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

CAPE supports the PMRA's effort to update fees but argues the proposed increases are inadequate for full cost recovery. The organization advocates for a fee structure based on the polluter-pays principle that incorporates health, environmental, and social costs, while opposing 'niche' product exemptions and discounts for high-volume registrants.

• CAPE argues that the proposed fee increases are insufficient because they do not achieve full cost recovery, which is necessary to meet the Pest Control Products Act's goal of preventing "unacceptable risks to individuals and the environment from the use of pest control products."
• The document recommends that fee calculations incorporate the polluter-pays principle and account for environmental, health, and social costs, including intergenerational impacts of persistent pesticides.
• CAPE proposes shifting away from a sales-based fee structure and argues against tiered schedules that discount fees for registrants with a higher number of registrations, as this increases the PMRA's workload.
• The organization opposes exemptions for "niche" products, specifically stating that no agricultural products should be exempt and that niche status should not be granted to crops covering 1 million hectares.
• CAPE suggests that the updated regulations should take effect in 2025 rather than 2026 and be structured as a full cost-recovery program extending through 2040.

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} }