COTA leads the organic industry and government on a wide range of issues affecting the organic sector. The following areas and issues are central to the current work that COTA is active on, but by no means represents the numerous areas of advocacy that COTA engages in.
Call to action
Send your own letter to Government to insist on full transparency of GE
Over the past year, COTA and other associations have been actively opposing CFIA’s proposed guidance that would allow product developers to release some genetically engineered (GE) seeds without any government oversight or mandatory notification. As you know, transparency and traceability of all products of genetic engineering is critical to safeguard organic certifications and protect our sector. The CFIA’s proposal threatens the viability of organic food and farming.
This is a crucial time as a decision from the Government is expected at any moment. It is time for organic businesses leaders to share their collective voices and build on the momentum of the opposition efforts.
Use the template, which can be found HERE to write your own letter. This will allow you to add information on how the changes would impact your business as well as amplify the message.
By post (free postage to any Member of Parliament):
The Honourable Marie-Claude Bibeau
Minister of Agriculture and Agri-Food
House of Commons
The Honourable Jean-Yves Duclos
Minister of Health
House of Commons
The Right Honourable Justin Trudeau
Prime Minister of Canada
House of Commons
More information on CFIA’s Proposed Changes
The Canadian Food Inspection Agency (CFIA) regulates genetically engineered seeds (GMOs) for environmental safety under the authority of the Seeds Regulations Part V which determines which plants are considered “Plants with Novel Traits” (PNTs) and how they are regulated. All the genetically engineered seeds now on the market were approved by the CFIA as PNTs and assessed for safety by independent CFIA regulators before being released into the environment.
However, the CFIA wants to change its interpretation of the regulations to allow most new plants created by gene editing (those with no foreign DNA) to be released without any regulatory oversight. The changes would also exempt some other genetically engineered plants that have a trait previously approved by the CFIA - over time, more and more other GMOs will also be exempt from regulation.
Instead of assessing the environmental safety of all new GMOs, the CFIA proposes to leave some assessments to plant developers themselves. The CFIA proposes to leave it in the hands of plant developers to determine whether their new gene-edited seed needs to be regulated or if it can be released unregulated— a clear conflict of interest. The CFIA would have no access to the safety data, or any other information, about these exempted, unregulated gene-edited plants, and would be less able to monitor them for unexpected effects in the future.
A Major Threat to Organic Markets
The CFIA’s proposal would mean even less transparency about GM seeds in the market and this lack of information would be increase the threat to organic integrity. Organic farming prohibits the use of genetic engineering including the new gene editing techniques, and organic farmers and food businesses work very hard to stop contamination. However, the CFIA’s proposals would allow plant developers to sell gene-edited seed varieties to farmers without revealing that they are products of this genetic engineering technology. Organic farmers and food businesses would be faced with the possibility of unknown, unidentified GMOs on the market. Managing the risk and preventing contamination from these unregulated GMOs would significantly increase the costs for organic farmers, food manufacturers and consumers - for example, due to continuous lab testing to ensure no GMO contamination. If GMO contamination was to happen, it would result in rejection of Canadian organic exports and Canadian domestic consumption. CFIA’s proposals could give a competitive edge to organic businesses from other countries where all new gene-edited GMOs are regulated. An increased threat of contamination could put the reputation of the organic industry at risk.
Seed Patents Risk More Lawsuits Against Organic Farmers
The CFIA’s proposal would significantly expand the ability of biotechnology seed companies to sell GE/GMO seed without transparency and increase the risk of organic farmers being contaminated with GE/GMOs. Organic producers will then be sued for patent infringement. Small farmers have too much to risk when up against a behemoth company that ends up forcing farmers to destroy all their seed variety that may hold some of their patented technology (by drift and adventitious contamination) and pay extensive fines and legal bills. All this when an organic farmer wants to do everything in their power to grow without contamination of prohibited substances. Currently, a small number of companies and institutions have control of gene editing patents. Just three biotechnology companies control 48% of the global seed market and 53% of the global pesticide market.
Outcomes of gene editing are not fully understood
Gene editing can change the function of a plant’s own DNA by silencing or forcing the expression of specific genes, removing genes, and/or changing the location of genes within the genome. It can also add new genetic sequences at specific locations. Gene editing can make radical changes to plants which are not possible through conventional plant breeding methods. With gene editing, plant developers can make changes to specific sites in a plant’s genome, but they do not have complete control over the results. The process of gene editing does not always behave as predicted. In short, full knowledge about gene editing does not exist.
Proposed guidance is not science-based
Science is continuously creating knowledge, and new research reveals new understandings, yet the CFIA’s proposal assumes knowledge about many future gene-edited plants (those that have no foreign DNA). The environmental impacts of future products cannot be known before they are developed, and the products of gene editing will be genetically engineered living organisms that can self-replicate and spread. A regulatory approach that says “we don’t need to know” is fundamentally unscientific. The proposals would also remove the ability of the CFIA to access the corporate science behind these new GMOs. The CFIA would rely on private companies to determine whether their own GM seed is subject to the regulations, with no transparency as to what, if any research supports these decisions. The CFIA’s environmental safety assessments already rely on plant developers own data, which is considered confidential business information. Exempting many new GMOs from independent government review would contradict the CFIA’s commitment to science-based decision-making, and this undermine public trust in both the regulator and the regulated plants.
Conventional farmers agree this is a move in the wrong direction:
The National Farmers Union (NFU) recommends that all genetically engineered seeds, including those developed using gene-editing technology, should be subject to Part V of the Seeds Regulations, to ensure that the CFIA maintains its ability to regulate genetically engineered seed in the public interest.
For More Information:
-For a closer inspection of the text of the CFIA’s proposed regulations, read the NFU’s commentary on the CFIA proposal for deregulating gene-edited plants.
-To read the NFU’s direct response to the CFIA on this issue, please see the NFU Submission to CFIA on Gene Editing Regulatory Guidance.
-To learn more about genome editing, read the Canadian Biotechnology Action Network (CBAN) report Genome Editing in Food and Farming: Risks and Unexpected Consequences.
MORE AREAS OF FOCUS FOR COTA
Advocacy to Reduce Contamination of Organic
We live in a polluted environment which presents increasing challenges for organic agriculture to avoid pesticide drift and adventitious contamination. Farmers don’t live in isolation. To protect organic crops from pesticide spray and drift generated by neighbouring farms, organic farmers must establish buffers. Permanent hedgerows or windbreaks can do the trick or a buffer zone – a distance of at least eight metres between their crops and land where non-permitted substances are used. Buffer zones may need to be larger if there is a greater risk of contamination by, for example, sprays drifting on the wind, fertilizer run-off or cross-pollination by genetically engineered (GMO) crops. For example, organic alfalfa grown for seed must be 3+ km away from genetically-engineered (GMO) alfalfa.
Despite all best efforts, unintentional contamination by the most widely used herbicide, glyphosate, is becoming an even larger issue for organic farmers who do everything in their power to avoid synthetic pesticide drift. To this end, COTA has been studying the impact on the industry which is summarized in our full report and summarized in the Executive Summary.
Health Canada is currently doing a consultation (until July 20, 2021) proposing to increase the maximum residue levels of glyphosate in Canada on key crops. COTA is opposed to such an increase (nearly double the current levels on some product categories) which not only hurts human health, particularly those of young children and babies, it also acts as an antibiotic causing shifts in the soil microbiome, with increased fungi and mycotoxins. In addition, glyphosate also acts as a chelator and binds with and may mobilize protein metals in soil. This briefing note outlines the issues and science that backs the reason why the glyphosate MRLs absolutely should not be increased.
National Organic Data Collection Plan
Having access to reliable data is essential toward ensuring a competitive landscape for organics in Canada. COTA is requesting that the federal government commit to developing a national organic data collection plan in conjunction with the sector.
As part of this plan, COTA is requesting government investment in tools that will enable the sector to better identify market opportunities and risks. In collaboration with a suite of government departments, COTA is eager to participate in a process of strengthening data collection through comprehensive action.
As part of this plan, and to maintain organic integrity and a high degree of consumer trust in organic products, COTA is requesting government funding to develop a publicly-available database of all organic operations in Canada.
Such a database, similar to the Organic Integrity Database in the U.S., would help to deter fraud, increase supply chain transparency for buyers and sellers, and promote market visibility for organic operations. Such a database would be a foundational element of any data collection plan for the sector.
Expanding the Scope of Canadian Organic Regulations
The current Canadian regulations for organics include “food and drink for human consumption and food intended to feed livestock” as well as seed. All other products are beyond the scope of the current regulations leaving several product categories, that are produced organically, excluded. Government-regulated standards for organic body care, natural health and cosmetic products, textiles and pet food should be adopted by the federal government.
Elsewhere in the world, a broader range of products can be certified as organic with governmental oversight. For example, the U.S. has a regulation for agriculturally derived products which include body care and cosmetic products. Many of these products – bearing the U.S.’ organic logo – can be found on store shelves here in Canada.
In Canada, operators can certify to a voluntary organic standard for products that fall outside the current scope of regulation, but the Canada Organic logo cannot be used, and different voluntary standards create uncertainty while weakening public trust. When consumers see the term organic, it should always mean that the product was certified under a strict system of government oversight to ensure uniform standards and common compliance.
COTA would like to work with the federal government to ensure the regulatory framework includes all product categories that are currently being produced organically. It is our ambition to ensure that organic body care, natural health and cosmetic products, textiles and pet foods be incorporated into the Canada Organic Regime. All organically-produced products should be subject to the same degree of government oversight and enforcement as organic food, feed and seed so as to maintain a high level of public trust.