Submissions

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.

The Canadian Federation of Agriculture (CFA) supports the goals of the Free Trade and Labour Mobility in Canada Act but stresses that reducing interprovincial barriers must not compromise food safety, international market access, or regulatory integrity. The CFA recommends that the government:

– Develops clear definitions of “comparable” standards – Develop sector-specific guidance through stakeholder engagement, ensuring food safety and Canada’s global reputation are not compromised.

– Provides support for provincially regulated meat plants – Provide financial, technical, and administrative assistance so facilities can meet federal standards without risking international market access.

– Harmonizes trucking regulations – Align provincial enforcement of safety codes, vehicle weights, permits, and training standards to reduce costs and inefficiencies in agri-food transportation.

– Avoids regulatory duplication – Where strong federal frameworks exist (e.g., Canada Organic Regime), align or exempt to maintain clarity, consumer confidence, and trade competitiveness

CFA’s recommendations for the regulatory modernization and red tape reduction consultation include:

– Make agriculture a regulatory priority – Amend the Cabinet Directive on Regulation to reflect the competitiveness and food security interests of producers, streamline stakeholder consultations, and encourage regulatory innovation through sandboxes.

– Address critical shortages – Enable faster approval of feed additives, pest control products, and veterinary medicines by recognizing trusted international approvals to reduce barriers and improve access.

– Strengthen trade and transportation – Ensure meat and seafood facilities meet national food safety standards, harmonize trucking rules across provinces, follow through on rail reform (MRE, penalties, transparency, interswitching), and modernize phytosanitary and food safety regulations to reduce costs and delays.

– Modernize plant, animal, and environmental oversight – Update compensation for animal disease culls, align organic standards with the U.S., reduce duplicative environmental reporting, and expand shellfish sanitation capacity to support sector growth

The recent surge in gopher populations—driven by prolonged drought and consecutive years of unchecked spread—is causing significant economic losses, environmental degradation, and operational disruptions for producers. In some Prairie regions, gopher infestations have led to significant reductions in crop, hay, and pasture yield. Their extensive burrowing damages irrigation systems, undermines soil structure, and interferes with farm machinery operation and causes expensive machinery damage, while also reducing available pastureland and other feed sources for livestock in times of drought and causing potential injury to livestock. The 2024 ban on strychnine has further limited effective control options, exacerbating the problem for many producers. Strychnine remains the most effective option available for managing gopher populations and other burrowing rodents that pose serious threats to crops, infrastructure, and farm productivity.

We understand the Pest Management Regulatory Agency’s 2024 decision to cancel all uses of strychnine due to environmental concerns, particularly risks to non-target wildlife. To help mitigate the concerns associated with the use of strychnine, we support the implementation of strict control measures, handling guidelines, and comprehensive monitoring and reporting to mitigate environmental risks.

We also urge Agriculture and Agri-Food Canada to prioritize and invest in the research and development of alternative pest control solutions that are both effective and economically feasible.