2025 Pre-Budget Consultation

RE: Written Submission for the Pre-Budget Consultations in Advance of the Upcoming Federal Budget by Pulse Canada

Pulse Canada is the national association representing growers, traders and processors of Canadian pulses (dry peas, beans, lentils and chickpeas). Our mission is to lead a profitable and sustainable Canadian pulse industry through innovation, efficiencies, and increased value. We are pleased to participate in the Finance Committee’s pre-budget consultations in advance of the upcoming federal budget. When implemented, the following budgetary recommendations will create the conditions necessary for Canada’s pulse sector to thrive by removing barriers to competitiveness, diversifying demand, and better positioning Canada globally.

Recommendation 1

• That the Government adopt and prioritize an agriculture-first trade strategy to grow Canada’s exports and to elevate Canada’s reputation ensuring Canada is the preferred supplier to the world’s top markets.

Recommendation 2

• That the Government invest in Canadian Food Inspection Agency (CFIA) modernization including timelier service delivery, full adoption of e-phyto certificates, and enhanced industry communication to align with the modern grain trade and to eliminate trade execution barriers.

Recommendation 3

• That the Government increase funding to the Agri-Marketing Program to support market access, technical capacity, and growth.

Recommendation 4

• That the Government engage in Pest Management Regulatory Agency’s (PMRA) structural reform including permanently increasing baseline funding to ensure the Agency can meet their service standards and the needs of stakeholders.

Recommendation 5

• That the Government deliver on its commitment to extend the interswitching pilot program for an additional 3 years and increase the distance to 500 km to promote fair competition, reduce transportation costs, and increase access for Canadian goods.

Recommendation 6

• That the Government fund minor crop breeding and development to ensure farmers have access to cultivars that are resilient to climate change, contribute to sustainable crop rotations, and increase on-farm profitability.

AG FIRST TRADE POLICY

Canada’s pulse and special crops sector operates in a rapidly evolving global trade environment, characterized by increasing geopolitical instability, rising protectionism, and shifting trade dynamics.

To achieve Canada’s trade diversification agenda, Canada requires an agriculture-first trade policy agenda which prioritizes agriculture in key markets and champions agri-food diplomacy on the world stage. Key pillars should include strengthened agricultural trade diplomacy capacity, domestically and abroad; a predictive and proactive approach to market access barriers; and renewed industry-government collaboration. Brand Canada and trade promotion needs to be paired with trade facilitative tools to address non-tariff barriers, regulatory misalignments, and infrastructure constraints.

As part of this agenda, Government should consider the following actions.

• Adopt an agriculture trade strategy to elevate Canada’s trade reputation and to ensure Canada’s agriculture exporters remain competitive globally.

• Renew and increase funding for the Indo Pacific Agriculture and Agri-food Office (expires December 2027) and for an expanded list of priority countries to better reflect Canada’s long-term commitment to the region.

• Target investment in technical capacity building throughout the Indo-Pacific to strengthen mutual understanding of phytosanitary standards, import processes, and Canada’s systems approach to pest risk management and quality.

• Encourage better collaboration between Global Affairs Canada, Agriculture and Agriculture Food (I.e. Market Access Secretariat), the Canadian Food Inspection Agency, and the Trade Commissioner Network and enhanced engagement models with industry to create more proactive and predictive market access support.

• Conclude of FTA negotiations with ASEAN, launch negotiations with the Philippines, and introduce legislation to ratify the CEPA with Indonesia and adopt a concrete plan to leverage it.

• Leverage the World Trade Organizations’ 14th Ministerial Conference to promote multilateralism and rules-based trade.

Recommendation 1: That the Government adopt and prioritize an agriculture-first trade strategy to grow Canada’s agriculture exports and to elevate Canada’s global reputation ensuring Canada is the preferred supplier to the world’s top markets.

CFIA Modernization (CFIA)

CFIA is essential to Canadian pulse and special crop exporters as it provides regulatory oversight, certifications, and plant health assurances needed to access and maintain international markets. Delays in service delivery, the lack of digital documentation, such as e-phytos, and discrepancies in communication create administrative burden, add cost, and reduce the competitiveness of Canada’s grain sector. Additionally, CFIA systems and tools have neither kept pace with modern grain handling and logistics nor Canada’s global competitors (I.e. United States, Australia, and Europe).

Phytosanitary certificates for Western Canadian grain are issued within 10 working days of receipt falling short of grain sector requirements. Our industry operates on tight shipping schedules and just-in-time logistics, where even short delays can disrupt vessel loading, increase demurrage costs, delay payment, and jeopardize market access commitments. Canada is lagging its competitors digitally and is increasingly pressured globally to adopt a framework to exchange phytosanitary certificates for grains electronically (E-phytos). E-phytos would replace traditional paper certificates increasing regulatory compliance, service delivery, and trade execution efficiencies. While the CFIA has launched MyCFIA and an e-phyto pilot program with the United States (grain not included), they lack funding (and direction) to expand the program to additional markets and commodities. Additionally, enhanced communications would provide more timely updates to industry and clearer guidance on export requirements, allowing better business planning and faster response to emerging market issues.

Recommendation 2. That the Government invest in Canadian Food Inspection Agency (CFIA) modernization including timelier service delivery, full adoption of e-phyto certificates, and enhanced industry communication to align with the modern grain trade and to eliminate trade execution barriers.

AGRIMARKETING PROGRAM

With 85% of pulse production exported annually, ongoing disruptions in major pulse markets and geopolitics have increased trade complexity and instability. Specifically, Canada’s three biggest pulse markets, the U.S., China, and India have shifted their strategies impeding exports and re-defining rules-based trade. As Canada's competitors expand exports and develop alternative supports for their industry, Canada must also enhance its efforts to both maintain market share and grow new opportunities.

The Government’s election platform recognized the need to protect Canadian agrifood workers and to build a stronger agrifood sector in the face of tariff threats, including an additional $30 million to the AgriMarketing Program. Additional funds would allow the pulse sector to better respond to substantial market access challenges, such as the 100% pea tariff in China and the ongoing threat of US tariffs, and to support the sector’s long-term competitiveness.

Recommendation 3. That the Government increase funding to the Agri-Marketing Program to support market access, technical capacity, and growth.

Pest Management Regulatory Agency (PMRA)

As the acres dedicated to Canadian pulses increase to meet the global demand for plant-based protein, pulse growers are being asked to produce higher yields while lowering their carbon footprint. To achieve this, access to the latest crop protection products is a must and requires the PMRA to make timely science and risk-based decision making to support the registration of these products.

The Government’s election platform committed to reforming and modernizing the PMRA mandate. Meaningful, structural reforms and increased baseline funding are needed to enable the Agency to meet its stated service standards and the needs of its agriculture stakeholders.

Recommendation 4: That the Government invest in Pest Management Regulatory Agency’s (PMRA) structural reform including permanently increasing baseline funding to ensure the Agency can meet their service standards and the needs of stakeholders.

EXTENDED INTERSWITCHING

Canada’s pulse industry relies on access to a timely, efficient transportation logistics system. Extended interswitching is a measure which gives shippers who are physically located on a single rail line the ability to seek competing service form the next closest railway within a certain distance. The following can be done to further strengthen this policy and promote fair competition while reducing transportation costs and increase access to Canadian goods:

• Increasing the extended interswitching distance to 500 km to ensure competitive market forces are available to the entire grain sector.

• Invest in rural rail infrastructure that can accommodate larger trains to expand the use of interchanges.

• Extend the pilot program an additional 3 years so that shippers can properly utilize this policy.

Recommendation 5: That the Government deliver on its commitment to extend the interswitching pilot program for an additional 3 years and increase the distance to 500 km to promote fair competition, reduce transportation costs and increase access for Canadian goods

Minor Crop Breeding and development

Canadian pulses are an economic and environmental success story. When grown as part of an agronomically responsible crop rotation, pulses lower Canada’s environmental footprint while providing tens of thousands of jobs and billions of dollars in economic output. Cultivation of pulse crops in rotations has benefits at several levels, including (a) on-farm benefits to pulses in rotation, (b) agro-ecosystem benefits at the landscape level, and (c) contributions to national efforts to reduce agricultural greenhouse gas emissions.

Pulses add to the sustainability of crop rotations through reducing carbon footprints, lowering greenhouse gas emissions (GHG) and increasing water use efficiency. They add value to crop rotations through positive influence on following crops. Climate change adaptation and abiotic stress resilience support yield stability along with the expansion of pulse crop areas and crop options. Growers need access to crop varieties that meet these demands to produce a safe, reliable, and consistent supply of Canadian pulses. On-going research to develop varieties that meet these needs is a high priority for the industry. Investments through government programming into varietal development is critical to achieve successful delivery of such varietal options for growers because of the limited funding available for minor crops through other industry sources.

Recommendation 6: That the Government fund minor crop breeding and development to ensure farmers have access to cultivars that are resilient to climate change, contribute to sustainable crop rotations, and increase on-farm profitability. 

CONCLUSION

Thank-you once again for the opportunity to provide input into the federal budget. For any questions, comments, or issues of clarification, please do not hesitate to contact us.