The CFA recommends the workshops to draw upon farm-level experiences, in addition to identifying strategies and best practices that increase the farmers’ resilience, reduce GHG emissions, and sequester carbon at scale.

CFA would also like to be engaged with ECCC when building Canada’s Nationally Determined Contributions (NDCs) and Canada’s 2035 Emissions Reduction Plan.

The programs, and policies to support long-term climate objectives cannot ignore short-term implications for the farmers’ ability to face the immediate threats of climate change while maintaining the viability of their operations and delivering on food security objectives.

CFA does not support the continued use of a single positive sample as the threshold for an index field. Spore detection should be confirmed in two separate samples within the same field before the field is classified as an index field.

The CFA supports the addition of a viability assessment for spores detected in potato fields when no visible tuber symptoms are observed.

The CFA supports the new “Field of concern” classification, as it would address some of the risk to the industry, associated with false positive or false negative test results. However, we suggest the following wording: “A field where spores in only one sample have been detected and confirmed via morphology and molecular analysis will be designated a field of concern.”

The CFA wishes to express some concerns regarding the proposed greenwashing provisions, especially as these provisions could have unintended consequences due to insufficient consultation and undefined terminology, which could lead to a potential increase in frivolous lawsuits, that could have a negative impact on the agricultural sector and be increase the workload of the Bureau’s employees.

We strongly urge you to take immediate steps to ensure the labour disruption between the GWU and the VTEA does not further damage our international reputation and negatively impact Canadians farms and farm families across Canada.

Biosecurity on farms is of great importance to Canadian producers, as well as to Canadians as a whole, as breaches in biosecurity can result in the loss of animals which would impact food security, jeopardize the national food supply, affect international trade relations and the economy, and impact the mental health and wellbeing of producers, their families, and employees. Canadian farmers ask for your support of Bill C-275, An Act to amend the Health of Animals Act (biosecurity on farms) to help ensure the continued biosecurity, safety, and wellbeing of Canadian farms and farm products.

For decades, farmers have focused on reinvesting in their operations to maintain competitiveness, enhance productivity, and continually improve practices to do more with less. For most Canadian farmers, these investments are made with an understanding that the assets they invest in will position them to maintain both the financial health of the business and ensure they can maintain quality of life into retirement. These sudden, fundamental reforms to Canada’s capital gains taxation, undermine plans that are often decades in the making and challenge the financial stability of capital-intensive multi-generational family farm operations.

While national standards are essential, it is crucial that these standards are adaptable to the diverse conditions across Canada’s provinces and territories. Housing challenges vary significantly depending on regional contexts—for instance, seasonal housing shortages in British Columbia, unique conditions in Quebec’s rural areas, and the distinct needs of operations in Nova Scotia. These regional differences must be taken into account to ensure the standards are both effective and feasible.

Transport Canada’s Grade Crossings Regulations do not explicitly state who is responsible for bearing the financial burden associated with the newly mandated safety upgrades. In the past, these upgrades and ongoing maintenance have always been performed by the railways, at the railways expense. Our concern is that in cases where pre-existing agreements are not already in place, the railways are now taking unilateral action to shift the cost burden for maintenance and upgrades of private crossings onto farmers, where they traditionally have done so, under threat of removing an existing and active private railway crossing altogether. Furthermore, we are hearing from our members of cases where farmers have received 30-day notices to close their crossings or that their crossing was removed by a railway without any notice.

The industry supports the safe handling of anhydrous ammonia through the Code of Practice. But, at present, there is no evidence suggesting that change to the current regulations is warranted, or that forcing farmers to have and maintain an expensive ERAP will reduce the number of incidents involving anhydrous ammonia.

Given theses concerns, we request that Transport Canada rescind their proposed amendments to section 1.24 of Transportation of Dangerous Goods Regulations.

The CFA uses the data from the FMS to inform its reporting and messaging on the sustainability, productivity, and innovation within the Canadian agricultural sector. The data allows us to quantify the impact of best practices with validated information to inform policy positions, and advocate for continued development of a resilient agriculture sector in Canada.