As Canada pivots away from the United States and the rules of the game change, we need a serious rethink on pesticide regulation.
Right now, decision-making on pesticides is structurally integrated with that of the United States, creating problems for Canada’s trade agenda, the health of Canadians and even the Government itself. We need a new playbook.
Case in point is the approval of three new PFAS, or “forever chemicals.” Since late 2025, the U.S. EPA has approved cyclobutrifluram, isocycloseram and epyrifenacil, and Health Canada’s Pesticides Regulatory Directorate (the successor to the PMRA) has followed closely behind on all three:
|
Pesticide |
🇺🇸 EPA final approval |
🇨🇦 Pesticide Regulatory Directorate registration |
|---|---|---|
| Cyclobutrifluram | US: Nov. 5, 2025 | CDA: RD2025-12, Dec. 19, 2025 – six weeks later |
| Isocycloseram | US: Nov. 20, 2025—one action, all uses together | CDA: RD2026-03, Jan. 28, 2026 – 12 weeks later (cockroach bait + cereal seed treatment) and
CDA: R D2026-13, May 21, 2026 (foliar/soil uses on corn, leafy vegetables, Brassica, tomatoes, prunes) |
| Epyrifenacil | US: June 30, 2026 | CDA: Proposed Aug. 21, 2026— still accepting comments, not yet final |
Structural Integration
This is not a coincidence. It’s policy, and it goes back to the time of free trade. The Directorate and the EPA currently operate under a formal “Regulatory Partnership Statement,” a product of the Canada–U.S. Regulatory Cooperation Council (RCC), launched in February 2011 by Stephen Harper and Barack Obama. The RCC followed a NAFTA-era Working Group on Pesticides that first met in 1996.
The goals of the Working Group were to help the regulators – co-ordinating approval processes and eliminating differences in residue levels— and help pesticide companies – through common data submissions and, in the words of Health Canada’s own international regulatory cooperation page, “providing concurrent access to products” across Canada, the United States and Mexico.
This structural integration was the old playbook, and it was engineered three decades ago so that North America would be the first point of global access for manufacturers to sell their pesticides.
Disconnect between Regulations and Reality
The old playbook assumes frictionless, predictable, reciprocal trade between the United States and Canada. That premise no longer holds. The rules of the game have changed.
Canada is diversifying away from the United States and toward Asia and Europe. That creates a disconnect between the regulatory input, still integrated with the United States—and the crop’s actual destination, increasingly somewhere else. The longer the Directorate stays tied to the EPA, the wider that gap gets. The regulations are not tracking the reality.
Trade Concerns
The disconnect is likely to hurt Canada on the trade front. The European Union has been working to close a double standard: pesticides that EU farmers are not allowed to use are permitted to legally enter the EU on imported food grown elsewhere. A European Commission report dated August 11, 2026, indicated that under the most severe scenario, Canada was one of 14 countries with more than $1.4 billion in exports at risk, with lentils among the most exposed.
The continuing approvals of PFAS pesticides compound the risk. A breakdown product of many is trifluoroacetic acid (TFA), a “forever chemical” that for practical purposes doesn’t degrade — it only moves. Once in soil, it’s taken up by plant roots — a 2020 review found TFA turns up in plants wherever it’s been studied — and into groundwater, where it persists for decades. Deregistration won’t undo that exposure; it’s already in the ground, and with every application even more accumulates. Regulatory pressure to set legal limits on TFA is building: the EU’s Scientific Committee on Health, Environmental and Emerging Risks has recommended folding TFA into the bloc’s groundwater standards — turning today’s approvals into tomorrow’s trade liability.
The risk of recall and rejection arises because of this disconnect between regulations and trade reality. In 2018, Canada’s PMRA proposed raising the diquat residue limit on dried peas and beans from 0.2 ppm to 0.92 ppm — matching the U.S. rather than the EU. By 2021, harmonization with the U.S. was complete, with the U.S. establishing a matching import tolerance. The EU’s limit never moved — it stayed at 0.2 ppm, the number Canada abandoned. That gap surfaced directly in the 2025 recall of Canadian lentil products in France over diquat residue.
Canada’s export industry runs a dedicated compliance program, Keep It Clean, recognizing that “although a pesticide may be registered in Canada on a certain crop type, there can be market access issues” in export markets. Canada exports more than 90% of the canola it produces, and “shipments containing even the smallest amount of unacceptable pesticide residue can be rejected, causing millions of dollars in losses.”
What’s changing is the scale, not the existence, of that risk exposure. Importing nations are “losing confidence in our science-based approach”—meaning they are not trusting Canada’s approvals—according to Cereals Canada‘s director of crop protection. Every new pesticide the Directorate approves on the strength of a matching American number, with no confirmation that others have accepted it, adds another item to the risk list.
Concerns for Canadians
A result of this integration is Canada has become one of the more permissive pesticide regulators among wealthy nations—banning far fewer active pesticide ingredients than the EU, the global average, or even Brazil. Canada has inherited the regulatory posture of the United States, one of the world’s most permissive major regulators, while never catching up on the backlog everyone else has already dealt with.
The numbers are significant. The EU has banned or refused approval for 383 active pesticide ingredients. Of those same 383, Canada restricts only 28—a 2023 Université du Québec à Montréal analysis found 355 substances the EU has rejected remain legal here.
Globally, 531 active ingredients are banned across 168 countries; Canada has banned 32. Even Brazil, whose MRLs can run up to 400 times higher than the EU’s for the same pesticide-crop combination, has banned 131 active ingredients—roughly four times more than Canada. That number matters because it’s Canadians who are exposed to these substances that other jurisdictions consider harmful enough to ban.
Problems for the Government
Structural integration with the EPA isn’t just pulling against Canada’s trade strategy. It’s pulling against commitments made by other parts of Government.
In December 2022, Canada hosted COP15 in Montreal, where the Kunming-Montreal Global Biodiversity Framework committed its parties, Canada included, to reducing “the overall risk from pesticides and highly hazardous chemicals by at least half” by 2030. Agriculture and Agri-Food Canada’s own briefing materials confirm the commitment stands. Yet as one public comment on Canada’s 2030 Nature Strategy consultation put it: “Canada committed to 50% reduction of pesticides risks by 2030, but registrations of hazardous pesticides are going up.”
The same conflict runs through PFAS pesticides. In March 2025, Health Canada and Environment and Climate Change Canada published the State of PFAs Report and jointly concluded the entire class of “forever chemicals” meets the legal criteria for a toxic substance, and committed to phasing them out. Months later, the Directorate approved cyclobutrifluram and isocycloseram—both confirmed to break down into TFA – and in August, 2026 proposed to register epyrifenacil (the consultation is open until September 20, 2026) – which also breaksdown into TFA.
Safe Food Matters Inc., with Friends of the Earth Canada and Prevent Cancer Now, has filed three Federal Court challenges against the finalized approvals, and litigation has also been filed in the U.S. 9th Circuit:
|
Pesticide |
🇨🇦 Canada litigation (SFM, FOE, PCN) |
🇺🇸 U.S. litigation |
|---|---|---|
| Cyclobutrifluram | T-221-26, filed Jan. 19, 2026 | 9th Circuit, filed ~Dec. 30, 2025 |
| Isocycloseram | Two applications: T-980-26, filed Feb. 27, 2026, and T-2926-26, filed June 22, 2026 | 9th Cir. No. 26-298, filed Jan. 15, 2026 |
| Epyrifenacil | None—nothing final to challenge yet | Not confirmed |
One of the Canadian groups’ arguments is the Directorate didn’t properly deal with TFA or the State of PFAS Report.
More Work for the Directorate
Every new PFAS pesticide the Directorate approves with the EPA likely increases the Directorate’s workload for tomorrow. In 2025–26, Denmark withdrew approval for 23 pesticide products — later followed by more — after finding six active ingredients break down into TFA: fluazinam, fluopyram, diflufenican, mefentrifluconazole, tau-fluvalinate and flonicamid. All six are registered in Canada and the U.S., and between them they cover soybeans, potatoes, corn, tree fruit, tree nuts and cereals — nearly every major category in Canada’s export basket. Because of Denmark’s prohibition, the Directorate is obligated to initiate a special review of these pesticides under s.17(2) of the PCPA, meaning more work for the Directorate. On top of that, more withdrawals are likely coming – Denmark has signalled further bans, and other EU states are on track to follow: the Netherlands, for instance, is modelling groundwater risk on 46 PFAS pesticides.
Rethink and Reclaim the Process
The solution to the problem of structural integration with the EPA is not to abandon trade or turn inward. The Build Canada Strong plan is to diversify and spread the risk across more trading partners, rather than betting everything on a single relationship with the United States who is becoming increasingly undependable and hostile.
The fix isn’t complicated, and it doesn’t ask the Directorate to do anything outrageous: stop defaulting to America, conduct a truly independent Canadian assessment and pay attention to where all of Canada’s markets—not just the old one—are actually heading.
This should be the new pesticide playbook. Because for so long as Canada’s pesticide policies remain calibrated to the US rather than to Canada’s own independent scientific assessment and trading realities, the strategy of building at home and diversifying trade abroad will leave Canada vulnerable.
