Proposed amendments would end mandatory post-market re-evaluation of pesticide health and environmental risks
Canada’s pesticide regulatory system is facing a major change that could leave older pesticide decisions in place even as scientific evidence evolves. Amendments to Canada’s Pest Control Products Act (PCPA) buried in the government’s second budget bill, Bill C-31, Division 13, would remove the mandatory requirement for the cyclical re-evaluation of registered pesticides.
Re-evaluations are the primary mechanism for comprehensive, post-market review of pesticide risks. Removing that requirement would fundamentally weaken federal oversight of pesticides and the PCPA’s purpose of preventing unacceptable risks to human health and the environment.
The David Suzuki Foundation, along with health and environmental organizations including Safe Food Matters, has issued a September 2026 briefing note titled “Silent Spring” Provisions in Bill C-31 Gut Federal Pesticide Protections, calling on parliamentarians to reject the amendments.
Why mandatory pesticide re-evaluations matter
The requirement for the Health Minister to initiate a re-evaluation of every registered pesticide on a 15-year cycle was introduced when the PCPA was overhauled in 2002. Before that, post-market re-evaluation was discretionary, contributing to a backlog of older chemicals approved using outdated risk assessments. Scientific knowledge and methods evolve, patterns of pesticide use change, and long-term or cumulative harms may only become apparent over time. Mandatory cyclical re-evaluations were established to ensure that the health and environmental risks of registered pesticides continue to be assessed against up-to-date scientific evidence and methods.
Re-evaluations also provide important transparency and accountability mechanisms. During a re-evaluation, the Minister of Health can request updated scientific information from pesticide registrants and government departments and agencies. The PCPA provides for public consultation, and Health Canada is required to publish its re-evaluation decisions and the reasons for them. Decisions can also be challenged through a Notice of Objection procedure. Re-evaluations can identify changes in a pesticide’s risk profile or risks that were not previously recognized, leading to restrictions when necessary to protect human health or the environment.
A regulatory system must be able to change with the science
For Safe Food Matters, this is a fundamental issue of regulatory accountability.
Mary Lou McDonald, president of Safe Food Matters Inc., said:
“Re-evaluations are the only institutional check to ensure the regulator is behaving, and that the science still holds years later. Why? Because regulators are prone to capture, and science by its nature evolves. We can’t remove institutional mechanisms for accountability just because things are taking too long. The answer is to fix the process, not remove protections.”
The purpose of a re-evaluation is not simply to repeat an old assessment. It is to determine whether a pesticide remains acceptable in light of what is now known. Removing the mandatory review requirement changes that fundamental safeguard.
What Bill C-31 would change
Under Bill C-31, mandatory re-evaluations would be replaced with a more limited “assessment” of “available information.” The proposed amendments do not establish requirements for what these new assessments must include, potentially circumventing the PCPA’s existing requirements for scientific standards, consultation, transparency and accountability.
A re-evaluation would only be required if the assessment indicates that the health or environmental risks of a registered pesticide have “increased significantly.” But “increased significantly” is not defined, and there is no timeline for initiating a re-evaluation if that threshold is met. The additional assessment step could therefore result in longer delays before a pesticide is comprehensively reviewed, potentially prolonging exposure to new or increased risks.
But “increased significantly” is not defined.
There is also no timeline for initiating a re-evaluation if that threshold is met.
The additional assessment step could therefore result in longer delays before a pesticide is comprehensively reviewed, potentially prolonging exposure to new or increased risks.
The science already has a system for ongoing oversight
The proposed changes are described as a move toward more risk-based oversight and greater efficiency following budget cuts at Health Canada. But Health Canada has already implemented new “continuous oversight” and “proportional effort” policies intended to improve regulatory efficiency while proactively monitoring new scientific information about registered pesticides.
Those policies were designed to complement—not replace—the existing mandatory cyclical re-evaluation system. Eliminating the mandatory review requirement before these newer policies have even been fully implemented could undermine their effectiveness.
Another rollback of pesticide protections
Bill C-31 follows Bill C-30, which amended the PCPA in June 2026. Bill C-30 granted Cabinet authority to issue emergency orders overriding the Minister of Health’s science-based risk assessment restricting the use of a pesticide known to cause environmental harm. It also requires the Minister of Health to consider undefined “national economic security, regional economic security or national food security” when making certain pesticide decisions.
The two sets of amendments together raise concerns about science-based decision-making, democratic process, and health and environmental protections.
Five concerns with Bill C-31
The “Silent Spring” briefing note identifies five major concerns with eliminating mandatory cyclical re-evaluations:
1. Health and environmental harms. Returning to discretionary re-evaluations with no fixed timeline could delay action on harmful chemicals.
2. A blank cheque. The proposed assessments have no prescribed criteria beyond consideration of “available information,” and there are no public participation provisions.
3. Risks could remain unidentified. New or increased risks that are not already documented in Health Canada’s compilation of “available information” could remain unknown or be ignored.
4. Market confidence. Cyclical re-evaluations are the backbone of Canada’s post-market pesticide regulatory system. Eliminating them could undermine public and market confidence in the system and potentially affect export opportunities for Canadian agricultural products.
5. A flawed process. There has been no formal consultation on the PCPA amendments in Bill C-31, while placing them inside an omnibus budget bill limits parliamentary study and debate.
Why “Silent Spring”?
The title of the briefing note invokes Rachel Carson’s landmark 1962 book Silent Spring, which documented the harmful impacts of pesticides on wildlife and helped galvanize modern environmental awareness. Carson’s work demonstrated the consequences of failing to identify and act on pesticide risks. The briefing note makes the same fundamental point for today’s regulatory system: when science evolves, pesticide decisions must be capable of evolving with it.
The default must not become inaction
A strong pesticide regulatory system cannot rely on old assessments indefinitely. Science changes. New evidence emerges. New risks can become apparent years after a pesticide is registered. That is precisely why mandatory post-market re-evaluation was established in the first place.
Maintaining regular science-based re-evaluations is critical so that pesticide risks are reassessed using up-to-date evidence and methods. Without cyclical re-evaluations, the default is inaction—putting Canadians at risk and undermining public and market confidence in Canada’s pesticide regulatory system.
TAKE ACTION
The “Silent Spring” briefing note calls on Parliament to:
- Reject the PCPA amendments in Bill C-31.
- Repeal the PCPA amendments passed through Bill C-30 in June 2026.
- Refer future PCPA amendments to Parliament’s health and environment committees and allow meaningful study and debate.
Canadians deserve a pesticide regulatory system that keeps pace with the science and maintains meaningful safeguards for human health and the environment.
SIGN AND SHARE PETITION E-7742 calling for the pesticide provisions in Bill C-31 to be removed and the PCPA amendments adopted through Bill C-30 to be reversed.
Read the full “Silent Spring” briefing note HERE:
