Government of Canada
Comments on Interim Final Rule
Mandatory Country of Origin Labeling
Embassy of Canada
501 Pennsylvania Ave., NW.
Washington. D.C. 20001-2114
September 5, 2008
Mr. Lloyd Day
Administrator, Agricultural Marketing Service (AMS)
Country of Origin Labeling Program
United States Department of Agriculture
STOP 0254, Room 2607-S
1400 Independence Avenue, SW
Washington, DC 20250-0254
Dear Mr. Day,
The Government of Canada appreciates the opportunity to comment on the August 1, 2008 Federal Register notice of the interim final rule on the mandatory country of origin labeling (COOL) provisions of the Food Security and Energy Act 2008.
Fundamentally, Canada's comments stem from our concern that this program will impose unnecessary costs on affected North American industries. The substantial volume of two- way trade between Canada and the United States has been a testament to the integrated and cooperative nature of many of our industries. Indeed,
trade with Canada supports more than 7.1 million jobs in the United States. Trade is also vital in the agricultural sector, and Canada is in fact the largest single-country export market for the United States with more than US$15 billion in sales last year. Focus on the size of the relationship, however, does not fully reveal how trade can be so mutually-beneficial.
For example, Canadian inputs in terms of cattle, hogs and their meats facilitate the ability of the United States to export to third markets. The mandatory COOL provisions could, therefore, also upset North American competitiveness vis-à-vis other markets.
In the current economic context, I believe we agree that ensuring a safe, efficient supply chain and supporting the overall competitiveness on both sides of the border are key priorities. In this regard, our mutual interest is for COOL to be implemented in a manner that is the least disruptive to industry, is flexible enough to avoid unintended consequences, and does not add unnecessary costs or administrative burden. Our comments are submitted toward this end.
However, should implementation of the subject mandatory COOL provisions result in an adverse impact on Canada, the Government is prepared to consider all of its options.
Specific comments and suggestions are outlined in the attached. I, and Embassy staff, remain available to meet with you, or your staff for further discussion. For any clarifications, please also feel free to contact Pamela Simpson at 202-682-7629.
Yours sincerely,
Michael Wilson
Ambassador
c.c.: Desk Office for Agriculture, Office of Information and Regulatory Affairs, Office
of Management and Budget
You want to talk legalities now on an agreement that is not legal under our Constitution?
That's up to the people who signed you on. Not us. If your people didn't follow your constitution that's up to you to fix it. Unlike some, we don't care to meddle in the internal politics of other countries.
Besides that, are you going to tell me that Canada's prices do not follow the US's?
No. They do follow the U.S. Just as the price of just about everything else in this country does. There is not much here, from cars to t shirts that is not tied to prices in your country, except maybe the supply managed livestock, and they are the only people in the livestock business right now that are making a living. Coincidentally, they are also under pressure 24 / 7 from U.S. interests that would love to dismantle them and take them over too.
As for that crappiest excuse? I heard it straight from the CFIA. As for our government growing a pair, there's nothing I'd like better. You really have no idea what the consequences of pissing your government off are though, do you? :roll: :roll: It isn't something to take lightly, but I sure wish they'd give it a whirl.