The Protection of Proprietary Interests in Pesticide Data in Canada (PPIP) regulation administered by the Pest Management Regulatory Agency (PMRA) has been a serious obstacle for farmers getting access to lower cost products. It has made it near impossible for companies to register generic crop protection products, leaving little competition in the market and farmers with few alternative product choices - products and prices farmers in most of Canada's main trading partners have access to, but Canadian farmers do not. This has created a serious disadvantage for Canadian farmers, and must be rectified immediately in order to close the gap created with our competitors.
In 2005, the Pest Management Regulatory Agency (PMRA) formed a taskforce with farm organizations and crop protection companies to address issues in the pesticide regulatory system that were creating an uncompetitive environment for Canadian farmers. The taskforce identified key recommendations to level the playing field, including:
1.Accelerate increased harmonization with the US to produce more joint review registrations (either with the US or globally) of new pesticides so Canadian farmers have access to innovative technology at the same time as their competitors.
2.Create the Grower Requested Own Use (GROU) program to allow growers to import the US version of a Canadian registered product if a significant price differential exists;
3.Improve the policy for protecting intellectual property rights by providing:
a) a system to increase minor use registrations that benefit Canadian growers;
b)timely and predictable process for registering generics
c) fair data protection for industry to promote innovation in Canada.
The Government has made important improvements with the first two recommendations. Farmers have seen tremendous progress by PMRA and crop protection companies on increasing the number of innovative products available to farmers through the joint review process. For GROU, farmers now have 20 products available for import from the US. While there is still much work to be done to complete the regulations and improve the flexibility of the program to allow for more new products on the import list, GROU has been a good example of crop protection companies, farmers and PMRA working together.
In 2010, PPIP regulations were introduced to address issues concerning the third recommendation, and unfortunately to date, success has been limited.
The implementation of PPIP has not resulted in the hoped for increase in minor-use registrations - actually down from 83 in 2010-2011 to 66 in 2012-2013. And it certainly has not resulted in a timely or predictable process for registering generic crop protection products. As of 2012, approximately only 15 per cent of total applications of generic end-use products were registered under PPIP. Conversely, in the past several years, a steady stream of pesticide products have become available for generic registration, and farmers in the U.S have benefited greatly from this increased competition due to their comparatively streamlined and timely registration process. Once again, our regulatory system is cutting into our competitive edge and Canadian farmers remain in a situation where there is an extreme lack of competition in the generic pesticide market.
I have heard from several frustrated farmers trying to sustain successful businesses and maintain productivity, and increased generic competition is an important way to ensure that capacity remains. The current environment simply does not make good business sense and is not in line with this government's cost competitive agenda.
The CFA and its members implore the Government to implement recommendations made by the generic crop protection industry that would address the serious imbalance in the PPIP regulations. We look forward to working in partnership with the Government to address these issues and continue to strengthen Canada's position in the marketplace by ensuring an essential mix of new innovative products, minor uses and generic pesticide options.