WHEREAS the ear tags on livestock are not permanent; and

We do appreciate you addressing this concern at your meeting and proposing a resolution to deal with this issue.  The CCIA approved tags are RFID button, external tags that are tamper-evident but not permanent at this time.  Also, it is the producer who is expected to pay for these tags under the mandatory requirements of the program.  As you state the tags, especially if not inserted in the correct location or with the correct applicator/pin, are subject to falling out at which point they must be replaced prior to the animal leaving the herd of origin. 

You have asked that CCIA consider an alternative permanent marking system and that the cost not be borne by the producer.  Please be advised that CCIA is continually welcoming new technology and types of tags from manufacturers to be submitted for testing.  All approved RFID tags must pass a minimum lab and field test standard which include criteria such as retention, readability, environmental, physical, electrical, and mechanical requirements.  We have in the past investigated more permanent forms of ID such as implants, tattoos and boluses but have revealed issues with all of them.  For example, with an implant there still may be a food safety issue, especially if it is inserted incorrectly. It may also migrate and appear unknowingly in the retail product.  As well, with implants you still would require an external tag to signify that there is an implant in the animal.  Boluses are used to a certain extent in some countries, however, they do create an issue again with the need for an external tag and are more costly than the regular RFID button tags.  There is also an issue with the retrieval of these boluses at the processing stage.  Tattooing, as done within the purebred industry, has been identified as an unacceptable option to the commercial cattle industry due to the time and effort required.  These tattoos would also not be externally visible and would be extremely difficult to read at speeds which would not affect commerce. 

With all of this said, there continues to be more research in this area and CCIA is monitoring this closely.  For example, there is now a permanent RFID tattoo ink that could be applied to an animal and may be read electronically.  However, at this time it is still in the research phase. 

In response to your concern regarding the cost to the producer we also recognize this concern, however, have no solution at this time.  At CCIA we do try to maintain competition within the tag market and due to volumes, keep the price as low as possible.  We most certainly acknowledge that the entire cost of the tag is borne by the producer and as other livestock sectors benefit from this program as well, some type of cost sharing and/or assistance should be considered.  However, it is important to recognize that the intermediary sectors and the packing plants have also significantly invested in this program to meet the technological requirements of reading the tags and transferring information.

We will present your resolution to our Board of Directors, which represents all sectors of the industry, and to the Canadian Food Inspection Agency and Agriculture and Agri-Food Canada as our ex-officio partners and provide you with the response received.