Canada Grains Council
CGC
The Canada Grains Council is Canada's national umbrella organization representing the grain, oilseed, pulse and special crop industries.
ID: 331337833900-51
Lobbying Activity
Response to Food and Feed Safety Simplification Omnibus
14 Oct 2025
The Canada Grains Council (CGC) welcomes the European Commissions initiative to develop a Food and Feed Safety Simplification Package. As a trusted, long-standing global trading partner and a key supplier of high-quality grains and derived feed ingredients to the EU market, the Canadian grain sector strongly supports efforts that enhance regulatory efficiency while maintaining the highest standards of food and feed safety. While the stated goals of the Simplification Package are positive, it is essential that the reform process does not inadvertently create new complexities or non-tariff barriers for international suppliers like Canada. For Canada, the primary concern lies in the predictability and clarity of rules governing market access, particularly in the domain of pesticide use and pesticide Maximum Residue Limits (MRLs). In particular, we are concerned with the reciprocity provision that was introduced in the Vision for Agriculture and Food and how its implementation is likely to result in unjustified barriers to access to the European market. The core purpose of a MRL under the WTO Sanitary and Phytosanitary (SPS) Agreement is to ensure the safety of the consumed product and facilitate international trade based on good agricultural practice (GAP). The CGC does not support the consideration of global environmental factors within the process of setting import MRLs. We believe that: 1. MRLs must remain science-based and strictly focused on trade facilitation. 2. MRLs must be established based solely on science-based dietary assessments, not environmental considerations. 3. Environmental protection is a shared global responsibility, but the MRL framework is not the appropriate tool for extraterritorial environmental regulation. Global environmental issues should be addressed through multilateral environmental agreements and international cooperation, not through trade-restrictive import requirements. 4. Incorporating external policy goals, such as environmental criteria unrelated to the final food product's safety, introduces significant uncertainty and complexity into the MRL setting process. This creates unpredictable barriers for third-country producers who operate under different climatic, pest, and regulatory regimes. CGC urges the Commission to ensure the simplification process maintains the strict scientific and risk-based focus of MRLs to preserve the availability and affordability of safe food through predictable market access for food and feed imports. The simplification initiative states it will "improve the clarity of terminology and transitional rules regarding MRLs." CGC urges the Commission to ensure this simplification process for MRLs focuses on: 1. Science-Based Harmonization: All MRL decisions, including those for MRLs set at the Limit of Quantification (LOQ) due to non-renewal of an active substance, must be based on robust, publicly available scientific risk assessments concerning consumer safety and dietary risk. 2. Trade Predictability: Any proposed changes to the terminology or transitional periods for MRLs must prioritize clear, predictable timelines and provide adequate transition periods for trading partners. Sudden or ambiguous changes disproportionately impact complex global supply chains and lead to trade disruption, as Canadian grain must be contracted and shipped, and at times stored, in advance of arrival in the EU. 3. Alignment with International Standards: CGC encourages the EU to increase alignment with Codex Alimentarius standards wherever possible to maintain a common, science-based global framework, thereby facilitating trade and reducing administrative burden on exporters. Thank you for your consideration and for the opportunity to provide feedback on this initiative. The CGC firmly believes that a competitive and simplified EU regulatory environment can coexist with safe and predictable international trade that enables the flow of food from areas of surplus to areas of deficit.
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