Submissions

CFA submitted a joint submission with organizations from across Canada’s food supply chain, calling on the federal government to treat farming and food production as a core national priority—on par with energy and supply‑chain security. If food security is to be a national priority, the foundation of that is strong, profitable farms.

The letter urged long‑term investment to boost farm productivity, protect farmland and soils, stabilize access to key inputs (like seed, fertilizer, crop protection, energy, and animal health tools), and speed up access to new technologies. It emphasized the need for predictable regulations, fair access to capital, and policies that support innovation rather than add costs.

The document also highlights the importance of value‑added processing in Canada, better transportation and trade infrastructure, and labour solutions to keep farms and processors running.

It recommends a whole‑of‑government approach that removes barriers to growth, strengthens domestic production, and keeps Canadian food affordable, all while positioning farmers to compete and succeed at home and globally.

CFA submitted its comments on the Part I consultation on the Order Providing for Reliance on Decisions of, or Documents Produced by, Foreign Regulatory Authorities in Respect of Certain Drugs.

The letter urged Health Canada to modernize regulations so farmers and veterinarians can access veterinary medicines and animal health tools more quickly. In the submission, CFA supports a new “reliance” approach that would allow Canada to approve products already authorized in trusted countries like the U.S., EU, and Australia.

CFA stressed that timely access to vaccines, treatments, and other animal health products is essential for animal welfare, disease prevention, responsible antimicrobial use, and farm profitability.

The submission calls for the framework to go further, by including generic drugs, addressing products that are approved but unavailable, and eventually expanding beyond pharmaceuticals, so Canadian livestock producers are not left with fewer options than their global competitors.

CFA submitted a joint letter with farm groups from across Canada, warning that recent closures of federal agriculture research stations risk weakening the science system that farmers rely on to stay productive and competitive.

The letter noted that public research plays a critical role in developing region‑specific crop varieties, livestock and meat science, disease management, food safety, and long‑term agronomic trials—work that cannot easily be replaced by the private sector.

The letter urges the federal government to slow down implementation, protect ongoing research and breeding programs, and work directly with industry to ensure critical research capacity, expertise, and infrastructure are not lost.

Strong, stable public agricultural research is essential to farm productivity, innovation, food security, and Canada’s ability to compete in global markets.

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.

On February 27th, CFA made its submission to the Horizontal Red Tape Reviews consultation.

In the submission, the CFA stresses that excessive, overlapping, and unpredictable rules are slowing down farm projects, raising costs, and making it harder for producers to stay competitive.

The CFA’s recommendations focus on five main areas:
– Project Reviews: Streamline approvals for on‑farm and agri‑food projects by reducing duplication among federal departments and setting clear, predictable timelines.
Getting Products to Market: Speed up access to essential farm inputs, such as feeds, veterinary products, pest control tools, by recognizing trusted international approvals and improving transparency in regulatory decisions.
– Reducing Administrative Burden: Eliminate unnecessary reporting, fix impractical rules like bulk fertilizer labelling, and modernize outdated legislation.
– Trade & Border Efficiency: Harmonize rules across provinces and international partners, strengthen export processes, and modernize border systems to keep Canadian products moving.
– Better Service Delivery: Improve consistency, communication, and turnaround times for inspections, approvals, and regulatory processes.

CFA argues that smarter, more efficient regulation will free up time and resources for farmers, supporting productivity, competitiveness, and a stronger Canadian food system.

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.