June 4, 2007
 

Canada’s Proposed Alternative to the United States Department of Agriculture’s Rule on Border Inspections and Fees
 

The following notice concerning the USDA’s decision to implement charges on all commercial conveyances and airline passengers arriving on flights from Canada to the US for inspection of fruits and vegetables grown in Canada and imported into the US; it is found on the CFIA web site at:
 

http://www.inspection.gc.ca/english/corpaffr/publications/borfrae.shtml
 

Canada’s alternative proposal to the Rule
 

Based on the ideas that have emerged from the working group’s efforts, Canada has proposed an alternative approach to that contained in the Rule. Instead of putting in place added layers of costs and controls at the border, Canada’s proposal enhances measures to effectively manage risks at their point of origin.
 

This approach to risk management is consistent with the shared principles of existing collaborative initiatives, including the Security and Prosperity Partnership of North America, the Canada-U.S. Smart Border Declaration, and the U.S.-Canada Free and Secure Trade (FAST) initiatives. Our mutual experience has shown that properly certifying or interdicting high-risk products and goods at origin, rather than at the border, is the most effective means of managing risks to our two countries. It also allows us to more effectively utilize resources at the border in a streamlined yet secure process that does not unnecessarily impede the flow of the CDN $1.9 billion of commercial goods which cross the Canada-U.S. border every day.
 

Canada’s proposed alternative is based on four elements, which have been identified by the bilateral working group. Combined, these elements can be used to collectively mitigate the risks identified in the Rule:
 

• Identifying Canadian origin commodities to facilitate more effective targeting of third country higher-risk goods. Export certification requirements such as these have already been successfully used in export programs for commodities such as cut flowers and potatoes;
 

• Enhancing fraud reduction activities to further ensure that a product’s country of origin is not misrepresented;
 

• Harmonizing standards where the pest risk is similar, and expanding the management and control of in-transit shipments between Canada and the U.S. to third country origin shipments; and
 

• Providing export certification for commodities not grown in Canada, thus assuring that U.S. import requirements are respected upon presentation for entry at the U.S. border.
 

Canada is prepared to allocate appropriate resources that would allow us to implement the proposed package of alternative measures.
 

In addition, the bilateral working group has developed an innovative, cooperative vision and work plan to address the phytosanitary risks that both our countries face. This approach reflects the reality that Canada and the U.S. share many of the same pest and disease concerns that are often associated with trade originating from off-continent sources, as well as newly-introduced invasive pests that have unfortunately become established in parts of North America. Sharing of plant pest risk assessments, global intelligence reports and compliance data, joint foreign pre-clearance programs, electronic certification systems, and shared development of better detection and survey tools all represent initiatives that serve to protect the agricultural and natural resources of our two countries.
 

The Government of Canada’s approach
 

The Government of Canada believes that this science-based approach to risk management represents a superior alternative that should displace the border measures and fees proposed in the Interim Rule.
 

Most importantly, this alternative represents a ground-breaking opportunity to address mutual risks from a harmonized North American perspective. It is consistent with the shared risk management principles which already represent the cornerstone of our mutual border security efforts, and with our longstanding history of collaboration on border management issues.
 

The Government of Canada is prepared to engage in further bilateral efforts on this important matter, to ensure the continued integrity of our collaborative efforts on border management issues and food safety, plant and animal health.