Thank you, Madam Chair and committee members, for the opportunity today to speak on the potential issues for consideration in relation to the 2026 review of the Canada-U.S.-Mexico agreement.

As the committee has heard me say in the past, our produce supply chain is highly integrated across borders. CPMA represents over 870 companies growing, packing, shipping and selling fresh fruit and vegetables in Canada. Our members are responsible for 90% of the fresh fruit and vegetable sales in Canada and make a significant contribution to Canada's economy, in the amount of approximately $15 billion in GDP.

The pandemic has highlighted that the Government of Canada must prioritize food as an essential item in framing our trade agreements, with the fundamental goal of supporting domestic markets while strengthening food security and ensuring product diversity.

It is also critical that the government support all Canadian agriculture and food products in trade negotiations and not prioritize certain sectors to the detriment of others. CPMA cannot understate the critical importance of CUSMA in supporting our integrated supply chains. Our partners in CUSMA are by far Canada's largest trading partners when it comes to fresh produce, and particularly the United States, both in imports and in exports. There are also many companies that operate across all three jurisdictions.

In looking to the 2026 review, I would like to highlight three areas of focus.

First, over the past number of years, we have seen some push coming from U.S. growers on trade actions, including an attempt to impose seasonal tariffs on certain fresh fruit and vegetable commodities to protect U.S. domestic producers from what they described as unfair competition from imports, which was not validated.

Between 2020 and 2022, the U.S. International Trade Commission also undertook a safeguard investigation into blueberry imports, as well as a fact-finding investigation regarding cucumber and squash imports. Investigations into strawberry and bell pepper imports were also launched, but ultimately stalled.

Thankfully, the commission's findings were ultimately in Canada's favour, but the process cost Canadian businesses and governments significant amounts of time and legal costs. There are concerns that these types of investigations will rise again under a new administration south of the border.

I will note that CPMA once managed the U.S. duties for produce and for our industry, which were phased out under the Canada-U.S. Free Trade Agreement and then NAFTA, along with the phasing out of duties with Mexico and Chile. The Government of Canada should look at opposing any reintroduction of any types of duties on our industry as we look at the 2026 CUSMA review.

Second, Canada's free trade agreements, including CUSMA, should support regulatory harmonization that can lead to adoption of higher standards and regulations across countries, ensuring that products and services meet the same safety standards and quality standards while reducing regulatory burden and associated compliance costs for businesses. Plant health and pest risk management are areas of potential improvement when it comes to regulatory collaboration.

Finally, CPMA would like to draw to the committee's attention the potential trade irritant related to the government's proposals in relation to plastic packaging. Our North American partners have raised concerns that the introduction of the federal plastics registry may violate the environmental and trading provisions under CUSMA, including the requirement to disclose proprietary information such as composition of packaging. Other concerns with the registry include the lack of clear guidelines on registration duties and accountability across the supply chain, as well as the increased risk of supply chain disruptions due to discrepancies with existing supply chain data systems.

ECCC's proposed actions in the form of the pollution prevention notice plan for primary food packaging, as well as proposed labelling and recycled content regulations, also contain requirements that are highly problematic to the North American fresh produce industry. The combination of these actions, if implemented, could mean a significant disruption to our industry and impact over 160 different countries that ship to Canada. There are also concerns that the proposed regulatory regulations create an unfairness around the delivery of our products domestically and internationally.

The continuation of a free trade framework for fruit and vegetables under CUSMA is vital as we navigate a world of high food inflation and growing production challenges.

In closing, as representatives of a highly globally integrated industry, CPMA is supportive of the government's progressive trade agenda, which aligns to business growth and market access, and we hope that we can continue that within a review of the current agreement.

Thank you.