Executive summary of the seed standards and grade tables task team final report – seed regulatory modernization

The Seeds Act and Seeds Regulations have undergone periodic amendments and modernizations since the first laws were established in 1905. During this current initiative the CFIA is looking to update the Seeds Regulations to:

• improve responsiveness and consistency
• reduce complexity
• become adaptable and flexible to address future technical advances and scientific innovation
• protect producers and consumers by strengthen existing requirements

Canada's grade tables and seed grading system are unique in the world. There are a large number of grade names and associated seed standards which make the system somewhat complex. In addition, the lack of flexibility and the inability to adapt standards quickly to industry changes has been identified as a challenge to stakeholders.

The seeds standards and grade tables task team, with support provided by government representatives and feedback from an advisory group of seed sector stakeholders, was composed of 13 members:

• 5 from seed sector
• 4 from producer groups
• 3 from commodity/value chain associations
• 1 non-governmental organization

Based on the initial topics suggested by the seed regulatory modernization working group, the task team presented a work plan for the analysis and discussion of the following 7 topics:

• Purity and germination was split into 3 topics
  • Higher voluntary standards
  • Additional quality standards
  • Aligning standards
• Weed seeds
• Incorporation by reference of the grade tables
• Varietal blends
• Mixtures

The task team focused on 3 major opportunities for improvement:

• Ability to adapt standards to changes occurring within the seed sector
• Simplifying standards for sale of seed in Canada
• Strengthening existing requirements

A total of 28 options were proposed and discussed by the task team which generated the following 30 recommendations being presented to the seed regulatory modernization working group:

Topic 1 – Higher standards recommendations

• Grade tables should continue to exist for pedigreed grade standards
• The CFIA should continue to set the minimum standards for purity and germination
• The CFIA should explore having only one common grade standard per grade table and eliminating the Common No. 2 standard (this recommendation to be forwarded to the common seed task team)
• The CFIA should explore making additionally requested information available via a quick response (QR) code on the official tag/label (this recommendation to be forwarded to the information (records and labelling) task team)

Topic 2 – Additional quality standards recommendations

• There was general consensus that additional (new) standards should not be added to the grade tables at this time
• Explore the development of a non-government, national system for standardization of test methods for additional quality standards (this recommendation to be forwarded to the seed testing task team)
• Explore options for labelling of test results of additional quality traits (this recommendation to be forwarded to the information (includes records and labelling) task team)

Topic 3 – Aligning standards recommendations

• For No. 2 pedigreed grade names, adopt the No. 1 standards for purity and disease but keep both the No. 1 and No. 2 standards for germination
• The CFIA should review the recommendations from this task team with representatives from the vegetable seed industry and adjust them if needed
• Keep Canada's seed standards for purity higher or equal to international standards

Topic 4 – Weed seeds recommendations

• The regional standards for wild oats and tartarian buckwheat should remain within the Seeds Regulations
• The CFIA should explore additional regional standards and/or how to amend the Weed Seeds Order (national standards) in a more timely and predictable manner
  • The focus should be on protecting Canada from invasive or other harmful species that could increase costs to farmers and pose trade barriers for seed as well as grain export markets
• The List of Regulated Pests regulated by Canada (includes quarantine weeds) should be amended in a more timely and predictable manner
  • It was noted that this list is not part of the Seeds Regulations, therefore this recommendation falls outside of the scope of seed regulatory modernization

Topic 5 – Incorporation by reference recommendations

• The grade tables (standards for both common and pedigreed grade names) should become a document that is incorporated by reference so that changes can be made in a more timely manner
• The CFIA should continue to set the minimum standards for purity and germination
• The grade tables (standards for common and pedigreed grade names) should be incorporated by reference and be administered by the CFIA with predetermined expert recommending/technical committees providing advice and recommendations

Topic 6 – Mixtures recommendations

• Purity standards should remain in the mixtures grade tables and be tightened as needed
• Germination standards for mixtures should be eliminated from the mixtures grade tables
• A new requirement for the components of mixtures to be tested and meet their individual table's standards (purity and germination) prior to mixing should be put in place
• No. 2 purity standards should be raised to be the same as No. 1 purity standards as per the previous recommendation (Topic 3: aligning standards)
• No. 2 Common/Canada grade name should be eliminated as per the previous recommendation (Topic 1: higher standards)
• The requirement for percentages of labelled components to be verified by the lab should be retained (no change to existing requirement)
• The CFIA should explore eliminating grade Table III (cereal mixtures)
• If the cereal mixture Table III is retained, the requirement for only 1 variety per kind or species should be eliminated
• Seed testing task team should review the mixtures tables also to input advice into tightening the purity standards of these tables

Topic 7 – Varietal blends recommendations

• Remove the varietal blend grade names from the grade Tables VIII to XII
• The CFIA should explore grading and labelling options for non-plant pest tolerance management (PPTM) varietal blends using the existing Canada Certified grade names (this recommendation to be forwarded to the information (records and labelling) task team)
• The CFIA should conduct a survey on what types of non-PPTM varietal blends stakeholders are currently using and what blends they anticipate being used in the future
• The CFIA should explore allowing for the use of PPTM varietal blends for all crop kinds
• Explore the possibility of having an official tag for varietal blends, possibly of a different colour but still compliant with the Association of Official Seed Certifying Agencies (AOSCA) requirements (this recommendation to be forwarded to the Information (records and labelling) task team)