prepared for:

Canada-U.S. Grain and Seed Trade Task Group

March 31, 2013 By

TRC Consulting, Ltd.

Alexandria, VA Kendell W. Keith

ASSESSMENT OF AGRICULTURAL COMMODITY

FLOWS FROM U.S. TO CANADA, AND

HANDLING/PROCESSING CHARACTERISTICS

AFFECTING PHYTO-SANITARY REQUIREMENTS

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Forward and Authors Notes

This study was undertaken to assess the potential implications of The Canada Food Inspection Agency’s directive D-12-05, that would require all (bulk commodity) import shipments of U.S. origin to enter Canada under either standing, renewable import permits or accompanied by phytosanitary certificates issued by U.S. authorities. In brief, the report concludes that new regulations could affect bulk international and local markets near the border. A broad perspective on U.S.-Canada trade is given in Figure 8, p. 32. This table shows that Canada bulk commodity exports to the U.S. are about 3 times the U.S. volume in 2012. However, much of the U.S. decline in volumes shipped to Canada since 2007 tracks with corn export decreases that relates to U.S. biofuels programs and U.S. production declines in 2011 and 2012. This table also shows that trade moves both directions for many commodities (pulses, corn, soybeans, canola, screenings) which is indicative of local trade where production is moving to market-optimal processing and gathering points on both sides of the border. Also shown in Figure 8 is that screenings are a significant part (20%) of total U.S.-to-Canada movements. Screenings, and the variation in types of products that may be included in this figure, are important in drawing conclusions from this report. And the Canadian Food Inspection Agency added data and commentary (Appendix) after the study was completed that is highly relevant. The industry processes used to handle, process and ship bulk commodities, including both mitigation and disposal of risk material, in the U.S. and in Canada, are important considerations in determining reasonable border monitoring. These processes are summarized in Figure 7, p. 25. A written analysis of industrial processes related to risk reduction is contained in pp. 17-23. Figures 1, 3 and 6, provide summary data that is highly accurate for total export weights and border crossing points. The average size of shipment, and mode shown in Figure 6 is an estimate based upon the best available, but admittedly less reliable than the weight data (which can be confirmed via multiple sources). The number of potential shipments affected by new regulations is estimated to be about 40,000 shipments/transactions annually. Screenings, defined as small pieces of grain and other material remaining after the handling of whole grains, potentially contain a high proportion of risk material. On page 22 of this report, the screenings issue is reviewed closely and it is concluded that as much as 90% of the risk material moving from the U.S. to Canada could be from screenings. However, there is other evidence that a significant amount of these screenings are comprised of soy protein material and wheat material that is a by-product of milling. The data supplied by Canadian Food Inspection Agency further confirms this. However, the confusion in defining product data in the context of conducting this analysis helps to demonstrate the significance of proper definitions and applications in any new regulations. Trade in these bulk products remains very important to the local and international market systems for both U.S. and Canada. Additional Notes

1. Assessment of Agricultural Commodity Flows from U.S. to Canada, and Handling/processing Characteristics Affecting Phyto-Sanitary Requirements” was produced by TRC Consulting Ltd.. The report was commissioned for discussion purposes by Agriculture and Agri-Food Canada (AAFC) on behalf of the Grains Roundtable, an industry-government forum. The content of this report does not necessarily reflect the opinions or interests of the entire Grains Roundtable membership or AAFC, nor does it necessarily reflect the opinions or interests of all parties interviewed during the

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researching of this report. The recommendations resulting from the report are not binding on any participant of this Roundtable. The Author appreciates the cooperation from both industry and government in conducting the study. However, any errors in the analysis or conclusions of the report are strictly the responsibility of the author. Note 2 below and Appendix A give detailed explanation of one difference in data and analysis that was only clarified well after the final study had been conducted. It is believed that Appendix A,which was drafted by the Canada Food Inspection Agency (CFIA), does assist in putting the issue regarding screenings volumes and regulatory status into better perspective than relying solely on the report as drafted by the author.

2. Trade data used to generate this report were not obtained from Canada Border Services Agency

(CBSA) but from Datamyne using commodity codes applicable to U.S. exports and not necessarily Canadian imports. Following completion of this study, the CFIA examined data presented for imports of screenings (please refer to section III-J) and determined that the approximately 400,000 tonnes of annual import shipments identified as “screenings” under HS Code 23.02 were likely a wider range of products and byproducts falling within 23.02 that are not proposed to be included in CFIA’s proposed directive D-12-05 and therefore not subject to importation under permits or phytosanitary certificates. A more detailed explanation prepared by CFIA has been included in this report as Appendix A. The information contained in Appendix A, in particular the significant narrowing of the subcategories of HS 23.02 that would be subject to CFIA’s proposed directive D-12-05, was not known to the author during the period the study was conducted. The author of the study did pursue clarification of the definition of regulated screenings during the study, but was unable to obtain information to differentiate regulated screenings beyond the 4-digit HS code. It is important also to acknowledge that the differences in analysis contained in the report vs that contained in Appendix A is not a deficiency of Datamyne data, as Datamyne data is provided in 10-digit detail, and could have been used to do comparable analysis to that provided in Appendix A, had the distinction been known to the author at the time of the study.

Kendell W. Keith, Author TRC Consulting Ltd.

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ASSESSMENT OF AGRICULTURAL COMMODITY FLOWS

FROM U.S. TO CANADA, AND HANDLING/PROCESSING

CHARACTERISTICS AFFECTING PHYTO-SANITARY

REQUIREMENTS

CONTENTS I. Explanation of Methodology ...................................................................................................................... 5

II. Summary Results of Reported U.S. to Canada Commodity Flows, by Shipment Units and

Weight, 2010 to 2012 ........................................................................................................................................... 7

Estimates of Average Movements by Truck, Rail and Water by Commodity ........................ 15

III. Marketing and Processing Practices, by Commodity, by Industry Segment .................. 18

A. Pulses ............................................................................................................................................................ 18

B. Wheat ............................................................................................................................................................ 18

C. Corn................................................................................................................................................................ 19

D. Minor imports: Barley, Oats, Rye, Buckwheat, Canary, Sorghum, Flax, Sunflower .... 20

E. Rice ................................................................................................................................................................. 21

F. Soybeans ...................................................................................................................................................... 22

G. Canola ........................................................................................................................................................... 22

H. Other Oilseeds ........................................................................................................................................... 22

I. Peanuts ......................................................................................................................................................... 22

J. Screenings – Commodity Shipments identified as exiting the U.S. under HS code

23.02 ..................................................................................................................................................................... 23

IV. Summary of Industry Processes, Outlook for U.S.-Canada Trade and Industry, and

Comments from Survey .................................................................................................................................... 25

V. Conclusion ...................................................................................................................................................... 34

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I. EXPLANATION OF METHODOLOGY

In 2012, the Canadian Food Inspection Agency (CFIA) initiated a consultation process on proposed new and updated (for certain cereal grains) import control measures intended to manage the agronomic, economic and environmental risk of invasive plant species considered to be pest species. Whereas such invasive species can accompany import shipments from any country of origin, CFIA proposed the additional measures for both the United States of America (U.S.) and offshore countries of origin. The new proposed directive, D-12-05 proposes that all import shipments of U.S. origin will enter Canada under either standing, renewable import permits or accompanied by phytosanitary certificates issued by U.S. authorities. This study was designed primarily to better understand the nature, volume and regional distribution of grain and grain product/by-product imports of U.S. origin to in turn understand the likely applicability of D-12-05.

This study was conducted during January-March of 2013. Formal data on shipments presented in this report are based upon U.S. customs export data (U.S. to Canada) as compiled and provided by Datamyne, a commercial data sourcing firm providing detailed information on underlying customs data. Total annual data from Datamyne for 2010-2012 were compared with U.S. commodity export data reported through USDA and other sources to confirm accuracy. While the Datamyne and USDA data do not match precisely (differences are generally within 2-3%), Datamyne numbers tend to be slightly larger than those reported by USDA due to the inclusion of seed shipments in addition to commercial commodity movements for food and feed purposes. Thus, the data have been verified to be highly accurate on an annual basis. Unless otherwise stated within this document, trade data are reported on a calendar year basis.

The customs data provided by Datamyne are generally used to map quantities and “units” shipped in identified commodity flows. Also mapped are the flows through reporting districts located in the U.S. These districts include: Seattle WA, Great Falls MT, Pembina ND, Duluth MN, Detroit MI, Ogdensburg NY, Buffalo NY St. Albans VT and Portland ME, plus other minor volume districts.

Additional information regarding U.S. handling practices and shipments to Canada was assembled through telephone/email contacts by the principal researcher of this study with government officials, industry representatives and other knowledgeable people involved in industry associations.

Information regarding Canadian handling and processing practices were gathered and reported through the following associations:

Canadian National Millers Association Canola Council of Canada Flax Council of Canada Animal Nutrition Association of Canada Malting Industry Association of Canada Pulse Canada Western Grain Elevator Association Canadian Association of Importers and Exporters Canadian Renewable Fuels Association

Additional Canadian and U.S. firms were interviewed by the principal researcher. Of particular interest in the study, in addition to the total flows of commodities, is the number of individual transactions and/or individual movements for each commodity. The Datamyne data are not

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reported in the form of individual transactions (bills of lading), but rather as combined “packets” or grouped “units” of transactions for each reporting district on a monthly or more frequent basis. Some “units” of monthly information can include as many as 12 unit reports for individual commodities within individual districts, and some of these are individual transactions; but others are clearly groups of transactions. On the basis of reported total weights of these individual units, and ranges of typical weights for various conveyances (truck weights generally ranging from 20 MT – 40MT; railcars ranging from 80 MT-100 MT; and laker boats from 10,000 MT to 25,000 MT), and additional information from shippers and receivers in the U.S. and Canada, an estimate is made in this study of the number of annual individual transactions and movements by various modes. The surveys of Canadian receivers were particularly helpful in confirming the overall patterns of shipping conveyances. In the context of gaining a better understanding of how many transactions would be potentially subject to the requirements, it is helpful to understand that rail movements involved in one transaction that include multiple cars could be graded and inspected as a single unit or as single cars. Laker vessel shipments can likewise be inspected as a single unit (shipment). In the case of truckload movements, each truckload could be treated as a single shipment, unless documentation permits otherwise.

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II. SUMMARY RESULTS OF REPORTED U.S. TO CANADA COMMODITY FLOWS,

BY SHIPMENT UNITS AND WEIGHT, 2010 TO 2012

Figure 1 presents a table of U.S. to Canada commodity flows by reported “units” shipped (which may contain one or more conveyances or transactions), total volume (Metric Tonnes, MT) and average weight of the reported shipment unit. The largest total commodity volumes moving are corn, screenings, soybeans, rice, canola, pulses, peanuts and wheat. Corn volumes vary the most between years, as relative crop sizes between U.S. and Canada vary due to weather and crop conditions. Corn imports in 2012 are at a 5-year low for trade between the two countries. If the U.S. returns to a more normal yield in 2013, with a higher exportable surplus, corn exports to Canada could increase somewhat.

Figure 1

Commodities Units Shipped and Total Volumes (Metric Tonnes), 2010 - 2012

2010 2011 2012

Code Product

Total Units

Shipped

Total Volume

(MT)

Average Weight

per Unit (MT)

Total Units

Shipped

Total Volume

(MT)

Average Weight

per Unit (MT)

Total Units

Shipped

Total Volume

(MT)

Average Weight

per Unit (MT)

0713 Pulses (Total) 741 107,404 145 779 101,613 130 803 100,681 125 071310 Dried Peas 191 34,184 179 178 20,838 117 160 17,543 110 071320 Garbanzos 53 3,826 72 65 7,496 115 71 5,183 73 071331 Mung Beans 44 1,078 24 42 1,060 25 37 589 16 071332 Red Adzuki 34 1,764 52 38 3,219 85 35 1,608 46 071333 Kidney Beans 160 29,608 185 195 38,989 200 234 42,46 181 071339 Beans (Other) 139 16,122 116 138 12,675 92 138 19,682 143 071340 Lentils 67 19,127 285 84 16,007 191 87 11,878 137 071350 Broad Beans 5 135 27 4 18 5 9 48 5

071390 Leguminous Vegetables

48 1,560 32 35 1,312 37 32 1,683 53

1001 Wheat 94 45,911 488 109 64,827 595 115 97,290 846 1002 Rye 3 292 97 5 119 24 4 334 84 1003 Barley 52 26,731 514 59 49,461 838 22 4,601 209 1004 Oats 53 20,595 389 52 20,474 394 48 7,126 148 1005 Corn 429 1,570,661 3,661 387 974,566 2,518 380 625,140 1,645 1006 Rice 785 225,939 288 757 226,325 299 772 225,008 291 1007 Sorghum 23 3,820 166 26 3,496 134 34 3,427 101 1008 Buckwheat 196 10,646 54 209 16,302 78 286 15,366 54 1201 Soybeans 134 230,842 1,723 131 264,151 2,016 146 241,506 1,654 1202 Peanuts 157 66,050 421 171 74,005 433 149 71,156 478 1204 Flaxseed 70 5,557 79 70 7,104 101 82 9,594 117 1205 Canola 66 198,498 3,008 74 130,249 1,760 67 136,988 2,045 1206 Sunflower 215 24,107 112 212 31,668 149 206 31,697 154 1207 Others (Oil) 345 17,948 52 358 17,864 50 395 24,281 61 2302 Screenings 340 381,340 1,122 356 355,992 1,000 324 403,911 1,247

[Refer to Appendix A for CFIA-provided clarification on the data]

Overall, Canada is very close to being self-sufficient in corn and utilizes wheat as a feed grain to cover some seasonal, and weather-related corn shortages in feed markets. Also, Canada exports some significant quantities of corn to the U.S. In the last 3 years Canadian corn exports to the U.S. have averaged 500,000 MT. Other U.S. commodity imports into Canada, for those crops also grown in Canada

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(including pulses, wheat, rye, oats, barley, soybeans, flax, canola, and sunflower), tend to be minor in volume (zero to five percent of total Canada production). Rice and peanuts are not grown commercially in Canada and the pattern of imports from the U.S. for those commodities tends to be very stable over time. In addition to the standard crop commodities, substantial quantities of screenings are shipped from the U.S. to Canada. Screenings which come from the handling of corn, wheat and protein/oilseed crops are generally used in feed rations.

Figure 2

Figure 2 is comprised of a series of charts showing the 3-year history of the frequency distribution of the sizes of reported units of U.S.-to-Canada exports by weight ranges. The reported “units” of data may represent individual shipments or groups of shipments. But, in general, commodities that are moved mostly via truck tend to have the highest concentration of shipment units in the first two categories, 0-50 MT and 50 MT to 120 MT. From these data, (supplemented by rail waybill sample data on rail movements, available through the U.S. Surface Transportation Board; and U.S. Dept. of Transportation Freight Analysis Framework data), industry survey work, and conversations with shippers, receivers and rail carriers, the data for estimated numbers of rail, truck and boat (laker) volumes and distributions by mode for each commodity were generated (these are shown in Figure 5 and Figure 6). The only two commodities that have significant movement by laker vessel are corn and soybeans, and the movement of corn by laker from U.S. to Canada was much smaller in 2012 due to the U.S. drought.

While the weight distribution frequency explains much of the variation in volumes, for some of this traffic such as pulses, sunflowers and other minor crops, a considerable proportion of the reported shipment units in the 0-50 MT category fall into weights below 15 MT, indicating that a number of individual shipments are at less-than-truck size. These shipments are likely reflecting the characteristics of local markets and local logistics in which some U.S. producers find marketing opportunities in Canada that are more favorable or in closer proximity than U.S. alternatives. No doubt, the same local market characteristics happen in other locations with Canadian producers bringing small lots into the U.S. where there are attractive U.S. market alternatives due to local marketing conditions and opportunities.

Figure 2

Frequency Distribution of Sizes of Reported U.S.-to-Canada Export Units, by Weight Ranges

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Figure 3 shows the distribution of shipment units and volumes of all commodities through the 17 highest

volume reporting districts for agricultural commodities. One of the reporting districts is listed as “low

volume”, which is simply a designation that that particular shipment amount was relatively small and the

actual district was not recorded in the paperwork. Pembina, North Dakota and Detroit, Michigan tend to

dominate the volume of movements, although Detroit declined sharply in 2012. Most of the laker traffic

for corn and soybeans is reported from the Detroit and Cleveland reporting districts, and corn volumes

shipped by water were particularly lower in late 2012, leading to most of the decline. This table provides

some indication of the metric tonne volume levels that might be expected in the future, should additional

import requirements be imposed. However, to assess the number of reported units that might be subject

to phytosanitary certificates, the reported “units” in the first three columns of Figure 3 must be adjusted

for the estimated number of conveyances and individual shipments. Those estimations and calculations

are presented in Figure 5 and Figure 6.

Figure 3

Total of Reported Commodity Units Shipped and Volume by Export Reporting District, 2010 - 2012

Number of Units Total Weight (Metric Tonnes)

Avg Weight per Unit (Metric Tonnes)

District 2010 2011 2012 2010 2011 2012 2010 2011 2012

PEMBINA, ND 562 545 573 984,263 581,852 440,466 1,751 1,068 769

SEATTLE, WA 475 538 548 106,267 161,861 377,726 224 301 689

DETROIT, MI 783 793 850 1,347,231 1,103,275 467,725 1,721 1,391 550

BUFFALO, NY 491 480 501 135,795 112,992 304,737 277 235 608

OGDENSBURG, NY 254 233 245 103,838 79,142 77,843 409 340 318

GREAT FALLS, MT 329 336 309 103,778 99,679 172,409 315 297 558

PORTLAND, ME 91 96 84 18,433 20,785 52,095 203 217 620

LOW VALUE 567 560 574 74,773 41,802 270,746 132 75 472

DULUTH, MN 102 124 92 23,093 24,331 161,893 226 196 1,760

ST. ALBANS, VT 37 34 41 11,757 3,662 6,272 318 108 153

CLEVELAND, OH 6 5 6 17,957 71,616 2,458 2,993 14,323 410

NEW ORLEANS, LA 4 2 2 89 24 14 22 12 7

ANCHORAGE, AK 1 1 3 24 20 881 24 20 294

BOSTON, MA 1 0 0 9,041 0 0 9,041 0 0

MILWAUKEE, WI 0 2 1 0 26,695 2,097 0 13,348 2,097

MINNEAPOLIS, MN 0 2 2 0 20 130 0 10 65

SAVANNAH, GA 0 3 2 0 60 171 0 20 86

COLUMBIA-SNAKE 0 1 0 0 10,400 0 0 10,400 0

Figure 4 looks at the eight largest volume commodities exported by the reporting shipping district for 2012. The data in Figure 4 are likely to be fairly representative of annual regional shipping patterns of major commodities through each reporting district, with the exception of corn. In previous years, the volume of corn shipments through Pembina, ND and Detroit, MI have been comparable. With the drought in 2012, both Detroit and Cleveland volumes are much lower. A more normal distribution for corn would likely have the total volume of corn shipments in the Detroit district very close to those for Pembina.

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Figure 4

Volumes of U.S.-to-Canada Movements, by Major Commodity Through Each Reporting District, 2012

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ESTIMATES OF AVERAGE MOVEMENTS BY TRUCK, RAIL AND WATER BY COMMODITY

Figure 5 and Figure 6 on the following two pages present estimates of the average rail, truck and water volume for each commodity over the previous 3 calendar years. Figure 6 takes the analysis a step further by estimating the approximate number of individual shipments (including whole train shipments and boat shipments) that would qualify for a single phytosanitary certificate if that became part of the requirements for moving commodities from U.S. to Canada.

Data estimates in Figure 5 and Figure 6 were compiled and estimated on the basis of the Datamyne analysis; from rail “waybill sample” data on rail movements, available through the U.S. Surface Transportation Board; and from the U.S. Dept. of Transportation Freight Analysis Framework data, that is based on the 5-year census.) Also considered in the estimates contained in Figure 5 and Figure 6 are the results of industry survey work, and conversations with shippers, receivers and rail carriers to estimate the numbers of rail, truck and boat (laker) volumes and distributions by mode for each commodity.

As for projecting likely U.S.-to-Canada shipping patterns in the future, it appears very likely that peanut shipments and rice shipments will remain fairly stable. If U.S. policy regarding use of corn for ethanol does not change, the U.S. could move into more of a surplus situation in corn than has been experienced in the last 4 years (since 2008) and corn movements from the U.S. to Canada could begin increasing somewhat. Movements in wheat between the U.S. and Canada will adjust to the new market circumstances and the net directional change on trade is difficult to forecast at this juncture. Trends in wheat trading will be influenced by a number of factors, some of which are yet to be determined.

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Figure 5

Estimated 3-Year Average, 2010 – 2012, U.S.-to-Canada Commodity Shipment Volume: Truck, Rail,

and Water, Metric Tonnes

Avg. Annual Metric Tonnes

2010-2012

Total Volumes Percent Volumes

Truck Rail Water Truck Rail Water

Pulses (0713) 103,000 82,000 21,000 0 80% 20% 0%

Wheat (1001) 69,000 14,000 55,000 0 20% 80% 0%

Rye (1002) 200 200 0 0 100% 0% 0%

Barley (1003) 27,000 0 27,000 0 0% 100% 0%

Oats (1004) 16,000 8,000 8,000 0 50% 50% 0%

Corn (1005) 1,057,000 384,000 423,000 250,000 36% 40% 24%

Rice (1006) 226,000 113,000 113,000 0 50% 50% 0%

Sorghum (1007) 4,000 0 4,000 0 0% 100% 0%

Buckwheat (1008) 14,000 14,000 0 0 100% 0% 0%

Soybeans (1201) 245,000 160,000 0 85,000 65% 0% 35%

Peanuts (1202) 70,000 63,000 7,000 0 90% 10% 0%

Flaxseed (1204) 7,000 7,000 0 0 100% 0% 0%

Canola (1205) 155,000 125,000 30,000 0 81% 19% 0%

Sunflower (1206) 29,000 22,000 7,000 0 76% 24% 0%

Others, Oil (1207) 20,000 13,000 7,000 0 65% 35% 0%

Screenings (2302) 380,000 304,000 76,000 0 80% 20% 0%

TOTAL 2,422,200 1,309,200 778,000 335,000 54% 32% 14%

[Refer to Appendix A for CFIA-provided clarification on the data]

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Figure 6

Estimated 3-Year Average, 2010-2012, U.S.-to-Canada Total Conveyances of Commodities (trucks, rail cars,

laker vessels) and the Number of Transactions Potentially Subject to Proposed CFIA Directives**

Trucks Rail Cars Boats

(Lakers)

No. of Transactions Potentially Subject to Proposed CFIA

Directives**

Pulses (0713) 2,563 210 0 2,610

Wheat (1001) 438 611 0 561

Rye (1002) 6 0 0 6

Barley (1003) 0 386 0 77

Oats (1004) 320 133 0 347

Corn (1005) 9,600 4,700 10 10,080

Rice (1006) 3,531 1,507 0 3,833

Sorghum (1007) 0 44 0 9

Buckwheat (1008) 438 0 0 438

Soybeans (1201) 4,000 0 5 4,005

Peanuts (1202) 3,150 93 0 3,169

Flaxseed (1204) 175 0 0 175

Canola (1205) 3,125 333 0 3,192

Sunflower (1206) 688 93 0 707

Others, Oil (1207) 406 93 0 425

Screenings (2302) 9,500 1,013 0 9,703

TOTAL 37,940 9,216 15 39,337

**To estimate numbers in this column, each truck is treated as an individual shipment and rail movements are assumed to move in five-car units, except for corn, which is assumed to move in 10-car lots. Truck sizes assumed for each commodity range from 20 MT (for peanuts) to 40 MT for the heaviest commodities.

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III. MARKETING AND PROCESSING PRACTICES, BY COMMODITY, BY INDUSTRY

SEGMENT

A. PULSES

Description of U.S. to Canada Trade: Canada is a significant producer and exporter of dry peas, lentils and dry beans. In dry pea and lentils, Canada produces about 6 times the quantity of the U.S. U.S. production of dry beans is somewhat larger than that of Canada and trade moves fluidly both ways across the border in all three categories of dry peas, lentils and dry beans. Figure 1 shows that in the last 3 calendar years, U.S. has shipped about 100,000 tonnes of total pulses to Canada each year. (For comparison, Canada shipped about 150,000 tonnes to the U.S. in 2012. And, U.S. exports of these commodities represent about 2 to 3 % of total Canadian output of these commodities.) Pulses in the U.S. are grown in a wide range of states, but tend to be most concentrated in the north, close to the border with Canada, and most of the shipments from the U.S. are reportedly done directly by farmer trucks or by marketing cooperatives and dealers that combine multiple farmers’ production prior to shipping mostly by truck. States where these practices are common include Michigan, Wisconsin, Minnesota, North Dakota, Montana and Idaho. For the most part, while most pulses are reportedly not cleaned prior to shipment and moved by truck, there are two handling and cleaning/sorting facilities in Western North Dakota that ship some dry peas and lentils to Canada via rail. Most of this trade in pulses, particularly in the Western U.S. and Canada, is from the most concentrated production areas in counties within 100 miles of the border and the trade (both U.S. to Canada and from Canada into the U.S.) probably reflects the natural combining of crops from similar growing regions on both sides of the border for the sake of marketing efficiencies that are gained. Processing and Handling in Canada: Based upon a survey of Canada processors (these processors represent about half of the reported import volume), about 20% of total shipments from the U.S. move by rail and 80% are trucked. A high proportion (90%+) of the surveyed companies purchase “field run” pulses, although a small percentage of shipments have been through a rough cleaning process, and are then given a more complete cleaning in Canada prior to moving to processor or to export markets. Most of the Canadian survey respondents were in the business of buying/selling/cleaning/exporting pulses.

As for the disposition of screenings, all the pulse handlers surveyed reported that the screenings following cleaning were sold to feed manufacturers. One large handler reported roasting some screenings prior to shipping to feed mills. Roughly two-thirds of the handlers (by volume shipped) reported that they sold screenings to feed operations that subsequently used heat in processing and/or utilized pelleting operations in feed manufacture.

B. WHEAT

Description of U.S.-Canada Trade: From 2010 to 2012 U.S. exports of wheat to Canada increased gradually from 46,000 MT to 97,000 M.T. The average for the 3 years was 69,000 tonnes (representing about 0.3% of total Canadian wheat production). As a comparison, in 2012, Canada shipped an annual average of 2.245 million MT of wheat to the U.S., or roughly 10% of Canada’s total global wheat exports.

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Industry reports of wheat trade indicate that about half of total Canadian wheat imports are purchased by Canadian mills, and the other half are purchased by grain trading firms that re-sell the wheat into export markets, to domestic animal feeders or other users. Very little, if any, of the U.S. wheat moving into Canada is cleaned prior to import, and Canadian trading firms that store wheat generally do not clean the wheat prior to sale. An estimated 80% of the U.S. wheat moving into Canada goes by rail, with the remainder going by truck. Presented below in italics is a detailed description of the industry practices of the Canadian milling industry provided by Canadian National Millers Association.

C. CORN

Description of U.S.-Canada Trade: Corn is an important crop in Canada (3rd largest in volume behind wheat and canola). In the U.S. corn is the dominant field crop and trade flows between the two countries fluidly in both directions. In the last 3 calendar years (see table below), while net trade tends to move more U.S. corn into Canada, the volume and direction of trade for a given year is most sensitive to growing conditions and overall production. The year 2012 was a very low-yield year for corn in the U.S. but Canada’s production was close to normal, resulting in net positive flows of Canadian corn into the U.S.

Canada-U.S. Trade in Corn, Calendar Years 2010-2012, (Metric Tonnes)

2010 2011 2012

U.S. to Canada 1,570,661 974,566 625,139

Canada to U.S. 274,000 524,000 698,653

For corn trade, all three modes are important. Laker vessels move an estimated 24% of U.S. corn into Canada in the East, while trucks and rail share roughly equal parts of the remaining traffic. Rail is important particularly in the west in moving trains of corn into western cattle feeding and other livestock operations. Truck movements of corn occur all across the border and represent more than one-third of total truck volume for all commodities moving into Canada.

Based upon the pattern in the three years of data, it appears that when there is a decline in the volume of trade in corn, the most dramatic decline occurs in lake traffic. Thus, the trade in truck and rail trade appears to be more stable from year-to-year. Of course, this pattern of movement will also be dependent on the pattern of any crop drought or other difficulties in short years.

Processing and Handling in Canada: Approximately 42% of Canada corn use is for food and industrial production (about 32% of total corn use goes through traditional corn wet milling to produce corn syrup, starch and related products; and about 10% in dry corn mill fuel ethanol production). The remainder of the corn is used in livestock and poultry rations for meat, milk and egg production. Very little, if any, of the U.S. corn that is imported into Canada is cleaned prior to entry. The various corn processing methods in each of these sectors is explained separately below.

Corn Wet Milling (for starch and syrup): Wet corn mills screen corn prior to entering a steeping process. That process utilizes sulfur dioxide and water heated to 50 degrees centigrade for about 30-40 hours to soften the corn prior to its separation into starch, gluten (protein), fiber and germ fractions. The starch fraction is used to produce food and industrial products; the gluten and fiber fractions are used to produce feed ingredients and the germ fraction is used to produce food grade oil and feed ingredients.

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The nature of the handling of the screenings from the corn is not changed by the final end product use of the starch. The screenings can be sold into feed markets “as is,” can be combined with fiber and steep water to produce corn gluten feed that can be sold in bulk form or be pelleted prior to being sold into feed markets. Pelleting includes heat treatment with temperatures reaching 90C for a minimum of 30 minutes. The screenings are a source of revenue to the corn milling operation so companies try to maximize revenue from screening and handling operations. The operation of any individual facility depends on the type and preferences of feeding operations that purchase the by-product (whether the feeders prefer raw screenings; screenings blended into bulk corn gluten feed or manufactured into pellets).

Corn Dry Milling for Ethanol Production: Dry milling operations generally have a cleaning process that removes coarse materials (crop residues), but does not attempt to clean to remove broken kernels that have value in the ethanol production process. If any cleaning is done to a level that removes broken corn or other material that has feed value, companies attempt to recover this material and add it to the end by-product, distillers grains (DDGs). The corn is then milled and moved into a slurry system where it is heated at 80C for 20 minutes; it then proceeds to a “jet cooker” for 10 minutes at 110C; goes through “liquefaction” at 85C temperature for 120-150 minutes; it then goes into fermentation for 44-50 hours at 32-35C. Ethanol is drawn off using a centrifugal mechanism and the remaining feed by-product, DDGs, is generally dried at the plant before moving into dairy, cattle, pork and poultry markets. It may be delivered and fed “wet” (without moisture removal for feeding operations that are very close and can utilize the material quickly) or it is dried and delivered into feed channels. Drying processes for DDGs vary. A typical drying operation would heat DDGs in an oven at 700 F with the DDGs increasing up to 190 F. Rotary dryers often used for this process require 20-30 minutes to dry the material down to storable moisture levels. In other operations, “flash” dryers are used at higher temperatures, but generally only require a few minutes to dry the product.

Commercial Feed Operations (custom manufactured feeds for livestock operations) or Livestock Feeding Operations Manufacturing Own Feed: Based upon industry input, the processing and handling of corn in feed manufacturing is highly variable. Here are some examples: 1) One sizeable feeding operation screens none of its corn; it processes corn through a hammer or roller mill to reduce particle size. Hammer milled grain is conditioned with steam at 75-80 C in a pelleting process. Some of the grain goes through a separate roller mill process to reduce particle size to 500-700 microns. There is no steam conditioning of this product. This part of the feed manufacturing process produces a mash that is included in the feed; 2) As another example of the commercial feed sector, the following description was provided by the Animal Nutrition Association of Canada (see below, in italics). ANAC membership represents about 90% of the commercial feed manufacturing in Canada. But it should also be recognized that there is a substantial volume of on-farm feeding and feed mixing that occurs. The commercial feed mill sector buys mostly corn and protein meals (canola and soy) and some screenings.

D. MINOR IMPORTS: BARLEY, OATS, RYE, BUCKWHEAT, CANARY, SORGHUM, FLAX, SUNFLOWER

Description of U.S.-Canada Trade: These seven crops have relatively minor import volumes into Canada. But as shown in the table below, four of these crops---Rye, Oats, Barley and Flax---have sizeable production and export flows from Canada into the U.S. As a total, these grains represent a more sizeable flow of commodities into the U.S. than the total of all of the agricultural commodities flowing from U.S. to Canada. These seven commodities represent only 3% of the total flow of commodities from the U.S. to Canada. The nature of the trade is different, however, in that Canadian-to-U.S. shipments of oats and

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barley tend to be in rail cars and in high volume lots, so there are fewer transactions relative to the total volume, compared to typical trade from U.S. to Canada. Sorghum in the U.S. has shrunken in planted area and is unlikely to expand significantly in the future, so U.S.-Canada trade patterns are unlikely to change. Likewise, barley and oats have declined in importance in the U.S. crop production mix, so little change in the direction of trade flows should be anticipated. Buckwheat, millet and canary seed are specialty grains that are used in some consumer baked products, but more often used in domestic and wild bird feed mixtures. (Note also that while these crops have minor imports into Canada, rye, oats and barley are very significant feed grains in Canada.)

Canada-U.S. Trade in Rye, Oats, Barley, Buckwheat (including millet and canary seed), and Sorghum, Calendar 2012 (Metric Tonnes)

Rye Oats Barley Buckwheat Sorghum Flax Sunflower Total

US to CA 334 7,126 4,601 15,366 3,427 9,594 31,697 72,145

CA to US 149,889 1,520,509 512,396 28,265 36 185,591 28,027 2,424,713

E. RICE

Description of U.S.-Canada Trade: Canada is the third largest destination for U.S. rice exports, and the trading pattern is very predictable and consistent across years. Rice imports into Canada occur via both truck and rail, in both bulk and packaged forms. There are four basic forms of rice imported: 1) (HS 10061) rough or paddy rice which remains in the husk form; 2) (HS 10062) husked or brown rice (husk removed and kernel is surrounded only by bran layer); 3) (HS 10063) milled or parboiled rice (most highly processed form); and 4) (HS 10064) broken rice. The following table presents the distribution of volumes for each of these HS codes.

U.S. to Canada Rice Total Volumes Shipped, 2010 – 2012 (Metric Tonnes)

2010 2011 2012 Rough Rice (10061) 145 264 211 Brown Rice (10062) 52,293 53,730 53,225 Milled/Parboiled Rice (10063) 148,959 143,927 142,582 Broken Rice (10064) 24,542 28,404 28,989

The milled/parboiled rice has been cleaned, milled and processed and is in final form ready for delivery to consumers in boxes or bags. This category represents about 2/3 of the total volume of U.S. rice movements into Canada. Brown rice, while less refined than fully milled rice has also been through a husk removal process and is in a consumer-ready form, although some additional processing could be done in Canadian facilities. Broken rice is rice that has been broken in the U.S. processing system and is generally sold into feed and pet food markets in Canada. Because such broken rice has generally been through the same processing and refinement as milled rice, it is not believed to pose any risks.

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F. SOYBEANS

Description of U.S.-Canada Trade: Trade in soybeans between U.S. and Canada, like many other commodities flows both ways. In calendar year 2012, U.S. shipped 242,000 tonnes to Canada, and Canada shipped 363,000 tonnes to the U.S. Based upon the pattern of traffic, movements of soybeans are dominated by truck movements in both directions, although some laker vessels are used. Approximately 2/3 of the total volumes of U.S.-to-Canada soybean moves are shipped via truck (generally 40 MT double trailers).

Processing and Handling in Canada: Processors reported that soybeans are not cleaned prior to import. All soybeans received are cleaned with disposal of all cleanings into landfills. The primary process used to crush soybeans is a hexane process, utilizing high levels of heat. Screenings are not re-added at any point to product or by-product out of the soybean processing facilities.

G. CANOLA

Description of U.S.-Canada Trade: In calendar year 2012, the U.S. shipped 137,000 tonnes of canola to Canada. Canada shipped 419,000 tonnes of canola to the U.S. A large majority of the U.S. movements were shipped by truck.

Processing and Handling in Canada: Processors indicated that canola was screened prior to the crushing process. In some cases, screenings were all milled, heated and pelletized and added to final product. Processed product is sold alone or in mixed feeds. In other cases (a company location) screenings were handled in 3 different ways: 1) use of unprocessed screenings alone or in mixed feeds; 2) use as processed (heat) screenings alone or in mixed feeds; and 3) disposal to landfill. This particular company noted that heating/pelleting equipment were being installed to pellet all screenings in the future.

H. OTHER OILSEEDS

Description of U.S.-Canada Trade: in calendar year 2012, the U.S. shipped 24,000 tonnes of commodities classified as “other oilseeds” (HS 1207). This category is comprised of cottonseed (46% of total) and oleaginous fruits (40%). The remainder of U.S. exports is comprised of very small quantities of sesame, mustard and safflower. None of these commodities appeared as imports to Canada firms that participated in surveys by the Canadian industry for this project, so there is no information on processes that are used. Cottonseed is used in the U.S. in dairy rations to improve milk fat production. As a comparison, Canada-to-U.S. shipments of other oilseeds in 2012 was 67,000 tonnes, 97% of which was mustard seed.

I. PEANUTS Description of U.S.-Canada Trade: (Note: all the information reported here, except for the export/import data from Datamyne is based upon conversations with U.S. companies and individuals knowledgeable

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about the U.S. peanut industry. No successful contacts were made with Canadian-based peanut operations.) Peanuts moving from the U.S. to Canada, generally come out of North Carolina and bordering states and are largely shipped by truck (20 MT trucks with packing done in either 1-metric tonne bags; or 50-kilo bags) although some small quantities are moved by rail. Total shipments in 2012 were 71,000 MT and similar amounts were shipped in both 2010 and 2011. There are 3 large peanut processing operations in Canada, and a number of smaller ones. Of the peanuts imported into Canada, about 50% are used in peanut butter production; 25% go into cooked/salted whole nut markets, and 25% into confectionary products. Part of the peanut butter produced in Canada is re-exported into the U.S. as a finished consumer product.

Processing and Handling in Canada: Precisely how Canadian processors handle peanuts is unknown to the author of this study. The shipping process from the U.S. includes harvesting peanuts; removing loose dirt; bagging the peanuts and shipping the raw product. In the U.S. peanut processing industry once shells are removed from peanuts, they can be used for cattle roughage (cellulose); pelleted for fuel (a relatively new process); landfilled; or used to produce artificial fireplace logs.

J. SCREENINGS – COMMODITY SHIPMENTS IDENTIFIED AS EXITING THE U.S. UNDER HS CODE 23.02

Description of U.S.-Canada Trade: U.S. movements of screenings to Canada are shipped mostly by truck, and mostly in raw, unprocessed form (not pelleted). It appears that, based upon shipping patterns, truck, and some rail movements of screenings move from the U.S. to on a fairly steady basis across the entire border from Eastern to Western Canada. Canada also ships about 166,000 MT of screenings to the U.S. The volumes over time also appear fairly consistent, at about 400,000 tonnes annually for U.S. to Canada movements. To get a better idea of what these screenings are, the following table reflects the source (wheat, corn, legumes), quantity and value for 2012 screenings. [Refer to Appendix A for CFIA-provided clarification on the data]

U.S.-to-Canada Shipment of Screenings, 2012 Type of Screenings Quantity (MT) Total Value Avg Value/Ton Range in Value

Corn 121,875 $14.4 mil $118 $56-329/MT Wheat 174,363 $27.9 mil $160 $72-301/MT Other Cereal 76,763 $8.2 mil $107 $99-289/MT Legumes 24,366 $5.9 mil $242 $86-371/MT

TOTAL 397,367 $56.4 mil $142 $56-371/MT

The vast majority of screenings are likely going into the feed market, largely as a substitute for corn or other feed grains. The values for 2012 were established in a year where corn price was highly variable but probably averaged $265 per metric tonne for the year, with a high of about $320. There is a difference in pricing of screenings on the basis of types and sources. Screenings are generally sold by weight, with heavier screenings worth more. At average 2012 values, if screenings were not permitted, replacing them with other material could cost Canadian industry $50 or more per tonne, or $19.9 million+. The average price spread for corn and screenings for 2012 was probably $123 per tonne ($265/tonne of corn minus $142 average screenings value) but if the screenings product were lost in some way to the market, the feeding value could be replaced at higher cost by comparable feed-value quantities of grains but additional costs for transport, gathering and additional raw material cost would be incurred. That is, the $123 per tonne would not be lost entirely, but there would be substantial cost

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for replacement. Screenings are utilized in a significant way in Canada because Canadian feeders and other users are located near a high-volume screenings producer ---the U.S.---and they are priced attractively relative to their feeding value.

Probably the reason that most screenings produced in the U.S. and shipped to Canada are in raw, non-pelleted form, is that pelleting is expensive. Based upon conversations with a feed milling operations manager, it is estimated that installing a new pellet mill would cost in a range of $1 million to $1.5 million, because of the need for a boiler and a conditioning system to maintain pellet size and conformity.

The level of total 2012 screenings U.S. shipped to Canada was 404,000 MT. This represents about 20% of the total commodities shipped during the year. Assuming that weed seeds are highly concentrated in whole grain screenings and that screenings might represent an average of 2% of the weight of whole commodity shipments, U.S. screenings shipments to Canada could represent up to 90% of the high risk material being traded. However, while this is a significant finding of this study, the source of screenings material, which partly come from by-products of milling (not just from screenings of whole grains) and the fact that some screenings are pelleted should also be considered in further analysis of risk presented by invasive species. The table above indicates that total screenings and other commodities shipped from U.S. to Canada in 2012 under HS code 23.02 was about 400,000 tons. This amount reflects 20% of total commodity movements across the border during the year, and was therefore quite significant. However, research and dialogue with commercials in both U.S. and Canada indicate that there may be some definitional differences of screenings that could affect the risk of invasive species. Based upon anecdotal information, it is believed that the corn screenings in the table are generally non-pelleted and are screenings mostly from whole grain elevator operations in the U.S. The screenings that are labeled “wheat” in the above table are known (on the basis of U.S. miller comments) to contain some substantial quantities of flour mill by-products in addition to whole grain screenings. No evidence was found that any of these “wheat” screenings were pelleted, and there was inadequate information gathered regarding how much by-product was included in the quantities. However, the sheer quantities of “wheat” screenings, compared to corn, would suggest that mill by-products contribute significantly to the volumes, because whole wheat volumes produced in the U.S. only represent 15-20% of the total corn volumes produced.

Finally, regarding legume screenings, anecdotal evidence was received that indicates a portion of these screenings are regularly pelleted prior to shipment. If weed seeds are concentrated in screenings (defined as screenings from whole grain handling), the volumes being moved from the U.S. to Canada would suggest that the phytosanitary risk from screenings is well over 50% of the total and could be as high as 90%. However, the precise amount of risk is not measurable from this report, because there is inadequate information gathered regarding the proportion of the reported screenings products that are processed or pelleted. It is therefore recommended that further study of import flows under HS code 23.02 be conducted to get a clearer understanding of the extent to which directive D-12-05 will be applicable.

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IV. SUMMARY OF INDUSTRY PROCESSES, OUTLOOK FOR U.S.-CANADA TRADE

AND INDUSTRY, AND COMMENTS FROM SURVEY

A. Summary of Industry Processes: Figure 7 below offers a summary of various industry handling and processing characteristics. The oilseed crushing industry’s, comprised of canola and soybeans. Screenings are generally exposed to high heat or are placed into landfills. The Canadian wheat flour milling industry mills screenings, and some screenings are pelleted (apparently very few flour mills in the U.S. pellet such material). Of the rice that is imported, only 23% undergoes any further processing in Canada. And the vast majority of this product is brown rice that has had the husk removed and been cleaned prior to export. Rough rice (with husks) is a very small amount of the total rice imported into Canada. The feeding industry is the most diverse of the industry sectors utilizing feed grains and screenings. While corn is the most common feed grain, barley, oats, rye and feed wheat also contribute much to total Canadian grains fed. In fact, (see footnotes to Figure 7) total feed grains fed in Canada averaged 20.5 million MT in 2010-2012. Interestingly, under some reasonable assumptions (i.e., 2% of grain production being recovered as screenings), Figure 7 estimates that screenings usage in Canada may total 1,669 K MT per year, 380 K MT of which is imported. This total number of 1,669 K MT represents 8% of total feed grains fed. U.S.-originated imported screenings represent about 1.8% of total Canadian grains fed. There are some large feeding and livestock operations using hammer milling, some pelleting, and steam treatment that will deactivate any sources of potential problems. But there are a wide range of feed handling and manufacturing processes throughout the industry that have different processes for different species. Also, on-farm feeding and mixing of feeds is common in Canada (as it is in the U.S.) which are generally unregulated.

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Figure 7

Canadian Production, Imports and Utilization of Major Commodities,

Canadian Production, Imports and Utilization of Major Commodities, 3- Year Average for 2010-2012 (Crop year basis)

and Summary of Canadian Processing Operations to Mitigate and Manage Risk Material (1,000 Metric Tonnes)

Commodity/ Industry

Production Imports Supply*** Exports Domestic

Processing Remove

Screenings Mitigation Processes

Risk Material Disposal

Pulses 4,778 108 4,886 3,941 932 Yes Some heating Feed markets

Wheat 25,264 75 25,339 17,446 8,684** Yes Hammering

Mills Pelleting

Feed Ingredients

Landfills Corn 12,154 976 13,130 1,121 11,922

Feed Mfg/Feeding No Hammer/

Roller Mills; Heat

Utilized in Feed Mixtures

Wet Corn Mills Yes Heat/Chemical

Process

Ethanol Dry Mills Yes Heat Process,

Heat in Drying

Soybeans 4,558 199 4,757 2,865 1,910 Yes None Landfills

Canola 13,569 149 13,718 7,668 6,828 Yes Heat Processed

or Unprocessed

Sold to Feed Mkts or Landfills

Other Grains****

10,879 42 10,921 4,410 7,257 Yes for malt

barley Steam-treated and Pelletized

Utilized in Feed Mixtures

Other Oilseeds 638 41 679 573 169 Rice***** 0 226 226 0 226 Peanuts 0 70 70 0 70

Screenings 1,437* 380 1,817 148 1,669 Feed Uses in

Various Forms

TOTAL 71,840 1,886 73,726 38,044 49,755

* Screenings production estimated at 2% of volume of grains/commodities produced. Screenings not included in sum totals of commodities at bottom.

** 40.5% of wheat usage is for food/industrial; the remainder is used mostly for feed, in competition with corn and other feed grains.

*** Supply of each commodity equals production plus imports; carryover stocks is not included in these figures. **** Other grains include barley, rye and oats. With the exception of about 300 K MT of these crops used for

food/beverage, the remainder goes into feed channels. Combining all grains used for feed (corn, rye, barley, oats, and feed wheat), grains used for feed total an average of 20,517 K MT per year. The screenings domestic use of 1,657 is 8% of this total.

***** Of 226K MT rice imported, 53 K MT is comprised of brown or rough rice that may be subject to further processing in Canada.

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Comments in Italics below are the summary of finding of the companies and associations surveyed: Summary of Survey of Cereal Grains as provided by the Canadian National Millers Association

This brief report is a summary of findings of a survey of member companies of the Canadian National Millers Association (CNMA) to gather information about typical import activity of the processing facilities operated by CNMA member firms, the nature of the processing activity and sale or disposal of materials removed from imported grain via cleaning processes. This survey was conducted by CNMA during February, 2013. The import volumes cited in this report apply to the 2012 calendar year. The data included have been aggregated so as to not disclose the identity of individual milling locations and member firms. About the CNMA CNMA is the national not-for-profit industry association representing Canada’s primary processors (millers) of cereal grains in Canada. To be eligible for membership in CNMA, the firm or individual must operate a milling facility in Canada. Some CNMA member firms are primary processors engaged only in milling of cereal grains (wheat, oats, rye, etc.) to produce primary products of milled grain intended for sale to further processors (bakery, bakery mix, breakfast cereal, biscuit, snack foods) or sale as ready-to-cook cereals such as rolled oats or bran cereals. However, some CNMA members operate or are affiliated with facilities that process commodities other than cereal grains or operate as further processing facilities that include manufacture of pasta, breakfast cereals, snack foods and other cereal grain based foods. The by-products of grain milling include materials removed in grain cleaning prior to the actual milling (grinding, reduction, separation of grain kernel components) and residual fractions (product streams) that are typically recombined into mill feeds (bran, middlings, ground screenings) for sale to livestock feed and pet food manufacturers directly for via brokers/distributors. A list of CNMA member companies and their respective mill locations can be viewed at www.canadianmillers.ca. CNMA members operate facilities across Canada ranging from Halifax to the lower interior of British Columbia. Grain Receiving Cleaning in Canadian Milling Establishments Shipments or lots of cereal grains to Canadian mills arrive by truck, rail car or freshwater vessels (lakers). With some exceptions, most shipments are not cleaned prior to vessel loading and shipment to mills. The exceptions are mills that are geographically positioned to receive grain that has already been cleaned to export standard, meaning containing significantly less foreign material, seeds of other species than grain that is not cleaned. The majority of shipments to mills are sourced from facilities that are part of Canada’s grain bulk handling and transportation system, meaning primary, transfer and terminal grain elevators. As grain enters this system via deliveries from farms, the grain is assigned a class and grade (typed of grad and quality determination) before being added to grain of like class and grade to segregate grain stocks by class, grade and other factors such as protein levels and/or named varieties (cultivars). Segregation of grain by named cultivars accounts for a very small portion of grain purchased by Canadian milling establishments. In excess of 95% of wheat arriving at Canadian mills has been purchased on the basis of being of a specific class and grade.

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A small portion of wheat received by Canadian mills is shipped directly from farms. Most of these shipments are transported by truck. However some are via rail cars that are loaded by producers (farmers) or their agents loaded directly so as to bypass the bulk storage and handling system. A larger percentage of oat shipments to Canadian mills are direct-from-farm shipments to oat milling establishments operated primarily in western Canadian provinces. When grain shipments are unloaded at mills, they are typically unloaded into a receiving pit from which the grain can be moved through a preliminary cleaning process or into storage (usually silos or steel bins) for cleaning at a later date immediately prior to processing (milling). The preliminary cleaning process typically removes very coarse foreign materials and crop residues (grain plant parts other than the grain kernels). At some mill locations, these materials represent a very small fraction of total grain received, have no commercial value and are bagged and/or bulk shipped for composting. The more thorough cleaning process that precedes milling involves a series of steps using various kinds of cleaning equipment to remove as much foreign material, crop residues, weed seeds and seeds of other crop types (canola, mustard, soybeans, corn) or particles of such seeds that are not intended or desired to be included in the primary products of the actual milling process (flours, semolina, meals, bran fractions, germ, etc.). The materials removed from this more extensive cleaning process are generally referred to as screenings and are segregated from all other processing streams except for blending back to mill feeds after being ground into finer particulate matter using hammer mills or other kinds of grinding/reduction equipment. Segregation and Disposal of Screenings As noted above, very coarse screenings removed during primary cleaning (scalping and magnets) are often segregated for composting or landfill. The screenings generated from the more extensive grain cleaning process are handled in one or more ways, dependent upon mill location, proximity to customers (end users) of the screenings. In the majority of mills, screenings are ground using hammermills and blended back into millfeeds. It is believed that when processed through a hammermill or similar grinding equipment, millfeeds no longer contain intact seeds capable of germination and growth. Some mills, but a small minority, segregate screenings for sale as unprocessed screenings to brokers or feed mills. Some mills, perhaps as high as 20% to 25% of the industry, grind and pelletize screenings to as to facilitate more economical shipment to other processors such as feed mills. In this case, it is also believed that grinding and pelletizing also renders all seeds incapable of germination and growth. The Commercial Value of Screenings Dependent upon the class and grade of grain being purchased and its origin (direct from farm or via bulk handling and transportation) screenings can account for between 1 and 3 per cent by weight of the inbound, un-cleaned grain.

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The profitability (economic performance) of milling establishments is reliant in part on recovering part of the cost of grain purchased through the resale of the screenings portion, whether as unprocessed screenings, ground and pelletized screenings or ground and blended back into mill feeds. For this reason, the movement of screenings to landfill or composting accounts for a very small portion of screenings generated in grain milling establishments. Imports of Cereal Grains by CNMA Member Companies The U.S. is the only country of origin from which any significant quantities of cereal grains are imported by CNMA member firms. Of these imports, wheat classes account for the majority of import volume. In 2012, the combined quantity of wheat imported by CNMA member firms from the U.S. was approximately 39,200 tonnes. This represented a total of approximately 740 import shipments, of which approximately 180 were rail car shipments and the remainder, approximately 560 truckload shipments. There were no imports by CNMA member companies of any of rye, oats or triticale to the best of our knowledge. The combined volume of imports of corn, sunflowers, pulses to processing facilities operated by CNMA member companies was approximately 135,000 tonnes. Of this volume, the estimated percentage via rail car shipments was in excess of 95%. No CNMA member company reported that mill operations or import patterns are likely to change significantly in 2013. However, some respondents indicated the possibility of increased import volumes of wheat in coming years as a consequence of changes in production and marketing systems in Canada. Current wheat imports are being made to meet specific product end use attributes that account for a small portion of total wheat milling finished product shipments. No CNMA member company expected other significant changes in operations at their milling facilities. No CNMA member company imported grains and other crops of U.S. origin for the purpose of resale in unprocessed form. All import shipments were intended for primary and further processing.

Summary of Survey of Commercial Feed Operations as Provided by the Animal Nutrition Association of Canada

As Canada has no feed mill licensing or registration system, the exact number of feed manufacturing facilities is unknown. It is estimated, however, that there are fewer than 500 commercial mills. By contrast, there are estimated to be over 25,000 on-farm mixing or manufacturing facilities. Commercial manufacturing accounts for approximately 20 million tonnes of complete feed per year, while 10 million tonnes are produced on-farm.

The principal crop imported as a whole grain from the U.S. to Canadian feed mills is corn. The processing and handling of corn in feed manufacturing is highly variable. Based on the survey respondents, volumes ranged from a couple of hundred metric tonnes to over 200,000 metric tonnes per facility per year. For some

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facilities, this represented as many as 1,500 truckloads annually while some facilities used rail transport exclusively, and imported more than 400 railcars. Corn imports varied depending on the domestic market, availability, and crop year. For some facilities, corn usage volumes per year can vary five to ten-fold. For example, one mill imported about 4,000 tonnes one year and more than 40,000 tonnes the following year. Some mills also purchase screenings, wheat, and other grains from the United States, but in significantly smaller volumes (a few hundred to a couple of thousand tonnes per year).

In some cases, the country of origin of grains and oilseeds may not be known, and grains of domestic and U.S. origin will be already co-mingled when received. Furthermore, feed mills have limited storage ability to segregate grains and oilseeds based on origin. Storage capability and inventory levels of grains and oilseeds at commercial feed mills are generally low, usually less than a week. A large number of commercial feed operations purchase grains and oilseeds from the United States through a broker (for some, this is in addition to purchasing directly from the point of sale in the United States). Screenings are mostly purchased through brokers and sometimes undergo a pelleting or hammer mill process prior to import.

Much of the grain purchased is used by the feed mill; however, some mills will resell corn to feedlots or to other industries for further processing (e.g. ethanol refineries, other feed mills). For some feed mills, this represents only 1-2% of the imported corn while for others; this totaled more than 100,000 metric tonnes annually. As the grain from all origins will typically be co-mingled at the feed mill, distinguishing the amount of imported grains re-sold is often impossible. The majority of feed mills use grains as received or have a scalper, which removes large non-grain debris. Few mills have the ability to clean grain or segregate into multiple components and sizes. Any screenings generated are usually further processed into finished feed, but may also go to compost or landfill.

There are a number of diverse product streams in a feed mill. No two feed mills are identical and many of them will serve multiple species and produce a variety of different textured feeds based on customer requirements. Some processes may present a lower risk for pests and weeds while others may result in minimal changes to the grains. Processes may include steam addition (generally in preparation for rolled/flaked grains, ranging from 70-95 degrees Celsius), particle size reduction (via a hammer mill or roller mill, resulting in a range of particle sizes), pelleting, or extrusion (less common). Pelleting usually involves conditioning temperatures ranging from 70-85 degrees Celsius with ingredients generally entering the pellet mill at less than 800 microns. The processes described can be used alone or in combination, depending on customer requirements. Most feed mills have at least one pellet mill; however, not all finished products will be pelleted and sometimes pellets will be mixed with larger particles or minimally-processed grains to create a finished product with different textures.

Summary of Survey of Malt Processing and Handling as provided by the Malting Industry Association of Canada

Malting Industry Association of Canada The Canadian Malting Industry is comprised of 4 companies with a total of 6 plants located across Canada. The locations include: Calgary, (Alta.), Alix, (Alta.), Biggar, (Sask.), Winnipeg, (Man.), Thunder Bay, (Ont.) and Montreal, (Que.) The industry purchases approximately 1 million tonnes of malting barley annually (99.99% from Canadian farmers) to be processed (via water and heat/germination) into malt for breweries around the world. Approximately 2/3's of all malt manufactured is for export markets.

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In terms of imports of malting barley from the U.S, the amount imported has been declining steadily and very little was imported in 2012. The trend for imports from the U.S is expected to decline over the course of the next 12 months and beyond. Only 2 companies (2 facilities) have historically imported U.S malting barley. Both facilities have received their shipments via rail cars. One facility acquires about 4,000 tonnes per year consisting of 3 to 4 rail cars @ 10 shipments per year. Entry points are via Vermont/New York. These tonnage amounts are expected to be similar to lower over the course of the next 3 years. A second Canadian facility that imports purchases less U.S. barley, and expects to import very limited quantities in the future, and possibly none in the next 3 years. Imports in the past to this facility have been via rail over North Dakota, Minnesota and Montana entry points. All malting barley that has been imported in the past was not cleaned prior to importation. The barley is cleaned at the malt plant facilities and is "steam treated" or "pelletized" if destined for the feed manufacturing markets. Some screenings (very limited) is NOT steam pellitized if destined for local/nearby livestock feed operations. No screenings are added back into the "final" malt product for shipment to brewers. No changes are expected in the handling or processing of malt (made from U.S malting barley) over the next 3 years. In fact, expected imported tonnages will decline significantly from those reported several years ago.

Summary of survey results on the future outlook for trade volumes

Future Outlook for Trade Volumes: As part of the survey, industry commenters were asked their view

of the trends and expectations for trade. Not all participants completed that portion of the survey.

The following specific comments were made, with attribution to the commodity if it was specified

(comments in italics):

No change expected in import volumes (soybeans) Constant pattern in soybean volumes expected Fairly flat to somewhat lower (peas, soybeans, canola, corn) Expect an increase in imports from current levels (canola) Imports are expected to increase from 2012 levels (corn) Imports are expected to decrease from 2012 (corn) Imports similar to what we have been doing (packaging operation, barley, beans, corn) Expect an increase in import volumes (rice) Importer of small quantities of wide range of grains: expects imports to be steady

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Other unsolicited comments made by respondents (italics):

General Comments of Canadian Importing Firms

1. A) We don’t anticipate significant change in trading volumes between U.S. and Canada unless the CFIA Policy/Directive or USDA/FGIS Policy/Directives are altered to impose additional or alternate requirements for Canadian importers/exporters of grains and oilseeds. B) CFIA Import Directives should be considerate of the system capacity available for issuing/overseeing phytosanitary documentation/permits/compliance agreements AND the impact these requirements may have on USDA/FGIS Import Policy (potential for non-tariff trade barrier). C) CFIA and USDA Import Directives should each be considerate of regional similarities, when much of the grains and oilseeds crossing the Canadian and U.S. borders are produced on lands directly adjacent to each other (within close proximity to the borders, crops are subject to the same/similar environmental conditions, including diseases, pests, etc.)—where practical, Canada and the U.S. should consider issuing phytosanitary exemptions/allowances for Canadian/U.S. crops grown in like geographical regions/areas.

2. Potential new phyto requirements will pose some new challenges to industry: a) some grain bought through brokers that crosses the border by truck moves so quickly, obtaining a phyto would be difficult; b) some trucks cross at “automated” crossings, but often the more efficient crossing points (the most direct transport routes) are not automated. Using these crossing points with new phyto requirements will cost additional transport money and human resource time, in addition to the cost of the phyto; 3) from a practical standpoint, if loads are rejected because they do not meet maximum toxin requirements at the importers unload point (aflatoxin, vomitoxin) what happens to the load?

3. We anticipate import volume changes on the basis of D-12-05 Phytosanitary Requirements and CFIA

Inspection Modernization.

4. There is some concern about corn trains going into western Canada locations, where commonly trains are broken up for delivery to facilities. How would new regulations affect this trade?

Apparent Trends U.S.-Canada Commodity Trade

Figure 8 looks at total commodity trade volumes for the last three years, U.S.-Canada, and compares that to 2007 levels of trade and to the 2012 Canada exports to the U.S. The 2007 data provides a check on more intermediate term trends in volumes moving across the border from the U.S. While 2012 was an anomaly because of the drought that affected the U.S. corn crop, actually 2012 followed a declining trend in commodity trade in general, seemingly driven mostly by corn. This trend has been driven by a trend of declining livestock numbers in Canada, and higher corn prices and expanded utilization of U.S. corn for ethanol. If these trends change in (U.S.) ethanol and (Canadian) livestock, net trade in corn will also likely change. Of all the crops U.S. exports to Canada, wheat trade from the U.S. to Canada seems to be growing gradually, but following the changes in Canada programs that permit more marketing freedom, this trend in wheat imports and exports from Canada to U.S. seems much more fluid and somewhat less predictable. The most stable trade seems to be occurring in rice, soybeans, peanuts and screenings. Several of the other smaller volume crops seem to be declining in volumes gradually over time. And for the most part, these are crops like barley, oats and sorghum which are unlikely to regain significance in the U.S. market. (There is one possible exception to this with sorghum as the U.S. Environmental Protection Agency recently determined that

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advanced biofuel can be manufactured from sorghum. This could boost this crop’s importance, but the impact of that is probably at least 2-3 years into the future, and is not certain to occur.)

Figure 8

U.S. Exports to Canada of Selected Agricultural Commodities, 2007-2012, and Comparisons to 2012 Canada-to-U.S. Exports

U.S. to Canada Exports, 1,000 Metric Tonne Units

Canada-to-U.S. Exports

2007 2010 2011 2012 2012 Pulses 73 107 102 101 167 Wheat 25 46 65 97 2,245 Rye 0.5 0.3 0.1 0.3 150 Barley 52 27 49 5 512 Oats 18 21 20 7 1,521 Corn 2,546 1,571 975 625 699 Rice 235 226 226 225 0 Sorghum 4 4 3 3 0 Buckwheat 8 11 16 15 28 Soybeans 226 231 264 242 363 Peanuts 72 66 74 71 0 Flaxseed 1 6 7 10 18x6 Canola 267 198 130 137 419 Sunflower 13 24 32 32 28 Other Oilseed 21 18 18 24 67 Screenings 415 381 356 404 166 TOTAL 3,977 2,937 2,337 1,998 6,551

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V. CONCLUSION

Imports of several commodities from the U.S. into Canada appear to be declining in total volumes. Canada’s livestock numbers declined from 2010 to 2012 and U.S. corn use for ethanol has increased sharply since 2008. If ethanol production in the U.S. begins to level off (as some predict) and Canada livestock numbers recover, growth in U.S. corn exports to Canada would not be surprising as the U.S. remains a large surplus producer of corn. Corn trade between the countries, though is more likely to be driven by Canada’s need for feed grains rather than the relative size of the corn surplus in the U.S.

Most commercial Canadian industry sectors have processes in place, or that could be activated, that would be expected to deactivate weed seeds. However, pelleting as an option is quite expensive unless the volume of material that needs to be managed is very large for a particular plant. It is doubtful that on-farm feeders have adequate equipment to mitigate the biosecurity (invasive species) risk intended to be addressed through the proposed CFIA directive D12-05.

Animal feeding operations are the most diverse processing industry in Canada, causing complexity in addressing risk mitigation. The diversity of commercial feed mills and the existence of significant volumes fed in on-farm feeding and mixing operations (with no regulatory control over any feed mixing/handling or disposal process for any material) would seem to greatly complicate regulatory considerations affecting the industry.

Based on research conducted for this study, it would appear that much of the U.S.- Canada trade is local trade between local market participants that just happen to be on different sides of a national border.

This study found that up to 40,000 shipments could be subject to proposed directive D-12-05, including those for commodities falling within HS Code 23.02. However, proposed implementation of D-12-05 is to include use of renewable standing import permits for some importers and end users where processing steps and by-product sale/disposal are considered to mitigate the risk of invasive species by rendering such species incapable of germination, growth and reproduction. Only in cases were importers and end-users do not qualify for import permits, will phytosanitary certificates be required.

Based upon industry input, this flexibility for compliance is important because not only would the additional paperwork place additional burden on governments to provide inspection service and add direct manpower costs to businesses, but other trading costs would be adversely affected. Trading through brokers near the border would become more complicated for quick shipments, and transport costs could be increased by required transport specified border crossing points.

This study focused on solely the known commercial transactions and it identified that there are a large number of transactions compared to the overall trade volume (unit sizes can be small). This suggests that the institution of any new requirements perceived to be necessary should be carefully considered for expected benefits and any unintended adverse effects on trade, because of the impact on transaction costs and logistics.

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Appendix A:

The following CFIA Analysis provides for regulatory definitions that were not made available to the author, therefore the

study does not have data comparable to that presented in this Appendix. As noted on pages 2-3 of the study, the 10-digit

HS codes were not analyzed in the original study because the level of regulatory distinction within HS 23.02 was not

clarified and made known to the study author.

CFIA Analysis of Historical U.S-origin Import Volumes of Products of Grain Products Falling

Within HS Code 23.02 and Applicability of New Requirements Under Directive D-12-05.

The trade data used to generate this report was not obtained from Canada Border Services Agency (CBSA) but from

Datamyne using commodity codes applicable to U.S. exports and not necessarily Canadian imports. While the CFIA does

not dispute that 400,000 MT of material is being imported under HS 23.02, or that this figure may represent

approximately 10,000 transactions per year there are currently only 8 codes out of 49 in chapter 23 that identify grain

screenings in CFIA’s Automated Import Reference System (AIRS). The rest of the codes under chapter 23.02 identify

highly processed grain commodities that are exempt for CFIA plant health requirements currently and are not subject to

new requirements under D-12-05. The following codes for grain screenings currently , as of June 20, 2013, require an

import permit to be released into Canada and no change is planned to alter these import requirements:

Table A-1

23.02.40.6216 Cereal grain screenings grade 1

23.02.40.6217 Cereal grain screenings grade 2

23.02.40.6218 Cereal grain screenings refuse

23.02.40.6219 Cereals grain screenings uncleaned

23.02.40.6223 Pulse grain screenings grade 1

23.02.40.6224 Pulse grain screenings grade 2

23.02.40.6225 Pulse grain screenings refuse

23.02.40.6226 Pulse grain screenings uncleaned

According to CBSA documentation, the volume of grain screenings defined in the 8 Canadian codes listed above

imported to Canada from the U.S. in recent years has been:

Table A-2

Year Number of importations Volume of screenings imported

2010 0 0

2011 7 128MT

2012 37 737MT

The CFIA, in proposing new requirements for grain commodities listed in the draft of D-12-05 circulated for public

comment in September 2012 sought to align the regulation of imports with the Harmonized System (HS) customs tariff

classification system. All grain imports to Canada must be identified using the appropriate HS code to facilitate the

review of the import by the Canada Border Services Agency (CBSA) and the CFIA. These codes also form the backbone of

CFIA’s Automated Import Reference System (AIRS) that imports to Canada are reviewed against to verify they meet all

Canadian import requirements.

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The purpose of AIRS is to provide accurate and timely information on import requirements. The application uses a

question and answer approach to guide the user through a series of questions about the HS Codes, origin, destination,

end use and miscellaneous qualifiers of the product they wish to import.

The basic six digit code that makes up the HS is composed of three parts. The first two digits specify the chapter the

goods are classified in. For example:

23 - Residues and waste from the food industries; prepared animal fodder.

The next two digits identify sub groupings under that chapter:

23.02 - Bran, sharps and other residues, whether or not in the form of pellets, derived from the sifting, milling or other

working of cereals or of leguminous plants.

The next two digits get more specific:

23.02.40 – Of other cereals

All member countries of the World Customs Organization use the same six digit code to identify commodities for import

and export purposes, but individual countries are allowed to use additional digits to get more specific as needed for

statistical and regulatory purposes. However, the code for a product in Canada may be quite different from the code for

the same product in the U.S. For example:

23.02.40.6227 - Rice bran with germs (Canada)

23.02.40.01.05 – of rice (U.S.)

Table A-3 Current and Proposed Phytosanitary Requirements for Chapter 23 Residues and waste from the food industries; Prepared animal fodder

Code Description

Phytosanitary Requirements

Current Proposed 23 Residues and waste from the food

industries; Prepared animal fodder

23.02 Bran, sharps and other residues, whether or not in the form of pellets, derived from the sifting, milling or other working of cereals or of leguminous plants

23.02.10 Of maize (corn)

23.02.10.6100 Maize ears ground Approved; No plant health requirements

Approved; No plant health requirements

23.02.10.6101 Maize grits by-product Approved; No plant health requirements

Approved; No plant health requirements

23.02.10.6102 Maize grain fines Approved; No plant health requirements

Approved; No plant health requirements

23.02.10.6103 Maize cobs, dehydrated, fine ground Approved; No plant health requirements

Approved; No plant health requirements

23.02.10.6104 Maize, cob fractions, screened Approved; No plant health requirements

Approved; No plant health requirements

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23.02.10.7100 Corn bran Approved; No plant health requirements

Approved; No plant health requirements

23.02.30 Of wheat

23.02.30.6111 Wheat flour less than 1.5% fibre Approved; No plant health requirements

Approved; No plant health requirements

23.02.30.6112 wheat flour by-product less than 7% fibre

Approved; No plant health requirements

Approved; No plant health requirements

23.02.30.6113 Wheat flour by-product less than 9.5% fibre

Approved; No plant health requirements

Approved; No plant health requirements

23.02.30.6114 Wheat mill run less than 9.5% crude fibre

Approved; No plant health requirements

Approved; No plant health requirements

23.02.30.7100 Wheat bran Approved; No plant health requirements

Approved; No plant health requirements

23.02.40 Of other cereals

23.02.40.6200 Barley malt flour dehydrated Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.6210 Other cereals Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.6211 Barley mill run Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.6212 Barley pearl by-product Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.6213 Buckwheat middlings Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.6214 Cellulose powdered Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.6215 Cereals breakfast process residue Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.6216 Cereal grain screenings grade 1 Prohibited from all countries except U.S; requires import permit and compliance agreement with CFIA

Prohibited from all countries except U.S; requires import permit and compliance agreement with CFIA

23.02.40.6217 Cereal grain screenings grade 2 Prohibited from all countries except U.S; requires import permit and compliance agreement with CFIA

Prohibited from all countries except U.S; requires import permit and compliance agreement with CFIA

23.02.40.6218 Cereal grain screenings refuse Prohibited from all countries except U.S; requires import permit and compliance agreement with CFIA

Prohibited from all countries except U.S; requires import permit and compliance agreement with CFIA

23.02.40.6219 Cereals grain screenings uncleaned Prohibited from all countries except U.S; requires import permit and compliance agreement with CFIA

Prohibited from all countries except U.S; requires import permit and compliance agreement with CFIA

23.02.40.6220 Feeding oat meal Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.6221 Oat groats by-product less than 22% fibre

Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.6222 Oat hulls Approved; No plant health requirements

Approved; No plant health requirements

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23.02.40.6223 Pulse grain screenings grade 1 Prohibited from all countries except U.S; requires import permit and compliance agreement with CFIA

Prohibited from all countries except U.S; requires import permit and compliance agreement with CFIA

23.02.40.6224 Pulse grain screenings grade 2 Prohibited from all countries except U.S; requires import permit and compliance agreement with CFIA

Prohibited from all countries except U.S; requires import permit and compliance agreement with CFIA

23.02.40.6225 Pulse grain screenings refuse Prohibited from all countries except U.S; requires import permit and compliance agreement with CFIA

Prohibited from all countries except U.S; requires import permit and compliance agreement with CFIA

23.02.40.6226 Pulse grain screenings uncleaned Prohibited from all countries except U.S; requires import permit and compliance agreement with CFIA

Prohibited from all countries except U.S; requires import permit and compliance agreement with CFIA

23.02.40.6227 Rice bran with germs Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.6228 Rice bran with germs, meal, solvent extracted

Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.6229 Rice hulls Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.6230 Soybean feed, solvent extracted Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.6231 Soybean flour by-product Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.6232 Soybean seed coats Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.6234 Rye flour by-product less than 8.5% fibre

Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.6235 Rice bran, stabilized Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.7100 Other cereal for human consumption Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.7100.01 Of rice Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.7100.02 Of oats Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.7100.03 Of barley Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.7100.04 Of rye Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.7100.05 Of sorghum Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.7100.06 Of buckwheat Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.7100.07 Of quinoa Approved; No plant health requirements

Approved; No plant health requirements

23.02.40.7100.99 Of other cereals Approved; No plant health requirements

Approved; No plant health requirements

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23.02.50 Of leguminous plants

23.02.50.6240 Pea, field, protein product, spray dehydrated

Approved; No plant health requirements

Approved; No plant health requirements

23.02.50.6241 Pea meal Approved; No plant health requirements

Approved; No plant health requirements

23.02.50.6242 Pulse seeds, pelleted pulse seeds Approved; No plant health requirements

Approved; No plant health requirements

23.02.50.7199 Of leguminous plants, other Approved; No plant health requirements

Approved; No plant health requirements