Regulations Amending the Pest Control Products Fees and Charges Regulations (Annual Charge)

The Canadian Association of Physicians for the Environment (CAPE) submitted comments on March 6, 2025, regarding proposed amendments to the Pest Control Products Fees and Charges Regulations (Annual Charge). While supporting the Pest Management Regulatory Agency's (PMRA) need for more resources, CAPE argues the proposed fee increases are inadequate and fail to achieve full cost recovery or align with the polluter-pays principle.

• CAPE supports the PMRA's efforts to update cost recovery because the agency requires more financial and operational resources to manage pesticide risk assessments and registrations, noting that current assessments are years behind schedule.
• The proposed fee increases are considered insufficient because they do not represent full cost recovery. CAPE argues that fees should be increased to fully cover costs in accordance with the polluter-pays principle and the objectives of the Pest Control Products Act to prevent unacceptable risks to the environment and individuals.
• CAPE recommends a 'fair fee' structure that incorporates social costs, including impacts on human health, healthcare, justice, and the environment, rather than focusing only on commercial benefits. They suggest Canada consider research from other jurisdictions regarding the costs of pesticides to occupational sectors and the environment.
• The organization advocates for several structural changes to the fee system: moving away from a sales-based structure, removing discounts for registrants with higher volumes of registrations, and eliminating 'niche' product exemptions, particularly for agricultural products.
• CAPE proposes that the regulations should take effect in 2025 instead of 2026 and be established as a full cost-recovery program extending through 2040. This is justified by the fact that the PMRA has not increased fees since 2011 and currently recovers only 18% of post-market costs.

APA

Canadian Association of Physicians for the Environment (2025). Regulations Amending the Pest Control Products Fees and Charges Regulations (Annual Charge). https://cape.ca/wp-content/uploads/2025/03/CAPE-Submission-PMRA-Consultation-Fees-and-Charges-March-6-2025.pdf#new_tab

Chicago

Canadian Association of Physicians for the Environment. Regulations Amending the Pest Control Products Fees and Charges Regulations (Annual Charge). 2025. https://cape.ca/wp-content/uploads/2025/03/CAPE-Submission-PMRA-Consultation-Fees-and-Charges-March-6-2025.pdf#new_tab.

Wikipedia

{{cite press release |author=Canadian Association of Physicians for the Environment |title=Regulations Amending the Pest Control Products Fees and Charges Regulations (Annual Charge) |date=6 March 2025 |url=https://cape.ca/wp-content/uploads/2025/03/CAPE-Submission-PMRA-Consultation-Fees-and-Charges-March-6-2025.pdf#new_tab |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{canadianassociationofphysiciansfortheenvironment2025regulations, author = {{Canadian Association of Physicians for the Environment}}, title = {{Regulations Amending the Pest Control Products Fees and Charges Regulations (Annual Charge)}}, publisher = {Canadian Association of Physicians for the Environment}, year = {2025}, month = mar, url = {https://cape.ca/wp-content/uploads/2025/03/CAPE-Submission-PMRA-Consultation-Fees-and-Charges-March-6-2025.pdf#new_tab}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }