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Review Regulatory Proposal
Revision of the List of Crops Subject to Variety Registration Under the Seeds Regulations
Amended - December 20, 1999
Plant Health and Production Division
59 Camelot Drive
Nepean, Ontario
K1A 0Y9
Tel: 613-225-2342
Fax: 613-228-6629
December 20, 1999
MEMORANDUM RE: FOLLOW-UP TO THE VARIETY REGISTRATION REVIEW
I am writing to ask your assistance and to update you on the latest information
regarding the Variety Registration Review that was conducted by FAAR Biotechnology earlier
this year. As you may be aware, the executive summary from this report was posted on
the Variety Registration Office homepage on April 12, 1999. The entire report is now
on our homepage (www.cfia-acia.agr.ca/english/plaveg/variet/vartoce.shtml.)
If you are interested in this document, you may obtain it through this source as
paper copies will not be distributed.
Since the submission of this report by FAAR, the Variety Registration Office has
developed some proposals that were shared at the annual meetings of the Canadian Seed
Growers' (CSGA) and the Canadian Seed Trade Associations. This information has been
developed into a regulatory proposal that is attached for your comments. We will
continue to expand and clarify these proposals over the coming months.
The first proposal for which your advice is being sought is the separation of
registration into two categories:
- Registration with Merit
- Listing (exempt from merit requirement.)
Under this proposal, the term "registration with merit" is used to define a
system that is generally equivalent to the status quo. However, this proposal
reduces the number of crop kinds to which it applies. Most respondents to the FAAR
Variety Registration Review felt that registration with merit is beneficial for several
key crop kinds where quality is fundamental to trade domestically and internationally for
that sector.
"Listing" (exempt from merit requirement) will provide official recognition
to a variety without the requirement for two to three years of merit testing as is
generally required under the current system. Official recognition allows for
acceptance of varieties by importing countries because of their inclusion on an official
national list. This registration category will also assist in providing a better
mechanism for tracking and regulating the import, export and/or sale of plants with novel
traits. This was one of the key recommendations in the Variety Registration Review.
Like the registration with merit category, if a variety is "listed", it
eliminates the necessity for obtaining additional acceptance of the variety into
certification by CSGA under the "Form 300 Eligibility for Certification"
process. Both organizations wish to avoid duplication of work and costs.
"Listing" would allow the CFIA to continue providing variety descriptions
directly to field and laboratory staff involved in crop and seed inspection and varietal
purity testing. For some species, it will prevent multiple names being used in
Canada for one variety, and the use of the name for two different varieties of the same
crop kind. In short, it will allow the CFIA to have some form of control over issues
related to the use of variety names on official seed tags and provide accountability for
varietal integrity as required under Canadian and international seed certification
schemes.
It is anticipated that the application processing times and fees for listing (exempt
from merit requirement) would be reduced from those currently in existence for
registration with merit. It is proposed that all of the crop kinds to which
registration currently applies that will not be registered with merit,
will be transferred to the listing category. The registration review also recommended
that crops such as industrial hemp and those agricultural plants with novel traits (PNTs)
or derived from PNTs that are not subject to registration with merit be
"listed". This would facilitate the submission of reference samples,
regulatory monitoring and seed recalls, and assist in pedigreed seed exports. If an
interest exists to have some form of official recognition of varieties of other crop
kinds, it is proposed that applicants could voluntarily have varieties of other crop kinds
listed and they would appear on the Canadian national list. Examples of this include
natto type soybeans, annual clovers, Kentucky bluegrass or sweet bromegrass.
Because listing excludes merit, recommending committees would not be involved in
generating information or supporting varieties for this category.
In order to reduce fees for listing, for those varieties that will be accepted into the
certification system by the CSGA prior to listing, the Variety Registration Office is
currently exploring with CSGA the role that information provided to them for crop
certification purposes (Form 300 "Eligibility for Certification Application")
could play as part of the information package to list a variety.
Where harm may be an issue for certain varieties listed (exempt from merit
requirement,) additional information may be required. For example, total
glycoalkaloid content and foliar and tuber symptoms of bacterial ring rot for potatoes may
be required for potatoes. Similarly, information on resistance to bacterial wilt in
alfalfa and low THC content for industrial hemp could be required to show that the
varieties meet the required standards.
As a result, your comments are requested on the proposal for two registration
categories and the crops that would be subject to each. Your input is also requested
as to which crops subject to listing (exempt from merit requirement) require additional
information to address issues of harm and what those requirements should be.
The attached regulatory proposal provides details on all the above mentioned issues.
The movement towards listing (exempt from merit requirement) and the resultant lack
of involvement of the committees in variety registration testing may have a significant
impact on the functioning and mandate of recommending committees. This proposal
would not preclude a committee's continued involvement in varietal testing for
provincial/regional recommendation or performance testing.
Thank you in advance for considering these many issues and for providing the Variety
Registration Office with constructive feedback to the proposals resulting from the review.
Sincerely,
Louise Duke
Chief
Variety Registration Office
Revision of the List of Crops Subject to Variety Registration Under
the Seeds Regulations
Regulatory Propasal
Regulatory Proposal
This bulletin is published by the Plant Health and Production Division, Canadian Food
Inspection Agency. For further information, please contact the Variety Registration Office
at:
Variety Registration Office
Canadian Food Inspection Agency
59 Camelot Drive
Nepean, Ontario K1A 0Y9
Telephone: (613) 225-2342
Facsimile: (613) 228-6629 |
