Submissions

On January 30th, CFA made a submission to the HUMA Committee as it studies the definition of “work” and the future of Section 107 of the Canada Labour Code. This section is an important tool the federal government can use to help prevent or resolve major labour disputes, especially in rail and port transportation, which farmers rely on heavily.

CFA stressed in the submission that when transportation workers strike or experience lockouts, farmers feel the impact immediately through:
– Higher interest costs due to relying on operating credit
– Demurrage fees and vessel delays
– Lost international market share
– Spoilage of perishable goods

CFA warned that removing Section 107, which has been proposed via Bill C-247, would greatly weaken Canada’s ability to prevent supply chain disruptions, potentially affecting both farm profitability and national food security.

CFA’s high-level recommendation included:
– Launch consultations with affected industries to address root causes of recurring labour disputes.
– Modernize dispute‑resolution processes, building on the 2025 Industrial Inquiry Commission’s recommendations—especially creating a Special Mediator with enhanced powers to ensure good‑faith bargaining.
– Amend Section 87.4(1) of the Labour Code by removing the word “immediate” so the CIRB can act when disruptions threaten essential goods like propane, diesel, or agricultural inputs.

In the submission, CFA highlighted several structural issues in India’s agricultural system that could limit benefits for Canadian exporters and impede market access regardless of tariffs:
– High tariffs and non‑tariff barriers on many agri‑food products
– Strong government intervention, such as price supports and export controls
– Unpredictable policy shifts affecting import demand
– Regulatory differences in inspection, certification, and SPS measures

It noted that while India is the world’s largest consumer of pulses, Canada faces 10–44% tariffs on key pulse crops, and market access to India has historically been disrupted by sudden restriction or administrative hurdles.

CFA urged the federal government to take a pragmatic, risk‑informed approach to any CEPA with India by:
– Prioritizing risk management and supply chain resilience
– Fully protecting sensitive agricultural sectors
– Strengthening SPS and biosecurity safeguards
– Ensuring enforceable commitments and fair dispute settlement
– Maintaining close engagement with farmers throughout negotiations

CFA raised strong concerns in response to PMRA’s proposed special review decision on dicamba. The proposal includes cancelling post‑emergence dicamba use in dicamba‑tolerant soybeans, cancelling dicamba use in seed production, reducing allowable application height in corn, and modifying buffer zones. CFA warns these changes would have significant impacts on weed management, production costs, seed supply, and long‑term farm sustainability.

CFA argued that PMRA has not adequately assessed practical alternatives, which may be less effective, more costly, or could accelerate resistance. Removing dicamba would undermine integrated pest management (IPM) systems, threaten yields, and reduce competitiveness. Seed supply stability could also be negatively affected by cancelling dicamba use in seed production.

CFA stressed that the proposal may unintentionally increase agronomic risk over time by contributing to weed resurgence, more rapid resistance development, and reduced IPM options.

CFA’s recommendation included:
– Pause the current decision process and engage in deeper consultations with farmers, commodity groups, and registrants.
– Assess the full economic and operational impacts on producers, recognizing the central role of dicamba in managing resistant weeds and maintaining crop competitiveness.
– Strengthen PMRA’s consultation and evaluation system, including earlier stakeholder engagement, clearer data transparency, and structured ongoing dialogue.
– Update PMRA’s mandate to include economic impact, competitiveness, and food security considerations in regulatory decisions.

In this submission, CFA emphasized that Canadian farmers rely heavily on rail and marine transport for timely delivery of inputs and products, and disruptions, such as strikes or lockouts, create severe financial and operational consequences, including lost markets, spoiled goods, and reputational damage to Canada as a trading partner.

To address these challenges, CFA recommended:
– stakeholder consultations to prevent recurring disputes
– a transparent and expedited dispute resolution process with a Special Mediator
– amendments to the Canada Labour Code to ensure essential services continue during strikes.

CFA stressed that modernized labour relations are critical to safeguarding food security and maintaining Canada’s competitiveness in global markets.

A coalition of organizations representing Canadian farmers, veterinarians, and animal health stakeholders, including CFA, sent a letter expressing strong support for Health Canada’s plan to implement the Minister of Health’s “Reliance” authority.

This would allow Canada to rely on decisions from trusted foreign regulators to expedite the approval of veterinary drugs, improving access to essential tools for animal health and antimicrobial resistance management.

The coalition urged Health Canada to design a predictable, impactful, and globally aligned process, extend the consultation period to 90 days, and consider expanding the pathway to include Veterinary Health Products in future phases.

This joint letter urges broadening of the Pest Management Regulatory Agency (PMRA) mandate to explicitly include economic considerations, food security, and agricultural competitiveness. This change would:

– Improve agricultural productivity by granting farmers timely access to crop protection innovations.
– Support food affordability and security by preventing significant crop yield losses.
– Enhance Canada’s global competitiveness by making its regulatory system more efficient and predictable.

The letter proposes adding a clause to Article 4(2) of the PCPA to ensure regulation minimizes negative impacts on productivity, food security, and competitiveness. It emphasizes that these changes could unlock over $100 billion in GDP growth over the next decade and calls for decisive action through the Budget Implementation Act.

CFA signed onto a joint letter which was sent to the Minister of Finance. This joint letter urges broadening of the Pest Management Regulatory Agency (PMRA) mandate to explicitly include economic considerations, food security, and agricultural competitiveness. This change would:

– Improve agricultural productivity by granting farmers timely access to crop protection innovations.
– Support food affordability and security by preventing significant crop yield losses.
– Enhance Canada’s global competitiveness by making its regulatory system more efficient and predictable.

The letter proposes adding a clause to Article 4(2) of the PCPA to ensure regulation minimizes negative impacts on productivity, food security, and competitiveness. It emphasizes that these changes could unlock over $100 billion in GDP growth over the next decade and calls for decisive action through the Budget Implementation Act.

On November 3rd CFA made its submission to the CUSMA review consultation.

The submission outlined the importance of CUSMA for Canadian Agriculture, especially in light of our highly integrated markets and supply chains. At a high level, the submission recommended to:
– Maintain and strengthen the rules-based framework established under CUSMA, including dispute settlement mechanisms.
– Promote regulatory alignment and eliminate non-tariff trade barriers, ensuring that regulation are science-based, transparent, non-discriminatory and predictable.
– Preserve agriculture specific labour programs to support competitiveness.
– Oppose any changes that undermine current market access for Canadian agricultural exporters.
– Preserve the integrity of Canada’s supply management system.
– Ensure efficient and predictable border access.

CFA emphasizes that the farmers’ privilege must remain broadly accessible, enabling producers to save and reuse seeds for their own on-farm use. Any future narrowing of this privilege should be considered only when there is clear support from producers or when agronomic realities make seed saving impractical. Further restrictions must be developed in close consultation with affected farmers and the broader value-chain, ensuring their meaningful involvement in shaping regulatory changes that directly impact their operations.

The Agri-Food Pilot provided a targeted, effective and permanent solution for experienced, non-seasonal workers in critical industries such as meat processing, greenhouse crop production, and livestock farming. These sectors are foundational to Canada’s food security, rural vitality, and economic growth.

In light of these considerations, we urge you to:
1. Reinstate the Agri-Food Pilot as a permanent program.
2. Expand its capacity to be more inclusive and better reflect each sectors’ unique labour demands and Canada’s broader economic growth agenda.
3. Ensure continued support for employers and workers navigating the transition from temporary to permanent residency.

The submission proposed amending these regulations so that it is explicitly stated that agriculture industry associations may sponsor registrations for emergency use of pest control products.

This would clarify to industry that they may also submit applications in circumstances where provincial, territorial, or federal authorities are unable to proceed on a sufficiently timely basis.

The Fall 2025 pre-budget submission outlines a strategic vision for strengthening Canadian agriculture amid rising economic and environmental pressures. CFA emphasizes the sector’s vital role in contributing $150 billion to GDP and supporting 2.3 million jobs. The submission highlights challenges such as rising input costs, labour shortages, climate-related disruptions, and global trade instability. It calls on the federal government to uphold open and rules-based trade under CUSMA, protect supply management, and conduct a comprehensive review of Business Risk Management programs to ensure they meet the evolving needs of producers.

The submission also advocates for regulatory modernization to reduce red tape and enhance competitiveness, noting that small agricultural businesses are disproportionately burdened. It recommends aligning regulations with food security goals, safeguarding critical farm inputs from trade countermeasures, and prioritizing agriculture in the new Trade Diversification Corridor Fund. Additional proposals include increasing interest-free loan limits, reforming labour programs, incentivizing equipment upgrades, modernizing the Canada Grain Act, and mandating Agricultural Impact Assessments for federal projects. The overarching message is clear: agriculture should be viewed as a strategic investment capable of driving significant economic growth and national resilience.