Submissions

Budget 2025 introduced immediate expensing for manufacturing and processing buildings, recognizing the importance of encouraging capital investment in critical production infrastructure. Aligning agricultural building expensing rules with the manufacturing and processing framework would ensure consistent treatment across core production sectors and reinforce Canada’s broader economic objectives under Budget 2025, including the recognition of agriculture as a strategic sector.

Furthermore, extending this tax provision to agricultural buildings would represent a logical and necessary next step to the Prime Minister’s January 26th announcement introducing immediate expensing for greenhouse buildings. Allowing producers to fully write off the cost of agricultural buildings acquired on or after November 4, 2025, and available for use before 2030, would provide critical support at a time when producers face rising capital costs and increasing pressures to expand production and diversify markets at the domestic and international level.

Agricultural buildings—including barns, storage facilities, livestock housing, and controlled‑environment production structures—form the backbone of Canada’s food production capacity. Removing tax‑related barriers to investment will enable producers to modernize operations, adopt innovative technologies, and scale production to meet growing domestic and export demand. Extending immediate expensing to all agricultural buildings would also advance national objectives related to food sovereignty, food security, and affordability.

Canada’s farmers remain heavily dependent on imported phosphorus fertilizers, leaving the sector vulnerable to unpredictable global forces. International market volatility, geopolitical tensions, transportation disruptions, and concentrated supply sources have all contributed to cost instability and supply uncertainty for producers. The risks associated with this reliance were underscored in recent years, when global fertilizer markets experienced significant disruptions—placing both producers and consumers at greater economic risk.

CFA encourages the Government of Canada to prioritize strategic investments, innovation, and regulatory pathways that enable the responsible development of domestic phosphorus production. Strengthening the availability of critical agricultural inputs aligns with national objectives for economic resilience, food security, and the sustainable growth of our sector.

Organizations throughout the food value supply chain have jointly written to the federal Agriculture Minister expressing deep concern over recent AAFC research station closures and cuts to public research capacity. The letter warns that these reductions threaten the productivity, competitiveness, and long‑term resilience of Canadian agriculture by disrupting essential research that cannot be replicated by the private sector, especially breeding programs, long‑term agronomy trials, disease screening, meat quality research, food safety work, and regionally adapted crop development.

The groups emphasize that losing research sites risks multi‑year delays in seed and variety development, the breakdown of long‑term datasets, and the erosion of highly specialized livestock, meat science, and environmental research infrastructure. They also note that industry partners were not adequately consulted before these decisions were made.

To prevent long-term damage, the organizations urge AAFC to delay implementation timelines, establish a clear transition framework to protect core research functions, and create a formal industry advisory committee to guide the process.

On February 13th, CFA delivered its submission to the Standing Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities study on the impacts of Temporary Foreign Workers (TFW) on the labour market.

The submission emphasized that agriculture faces chronic, structural labour shortages, with tens of thousands of unfilled positions that domestic recruitment alone cannot meet.

In rural areas TFWs do not displace Canadian workers or suppress wages. Instead, they provide essential labour that sustains farm productivity, stabilizes local economies, and protects national food security. Evidence shows that TFWs help maintain billions in economic activity across key agricultural sectors.

CFA noted that employers face significant costs to participate in the program—covering transportation, housing, insurance, and regulatory compliance—reinforcing that TFWs complement, rather than replace, the domestic workforce. The organization stresses the need for a long‑term, reliable labour strategy that supports both seasonal and year‑round operations.

To strengthen Canada’s food system, the CFA recommended to:
– Maintain the current agriculture streams within the TFWP, including the Seasonal Agricultural Worker Program;
– Reinstate and make permanent the Agri‑Food Pilot to create pathways for experienced, non‑seasonal TFWs in critical industries.

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.