The new "Product of Canada" guidelines came into effect on December 31, 2008, and were published as the new paragraph 4.19 in the Guide to Food Labelling: "a food product may claim 'Product of Canada' when all or virtually all major ingredients, processing and labour used to make the food product are Canadian." The Guide defines the standard as 98%. It became clear within a matter of months that the standard was too restrictive and that the former producer and processor consensus of 85% would be more workable.
At a meeting of more than 50 representatives of the Canadian food processing industry on April 19, 2010, Minister of State for Agriculture the Honourable Jean-Pierre Blackburn announced new consultations on the issue but limited the exercise to a consideration of "exempting specific ingredients which are difficult to source in Canada", i.e., sugar, vinegar and salt.
Who were the interests pushing for these three exemptions? Why not simply lower the threshold to 85%? Emails to officials to get some clarity on these questions remain unanswered.
By selecting without explanation three ingredients, officials have managed to create a minefield when an easy solution was there for the taking. This clumsy consultation, compounded by resort to an awkward computer questionnaire technique, is picking winners and losers while doing nothing to enlighten the consumer.
For example, products sweetened with imported raw cane sugar would be eligible for Product of Canada but products using domestic corn sweeteners that cannot quite meet 98% could not. Why would we want to benefit imported cane sugar over Canadian sugar beets? Why would we want to provide a benefit to foreign vinegar producers over Canadian produced vinegar? What Canadian food products require more than 15% salt? Doesn't this exemption idea simply invite all kinds of other commodities to argue for an exemption too?
A little history here is helpful. In 2005 the Canadian Federation of Agriculture (CFA) issued a paper that argued for a "Canadian" label to promote Canadian fruits, vegetables, poultry, beef, pork and grain products. CFA accepted the 51% "Product of Canada" claim but it also wanted a "Grown in Canada" claim, and, of course, this being CFA, money from Agriculture Canada to promote it. Then Wendy Mesley's book club and CBC highlighted the "misleading" nature of Industry Canada's 51% rule as applied to food and this engendered a media frenzy full of misinformation which brought great pressure on the government. The Standing Committee held hearings for many months, became very partisan, and a couple of weeks before its Report was issued, the government announced the new 98% policy in spite of the fact that by this time the CFA, most producers and the food processors agreed that 85% was about right.
The failure of the current policy is pretty clear. Try finding "Product of Canada" claims on Canadian processed food. The government should be commended for recognizing the need for speedy reform but the "consultation" seems to be going in the wrong direction. Moreover, the current consultation also suggests that the qualifiers on "Made in Canada" could be dropped. This would only cause more confusion for the poor consumer.
The solution is clear. Adopt the 85% rule for "Product of Canada", leave "Made in Canada" with qualifiers alone (a good innovation) and adopt a process to recognize "Grown in Canada" to help local farmers. This would be an easy win for Minister Blackburn who deserves credit for his leadership.
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