b'CSGA SPONSORED CONTENTreputation. Additionally, without adequate returns, futureRecommendation: Schedule III to the Seeds research investment in new varieties will not be made.Regulations should be incorporated by reference The appropriate use of variety names is critical to theand updated, with the CFIA as the responsible success of the entire Canadian seed value chain, fromauthority.variety development to processors. In Canada, only certi- Schedule III lists the crop kinds that are subject to variety fied seed can be sold by variety name. The countrysregistration. However, amendments to Schedule III are variety naming system is unique; it needs to be preservedgoverned by federal regulatory policy, resulting in a and strengthened.lengthy and arduous process. Marketing seed by its correct variety name is an inter- As new crop kinds and types emerged (like hemp, nationally recognized way to ensure new crop geneticsfood-type soybeans, quinoa, chickpeas), they were not and variety-specific characteristics provide benefits to alladded to Schedule III for various reasons. As a result, a participants in the crop production value chain. In fact,fractured variety recognition system exists in Canada. seed regulation goes even further in the EU and the UK,CSGA determines whether new varieties of crop kinds where only certified seed can be sold. exempt from registration are eligible for certification An industry trend seen in the United States is to sellthrough its Variety Certification Eligibility Application seed by a brand name instead of by variety name. A(Form 300). The CFIA verifies certification eligibility for brand is often trademarked as a word, number, design,most varieties through the regular variety registration or other feature that distinguishes one companys prod- process.uct from those of other companies. Currently, in Canada,CSGA believes CFIA should be the single and sole neither a variety name nor any part of it is allowed toapprover of varieties. As the regulatory system is modern-be trademarked. Care must be taken to avoid confusionized, running two parallel variety recognition systems between a brand name and a variety name. A varietyconcurrently is unwarranted. Given the CFIA is ultimately must be distinguishable, uniform and stable and can beresponsible for the varietal certification of seed in Canada, officially verified; a brand, however, cannot. it should also be responsible for the official recognition Seed regulatory systems based on variety names pro- of varietal identity. An administrative approach for official mote transparency and facilitate resilient and sustainablerecognition of varieties outside of the variety registration seed sectors, including small- and medium-sized enter- system could be explored.prises, whereas systems using branding, usually domi-nated by select companies, result in opaque markets. SEED QUALITY ASSURANCEIt is CSGAs position that the variety name require- Canadas seed quality assurance system for seed cer-ments are maintained to continue to provide customertification and seed importation is built on the current protection and deliver the broad societal benefits of aframework of Registered Seed Establishments (RSEs) and robust, transparent, and trustworthy national seed certifi- accredited seed testing laboratories.cation program. One flaw in this system is that non-pedigreed (Common grade) seed is not subject to the same require-Recommendation: CFIA should continue to bements. The creation and maintenance of recordsa responsible for variety registration. fundamental component of quality assuranceapplies Variety registration is central to Canadas seedonly to seed certification and imports and not domestic, varietal identity and crop quality assurance systems. In anon-certified seed.world where consumer confidence is paramount, official evaluation, recognition, and monitoring of varietal identityRecommendation: Part IV of the Seeds Regulations are essential. The CFIA should continue to be the ultimateshould be incorporated by reference.authority of this system. Innovative plant genetics will bePart IV lays out regulations concerning the reg-more acceptable to consumers if they are overseen byistration of establishments and the licensing of operators government. for seed certification and import purposes.Consumers are looking for government oversight andThese regulations could be incorporated by refer-confidence-building measures built into official regulatoryence, which would allow the process for change to be programs. As a result, variety registration will becomemore efficient. CSGA would be delegated the authority more important than ever. to deliver the seed certification program, and the CFIA 28GERMINATION.CAJULY 2021'