# REGULATORY PROPOSAL TO STANDARDIZE THE

GRADES AND NOMENCLATURE FOR PURE MAPLE

SYRUP IN THE NORTH AMERICAN AND WORLD

MARKETPLACE

Submitted to: ALL FEDERAL AND STATE/PROVINCIAL AGENCIES WITH MAPLE PRODUCT SALES

REGULATIONS IN CANADA AND THE UNITED ST ATES

By the:

INTERNATIONAL MAPLE SYRUP INSTITUTE

Date: September 2011



## Approved For Distribution

English Language Contact: Dave Chapeskie, R.P.F.,

Executive Director, I nternational Maple Syrup Institute, 5072 Rock St, RR#4, Spencerville, Ontario K0E 1X0 Telephone: 613

- 658

- 2329 Fax: 877

- 683

- 7241 E

- mail: agrofor@ripnet.com



### French Language Contact: Yvon Poitras, Directeur Général/General Manager,
Association Acéricole d u N.B./N.B. Maple Syrup Association Inc. 1350 Regent Street, Fredericton, New Brunswick E3C 2G6
Tel: 506

- 458

- 8889 Fax: 506

- 454

- 0652 E

- mail: yrp@nb.aibn.com1 

## TABLE OF CONTENTS

Page

I. BACKGROUND

................................ ................................ ................................ ................................ ........ 3

II. VALUE OF THE NORTH AMERICAN MAPLE SYRUP INDUSTRY

................................ .............................. 5

I II. SCOPE OF THE REGULATORY PROPOSAL

................................ ................................ ............................. 6 What is Proposed for Regulat ion ?

................................ ................................ ................................ ..... 6 Maple Regulations Requiring Change

................................ ................................ ................................ 6 Purpose o f Standard Grades a nd Nomenclature

................................ ................................ ............... 6 Target Product

................................ ................................ ................................ ................................ ... 6 Target Trade

................................ ................................ ................................ ................................ ....... 7 Target Audience

................................ ................................ ................................ ................................ . 7
Intended Beneficiaries

................................ ................................ ................................ ....................... 7

IV. PROPOSED INT ERNATIONAL GRADES AND QUALITY STANDARDS

................................ ....................... 8
Definition and Requirement s for Pure Maple Syrup

................................ ................................ ......... 8
Q u a l i t y D e s c r i p t o r s

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

G r a d e A M a p l e Sy r u p

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Processing Grade Maple Syrup

................................ ................................ ................................ ...... 9
Product Label ing Requirements

................................ ................................ ................................ ........ 9 Regulat ory Emphasis Required

................................ ................................ ................................ ........ 10

Overvie w of the Current Maple Regulations T hat W ould B e Affected

................................ ............ 1 1

V. RATIONALE FOR STANDARDIZED GRADES

................................ ................................ ........................... 11 Why is the Change Needed?

................................ ................................ ................................ ............ 11
Consumer Preferences

................................ ................................ ................................ .................... 11
What I s the Issue and Why I s I t Important?

................................ ................................ .................... 12

VI. ANALYSIS OF REGULATORY AND NON REGULATORY OPTIO NS

................................ ......................... 13 The Need for Regulation

................................ ................................ ................................ .................. 13

How w ill t he Regulatory Proposal Resolve the Issue?

................................ ................................ ..... 1 4 What are the Supporting References for the Proposed Changes?

................................ .................. 1 4 Involvement of Regulatory Officials

................................ ................................ ................................ 14
Self Monitoring and Education

................................ ................................ ................................ ........ 1 5 Grading of Maple Syrup and Third Party Verification /Audit

................................ ........................... 15 Operational T rial Markets

................................ ................................ ................................ ............... 16

VII. SUPPORT AND CONTROVERSY REGARDING THE STANDARDIZED GRADES PROPOSAL

................... 16
Public Interest and Maple Stakeholder Support

................................ ................................ ............. 16 Potential Controversy

................................ ................................ ................................ ...................... 162

VIII. IMPACTS OF THE CHANGE TO STANDA RDIZED GRADES

................................ ................................ . 1 7

O n the Consumers and Ingredient Users

................................ ................................ ........................ 1 7

O n Trade Partners/Economy

................................ ................................ ................................ ........... 1 8 Impact as a Trading Language for the Sector

................................ ................................ ............. 18 Impact on International Regulatory Cooperation will Reduce Technical Barriers to Trade and Improve Competitiveness

................................ ................................ ................................ ............ 1 8

Im pact on International Trade Agreement or Obligations

................................ ......................... 1 8 Impact for Interstate, Interprovincial a nd International Trade

................................ .................. 18 Impact on Small versus Large Maple Producer and Packer Operations

................................ ..... 1 9 Preventing Anyone from Accessing Their Current Markets for Maple Syrup

............................. 1 9 Stimulating Access to New Markets for Pure Maple Syrup

................................ ........................ 1 9

O n Governments

................................ ................................ ................................ ............................. 19 Reducing Administrative Burden and Duplication

................................ ................................ ...... 19 Alignment of the Standard Grades Proposal with Current Provincial/State Standards

............. 20 Enforcement of the New Maple Gradin g Standard

................................ ................................ .... 20 Impact on Federal Departments, Agencies , other Countries

................................ ...................... 20 Coordination of Implementation a mong State, Provincial and Federal Regulators

................... 20
Fit with Initiatives to Re

- Draft Maple Regulations

................................ ................................ ...... 20 Reasons for Governments to Place High Importanc e on these Regulatory Changes

................. 20

Cost s and Savings (Qualitative and/or Quantitative)

................................ ................................ ...... 2 1

IX. IMPLEMENTATION AND EVALUATION OF THE PROPOSAL

................................ ................................ 21

X. APPENDIX

................................ ................................ ................................ ................................ ............ 2 2

A: 2011 List o f I MSI Members a nd Maple Grades a nd Nomenclature Committee Members

........ 22

B : World Pr oduction of Pure Maple Syrup / Value o f t he North American Maple Syrup Industry

.. 23

C : Comparison of Proposed Standard Maple Grades and Nomenclature with Existing Maple
Grades and Nomenclature in Canada and t he United State s

................................ ......................... 2 5 D: Implementation Schedule

................................ ................................ ................................ .......... 2 63

I. BACKGROUND

The International Maple Syrup Institute (IMSI) is a voluntary organization

, represent ing maple syrup industry stakeholders. The membership of IMSI is comprised of groups and individuals, including maple packers

, various maple enterprises

, most maple producer organizations

, maple equipment
manufacturers and vendors

, and others in both Canada and the United State s

. A listing of the U

. S

. and
Canadian IMSI member s is included in Appendix A

. The organization

, which was founded by maple industry leaders in 1975

, works to maintain a thriving maple syrup industry in North America and internationally. This includes providing a communications forum for members

, facilitating sharing of
information and dealing with issues of importance to the internati onal maple syrup industry such as maple syrup industry standard s, product purity and marketing. For the purposes of this document, marketing is defined as the advertising, promotion, and display of products intended to assist the sales of pure maple syrup. The primary objectives of the Institute are to maintain the integrity of pure maple syrup and develop standards for the maple industry to ensure that soci et al

, economic and
environmental benefits to Canada and the United State s are both sustained in the s hort

- term and
enhanced in the medium and longer

- term.

In 2002

, a committee of the IMSI was established to review definitions

, grades and nomenclature in existing regulations for pure maple syrup in Canada and the United States. The present membership
of the IMSI Standard Maple Grades and Nomenclature Committee is included in Appendix A. Most of
the members listed have served in this role since 2002. T he committee mandate was to make recommendations for change

, if any, that would be seen as beneficial both to consumers of pure maple syrup as well as to maple syrup industry stakeholders throughout the value chain for pure maple syrup in the U

. S

. , Canadian and overseas markets . After a period of about three years of consultation with maple syrup industry lead ers in Canada and the United State s and an exhaustive

review

, the IMSI’s Maple Grades and Nomenclature Committee finalized their recommendations. The

committee recommended that it would be highly beneficial to the maple industry to establish a standard def inition and standard grades and nomenclature for pure maple syrup

. The need for
international standards has become very apparent and the timing for this change is ideal since the industry is mature, well organized and ideally positioned for growth both in terms of scale and
markets in North America and overseas.

Consumers currently face a patchwork of grading systems that are confusing and fail to explain the important differences between grades and colour classes in meaningful terms to consumers (i.e.

cu rrent grading systems rely on colour descriptors with no indication of flavour )

. It is clear that the current system needs improvement. Some of the i mportant benefits of standardization expected in
North American and w orld markets include: a) Provide a Standa rd Worldwide Definition for Pure Maple Syrup:

 Establishment of a world wide standard definition for “pure maple syrup”

, creat ing a single
reference for consumers , maple producers

, maple packers

, maple retailers and regulators

. For the purposes of this regul atory submission, “ pure maple syrup ” is synonymous with “100% pure maple syrup” and “maple syrup”.

 Provision of a uniform standard for maple syrup, allowing easy comparison with other sweeteners in the marketplace

.

 E nhanc ement of consumer awareness of “pu re maple syrup” as a 100% pure and natural product

, distinct from all other common sweeteners , both natural and artificial

.4

b) Moderniz ation of the Grad ing and Classification System for Pure Maple Syrup Sold in Retail
Markets:

 Elimination of Canada No. 2 Ambe r and Grade B designations in retail markets

, thereby removing grade discrimination against darker syrups

.

 Creating four uniquely different classes of Grade A maple syrups for retail markets

, including
flavour information on the label of the product for t he benefit of the consumers

. ( T his is a new labeling provision, currently absent from all existing maple regulations

. )

 Establishment of a single Processing Grade for off

- flavoured and otherwise defective syrups

. These syrups can be used as a food ingredie nt or for other non

- food uses but are not acceptable for retail sale

. c) Moderniz ation of Maple Regulations in Canada and the United States:

 U niform updating of the provisions of the government regulations on nomenclature, grade s and classes for pure maple sy rup

. T he se provisions of some regulations are very seriously out
of date

.

 A more simplified and uniform description of grades and nomenclature for pure maple syrup for maple syrup industry stakeholders as well as consumers and ingredient users

.

 Elimination of confusion about grade names and nomenclature from jurisdiction to jurisdiction around the world, including communications on the internet and rapidly emerging social
media. d) Marketing and Sales Benefits:

 Simplifie d communication related to trade

, packi ng , marketing and sale of maple syrup

, with
reduced costs

, particularly in the medium and longer

- term.

 Consumers and ingredient user will greatly benefit from a more uniform definition for pure maple syrup, more uniform label descriptions and an indication of different taste intensities on the product label, thereby aiding in more consistent purchase decisions and satisfaction

.

 Provi sion of a more specific and industry assisted standard for keeping off

- flavour ed syrup out
of the retail mark etplace

.

 Potentia l for expanded sales of pure maple syrup, particularly good quality syrups of darker
colour. e) Food Quality and Safety:

 T he potential for off

- flavours in the different colour classes of maple syrup should be reduced
overall . This will be a consequence of en hanced producer, packer and consumer training and vig ila nce as well as more of an emphasis on taste with taste characteristics being included on the labels of the different classes of syrups

. Note: (1) Off

- flavours , if they occur, are of most serious cons equence in the lighter syrups

since they are less likely to be masked by the stronger intensity of flavour of the darker

syrups

. (2) Syrups in the darkest colour class are a relatively small proportion of the syrups produced

. (3) Most consumers will use t he syrups in the darkest colour class “ for cooking ” and

many producers will market it for that purpose

, albeit common use is not specified on
the label.

 The proposed changes will have no impact on food safety regulations or food safety monitoring for pure maple syrup

, with the possible exception of the batch coding label provision.5

In 2005, a fter extensive consultation with maple syrup industry leaders

, the IMSI’s Maple Grades and
Nomenclature Committee recommended the adoption of standard grades and nome nclature for the international maple syrup industry

. The IMSI’s Board of Directors approved this recommendation in principle

, subject to completing related sensory evaluation and consumer research to help validate
the change. After completion of t his resea rch and further consultation and negotiation with maple syrup industry stakeholders

, a proposal was finalized . This proposal took into account the sensory evaluation and consumer research findings as well as additional maple stakeholder input. Maple

syrup industry stakeholders

, representing maple syrup producers and packers

, met in Bar Harbor

, Maine where the final content of the standard grades and nomenclature proposal was negotiated

. Subsequently, t he IMSI’s Board of Directors unanimously approved the s tandard grades and nomenclature proposal for implementation at their meeting in Bar Harbor in October

, 2009.

An implementation plan for the changes was developed following the meetings in Bar Harbor and this plan was approved by the IMSI’s Board of Direc tors in February, 2010

. A target for implementation

was set , subject to regulatory approvals, for the 2013 maple syrup production season

.

Since October of 2009

, the IMSI ha s been working primarily to raise awareness of the proposed maple grades and nomen clature changes within the maple industry . Work has also gone into planning for other aspects of implementation , including planning for operational market trials

, prepar ing this regulatory proposal and exploring options for new colour classification kits.

The IMSI will follow this regulatory submission wi th related communications efforts and other planning activities, in cooperation with maple syrup industry stakeholders and respective
governments, to facilitate implementation of the standard.

Members o f the IMSI and other supporters of standardized international maple grades are being
asked by the IMSI to write individual letters of support for this regulatory proposal by September 30 th

, 2011. Letters of support should be forwarded to the IMSI’s Executi ve Director.

Government and maple industry contacts are being designated in both Canada and the United States

in preparation for the proposed standardized definition

, grading and nomenclature changes for pure maple syrup . These contacts will be in place at the federal levels as well as in each state and province with a commercial maple syrup industry. These individuals will receive a copy of this regulatory proposal when it is finalized

.

II. VALUE OF THE NORTH AMERICAN MAPLE SYRUP INDUSTRY

The value of the North American maple syrup industry is estimated at $400 million annually in terms of product s ales

. The maple crop can vary significantly from year to year due to weather and other factors. Both the United States and Canada are major contributors t o the scale and sustainability of the North American maple syrup industry. While Canadian production of maple syrup exceeds U.S. production at present, the U.S. market is essential to maintaining a sustainable maple syrup industry
in North America. It is i mportant to understand that the relative size of the commercial maple syrup industry in different states and provinces may change over the next 20 years. Information on the size6

and value of the maple syrup industry in 2009 is provided in Appendix B. The p rosperity of the commercial maple syrup industry is contingent on maintaining close cooperation and collaboration between maple syrup industry representatives in Canada and the United States.

III. S COPE OF THE REGULATORY PROPOSAL

What is Proposed for Regulation ?
The standard grading

, labeling and sale of pure maple syrup in retail markets ( Grade A) is proposed for regulation as well as the packing

, labeling and sale of pure maple syrup which does not meet the

propose d requirements for retail sale (P roc essing Grade )

. This is in addition to other regulatory requirements related to food quality and safety. The proposal would amend the definition, grades, and

some labeling requirements of all pure maple syrup

.

Maple Regulations Re quiring Change
All existi ng maple regulations at the federal and state or provincial level s in Canada and the United States would require change

. Specific jurisdictions with required or voluntary regulations in place
would be a ffected. This includes the U

. S

. and Canadian f ederal r egulations, provincial maple regulations in Ontario and Quebec and state regulations in Maine, Vermont, New York, New Hampshire, and Ohio.

All applicable f ederal and s tate / p rovincial regulations and policies related to food safety and quality

assurance w ould continue to remain in force under the proposed new standard. Syrup which fails to
meet these grade provisions and standards must be disposed of as prescribed by these regulations (e.g. used in non

- food applications, destroyed, reworked, etc.).

Purpos e o f Standard Grades a nd Nomenclature The overall goal of standard grades and nomenclature is to provide a universal definition and standardized grading and labeling requirement s for pure maple syrup in the North American and
world marketplace . This will better reflect the needs of consumers and maple syrup industry
stakeholders.

Target Product The target product includes all good quality pure maple syrup s uitable for human consumpt ion in the
North American and world retail marketplace ( G rade A) and syrup un suitable for retail sale but
suitable for use as an ingredient in food products ( P rocessing G rade)

.

Product composition would need to fall within the recognized norms for pure maple syrup. Products derived from pure maple syrup that have been significa ntly modified from industry accepted norms would be excluded from this standard

, unless they have been specifically accepted to fall under the definition of pure maple syrup. Examples of altered syrup products would include a product marketed
as “Extra Thi ck” maple syrup

, as well as other products such as low Glycemic Index Syrups derived directly from pure maple syrup that may be available in the future

.7

The proposed standard

, governing the labeling and marketing of pure maple syrup

, would not specifical ly dictate the use of the product by consumers or ingredient users. The intent is to provide adequate information so that consumers can purchase maple syrup ( Grade A) that meets their expectations. Producers and packers of pure maple syrup would continue t o be free to market their syrups promoting specific uses for various colour classes , provided that all of the required label information as outlined in this proposal is p resent and all regulatory requirements are being met. Because information regarding co mmon us es of different colour classes of syrup is excluded from the required label provisions in this proposal, it is up to consumers to match colour classes of syrup to

uses based on their preferences or on maple producers and packers to provide informati on and suggestions to help consumers with their decisions . This is especially important for the darkest syrups which are most commonly used for cooking and can be less pleasing to the palate for ma ny

consumers due to their strong taste.

It is recommended that all regulating bodies permit the option of using stickers on the cap or neck of
bottle s for the grade, colour and taste descriptor information. At the present time, the grade designation cannot appear on the cap in Canada. Since there is only one Grad e A in the proposed standard system, it is recommended that this restriction on the use of grade stickers be removed in
Canadian regulation

. All other regulations related to the placement of label information are not affected by this proposal.

Processing G rade maple syrup would also have label requirements ( as described on pages 9 and 10) under the proposed system but would not be permitted to be sold at retail. Processing Grade Syrup
could be used for food processing and non

- food uses and would be requir ed to be packed in
containers no smaller than 5 gallons or 20 litres in size.

Target Tra de
All i nternational

, i nter s tate, i nter p rovincial, regional and local packing

, sale and l abeling of pure maple syrup would be impacted by the changes

.

Target Audienc e All vendors and distributors of pure maple syrup in Canada

, the United State s and the i nternational marketplace w ould be affected by the proposed introduction of standardized grades

, packing and labeling requirements

.

Intended Beneficiaries It is expec ted that the following groups would benefit from the proposed standardized grades and nomenclature of pure maple syrup:

 Consumers and Ingredient Users of Pure Maple Syrup (food use only)

 United States and Canadian Maple Syrup Industries

 Individual Maple Syrup Producers and Packers of Pure Maple Syrup

 Regulators of Pure Maple Syrup

 Buyers and Retailers of Pure Maple Syrup

 Restaurants and Pancake Houses8

IV. PROPOSED INTERNATIONAL GRADES AND QUALITY STANDARDS

The proposed framework and specific provi sions for the proposed standard ized maple grades and
nomenclature are outlined below.

Definition and Requirement s for Pure Maple Syrup

 Produced exclusively by the concentration of maple sap or by the solution or dilution of a pure maple product other tha n maple sap in potable water ; potable water must meet applicable quality and safety standards in the jurisdiction where the syrup is sold

 Minimum soluble solids of 66 .0 %

 Maximum soluble solids of 68.9%

 Comply with f ederal and s tate / p rovincial guidelines

, laws and standards for contaminants

 Comply with all other f ederal and s tate / p rovincial regulations and policy directives (e.g. labeling

, standard containers

, establishment registration

, and product quality )

 Proper determination of grade and colour class
***Note: It is recommended that the con s ensus of the IMSI Board of Directors be the determining factor regarding whether or not a new product derived from pure maple syrup falls within the scope of this definition

. ***

Q u a l i t y D e s c r i p t o r s

G r a d e A M a p l e S y r u

p G r a d e A m a p l e s y r u p w o u l d b e c o m p r i s e d o f f o u r u n i q u e c o l o u r c l a s s e s , a l l o f w h i c h w o u l d b e

p e r m i t t e d t o b e s o l d i n r e t a i l m a r k e t s , p r o v i d e d t h a t t h e f o l l o w i n g r e q u i r e m e n t s a r e m e t :

 Uniform in colour

 Intensity of flavour (taste) normally associated with the colour class

 Free from objectionable odours

, off

- flavours , and fermentation

 Free from turbidity or sediment

The quality descriptors and a general description of each of the four colour classes of Grade A maple

syrup would be as follows:
Golden Colour and Delicate Taste Pure maple syrup in this class has a light to more pronounced golden colour and a delicate or mild taste. It is the product of choice for consumers preferring a lighter coloured maple syrup with a delicate or mild taste. Light tr ansmittance not less than 75% Tc.

Amber Colour and Rich Taste Pure maple syrup in this class has a light

, medium or darker amber colour and a rich or full

bodied taste. It is the product of choice for consumers preferring a full

- body tasting syrup of
med ium taste intensity. Light transmittance 50

- 74.9% Tc.

Dark Colour and Robust Taste Pure maple syrup in this class has a dark colour and a more robust or stronger taste than syrup in lighter colour classes. It is the product of choice for consumers prefer ring a dark coloured syrup with substantial or robust taste. Light transmittance 25

- 49.9% Tc.9

Very Dark Colour and Strong Taste Pure maple syrup in this class has a very strong taste. It is generally recommended for cooking purposes but some consumers m ay prefer it for table use. Light transmittance less than 25% Tc

.

Processing Grade Maple Syrup Processing Grade maple syrup would be restricted from being sold in any retail markets. It could be any maple syrup that does not meet Grade A requirements but does meet all other maple regulations and guidelines related to food quality and safety. Processing Grade maple syrup c ould have any of the following attributes and restrictions:

 May be any colour class and any light transmittance

 May contain off

- flavours * *

 May be very strong tasting syrup

 Must be p acked in containers of 5 gallons or 20 litres or larger

 Cannot be sold at retail

 May be used in food processing

** Off

- flavours are defined as any specific and identifiable or unidentifiable flavour or smell defec t that is not normally found in good quality pure maple syrup that may be related to natural factors ( i.e. woody, buddy) or the production

, handling , or storage ( i.e. burnt, chemical, mold) of the maple syrup. See Appendix 4 of the North American Maple Syr up Producers Manual (2006) for more information regarding off

- flavours in maple syrup.

Product Label Requirements All pure maple syrup sold in retail markets (Grade A) w ould require the following information to be
marked on the label :

 Pure Maple Syrup or 100% Pure Maple Syrup

 Product Origin ( State or Province or Country )

 Grade A (grade name declaration)

 Colour Class

 Intensity of Flavour

 Batch Code or Code of Production

Under the proposal, P rocessing G rade maple s yrup may contain objectionable odours and flavours and may not be sold in retail markets. Processing Grade may only be sold in bulk for food processing or

non

- food uses. It must be packed in 5 gallon or 20 litre or larger containers and be labeled with the following information :

 Pure Maple Syrup ( or 100% Pure Maple Syrup)

 Product Origin ( State or Province or Country )

 Processing Grade (grade name declaration)

 For Food Processing

 Batch Code or Code of Production Note: Name of producer/packer or registration number is a requirement in existing regul ations
and will be continued as a label requirement.10

The following is a summary chart of the proposed product descriptors to appear on the label of pure maple syrup:

Regula tory Emphasis Required Priority should be given to helping keep off

- flavoured or otherwise defective syrups out of retail
markets ( i.e. P rocessing G rade and syrup not meeting other quality or food safety standards presently included in government regulation and policy). Emphasis should also be placed o n ensur ing that pure maple syrup is labeled in accordance with the label information outlined in this proposal for both
Grade A and P rocessing G rade syrup

.

Less emphasis would be required to regulat e whether Grade A maple syrup is p laced in the appropriat e colour class es

. M arket forces should be largely sufficient to motivate maple producers and packers to avoid any misrepresentation in this regard

. The colour classes are designed for the consumers, essentially to aid in selecting maple syrup to meet their expectations. The regulatory emphasis will be to ensure that maple syrup sold as Grade A syrup in retail markets does not contain
off

- flavours and meet s regulatory requirement s related to food quality and safety.

It is recommended that grading and off

- flavour identification training of maple regulators and maple producers and packers be stepped up significa nt ly from existing levels. Emphasis in training programs should be placed on the identification of off

- flavours and other defects in maple syrup and how to
avoid th ese where they are relate d to the production or packing process. The format and content of the IMSI sponsored Maple Grading School provides an excellent model to emulate and expand at the provincial / state and federal level s

. This s chool has been highly successful. Further information on the

s chool can be accessed at http://umaine.edu/maple

- grading

- school/

.

Research currently underway at Centre Acer in Quebec may lead to the developmen t of affordable and practical instrumentation to help identify off

- flavours in syrup at the field level. This development would provide an excellent supplement to assessment of flavour by trained individuals

.

It is strongly recommended that the applicati on of standard ized grades and nomenclatur e apply i n all

s tate and p rovincial jurisdictions with a commercial maple syrup industry

.11

Overview o f t he Current Maple Regu lations That Would Be Affected The following maple regulations would be affected by the proposed changes:

 At the Federal level

, regulations administered by the United State s Department of Agriculture and the Canadian Food Inspection Agency.

 State regulations currently in place in Vermont

, Maine

, New Hampshire

, New York State, and
Ohio

.

 Prov incial regulations currently in place in Ontario and Quebec

.

 Any states/province s currently without regulations but interested in implementing maple grades in the form of regulations or voluntary standards

.

A summary of existing maple regulatory require ments for grading and nomenclature for pure maple syrup in Canada and the United States is included as part of this submission (Appendix C). A review of this chart shows the important differences between the grading and nomenclature requirements in

current maple regulations compared to those in the proposal. Light transmittance classes have been adjusted somewhat for syrups with a light transmittance less than 75 Tc. as part of the proposed
standard

. This improved alignment better reflects the changing tast e intensity of syrups across the full gradient of colour and provides consumers with up to four good quality classes of syrup to choose
from. New colour classification equipment is required to reflect this change in colour classes. P ractical grading equipm ent to help identify off

- flavours in a field envir on ment may also become a reality in the future, supplementing existing means of grading.

The i ntroduction of standard grades will significantly lessen the discrepancy between f ederal, s tate
and p rovincial regulations

. With a standardized system in place

, it would also be easy for s tates and

p rovinces without existing maple regulations to adopt the new system. These states and provinces are strongly encouraged to do so

.

V. RATIONALE FOR STANDARDIZED GRAD ES

Why is the Change Needed? The change is required to more closely align the definition, grading, nomenclature and labeling of pure maple syrup wit h the expectations of consumers and ingredient users and the recommendations of maple syrup industry stak eholders

. More consumers will purchase and consume pure maple syrup if they are provided with meaningful label information related to taste and more emphasis is placed on keeping off

- flavoured syrups out of the retail marketplace. Simple and uniform gradin g and labeling of pure maple syrup is nee ded to reduce confusion and provide consistency for consumers. In the medium and longer

- term

, these changes in syrup grading, syrup classification and syrup identification will lead to a larger market share for pure maple syrup both in the North American and i nternational marketplace. This will have a highly beneficial trickledown effect into local communities in Canada and
the United States.

Consumer Preferences Consumer research findings and anecdotal evidence i ndicate s that ma n y consumers do not
understand current maple grading and classification systems and are further confused by differences12

between the various maple producing provinces and states. Consumers are highly mobile and a large
amount of syrup is exp orted across jurisdictional bound a ries.

There is also some confusion with regards to the definition of pure maple syrup. A uniform definition would be advantageous to consumers.

Consumers wish to know where the ir syrup originates from (provinc e , state or country)

.

Consumer research findings in Canada and the United States show that there is a range of consumer preference s for maple syrup related primarily to differences in the intensity of flavour or taste of

syrup. Consumers have indicated that both c olour and taste of syrup are important to their purchase decisions and a basic indication of taste intensity on the label , in addition to colour, would be highly
beneficial

. More complex application of flavour terminology is not easily understood by most

c onsumers and is not recommended in this proposal. M aple producers and packers are not always
available t o fully address the questions of consumers regarding the taste and other attributes of maple

syrup so it is very helpful to have this information on the bottle. Consumer preferences for various

taste intensit ies of maple syrup is analogous to cheddar cheese products where some consumers prefer a mild cheese and others prefer a cheese with a very strong flavour. Consumers have also
indicated that it is rea sonable to distinguish up to four distinct classes of syrup based on colour and
taste attributes. A single Grade A with four different colour classes of good quality syrup is designed to
reflect th ese realit ies

.

Consumers are negatively impacted when off

- flavoured or otherwise defective syrup is sold in retail markets and the reputation of the maple syrup industry is negatively impacted.

Consumers also expect that producers and packers should be in a position to trace a problem back to
the source if one is identified to them by a regulatory officer or consumer

.

What i s t he Issue a nd Why is i t Important?
The main issue is that the definition

, grading and nomenclature of pure maple syrup are not aligned
with the needs of consumers and ingredient users. A non

- standard approach to grading and nomenclature for pure maple syrup generates confusion among consumers and adds to product labeling costs across the value chain for the product. The international maple syrup industry is well positioned for expansion but current grading systems and nomenclature present an obstacle

.

Darker syrups are currently graded as Grade B in the U.S. and Canada #2 Amber or Canada #3 in
Canada . This implies that darker syrups suitable for retail sale are of inferior quality to l ighter syrups

. In reality, there are m any consumers who prefer good quality Grade B or Canada #2 Amber or even darker coloured syrup. The new system would place all colours of maple syrup on equal footing in the retail market, provided they meet taste and quality standards.

There is no indication of intensity of flavour , a more meaningful product attribute to consumers than colour, on the label s of syrup in current maple product and sales regulations

. Many consumers of pure maple syrup use colour as a sur rogate for taste once they become familiar with the product. The proposed taste descriptors are basic and do not represent hard line distinctions of flavour between13

different colour classes of syrup for retail sale. Maple producers and packers would contin ue to classify syrup using colour, but would add the simple taste descriptor to assist consumers and ingredient users in their choice of syrups. Blending of more than one batch of pure maple syrup is an acceptable practice that can be used to help satisfy market demand and should be encouraged if it helps align the characteristics of the syrup with consumer demand.

There is currently an insufficient emphasis on assessing the taste of syrup in the current grading
system, with a high potential for off

- flavo ured syrups or otherwise inferior syrups to be sold in retail
markets. The addition of taste descriptors would motivate producers and packers to more closely

monitor the taste of syrups and identify any off

- flavoured syrup as P rocessing G rade.

Some regul ations are seriously out of date with respect to consumer demand and current marketplace
realities and have had limited modification s and/ or exemptions added over the years which are only
band

- a i d solution s

. For example

, in Maine the Grade B designation wa s eliminated and the Grade A designation was extended into the darker syrups

.

The change will help make 100% pure maple syrup stand out from competing sweeteners in the marketplace, including table syrups that are identified as containing some pure maple syrup. Pure maple syrup currently represents less than 1% of the market share of common sweetener sales in
North America.

The change will help facilitate trade and eliminate costly duplication in preparing products for export
and will simplify trade lan guage requirements.

VI. ANALYSIS OF REGULATORY AND NON

- REGULATORY OPTIONS

The Need for Regulation Regulations are necessary to enforce the grading and labeling standards for pure maple syrup since voluntary and purely self

- regulatory approaches lead to a patchwork application both at the producer/packer level and at the s tate / p rovincial level. Lack of regulations or their enforcement can also result in syrup of inferior quality entering the retail marketplace. Grading of maple syrup is currently volun tary in some jurisdictions

. I t is not uncommon to see pure maple syrup being sold without any indication of grade or colour class , even in jurisdictions where regulations currently exist. Regulations are necessary primarily to help ensure that off

- flavoure d or otherwise defective syrups are
not offered for sale in the retail marketplace and that all syrup sold is batch coded or code identified

. Batch coding is important so that if there is a problem with product quality or safety

, identified after the prod uct is sold, the origin of the syrup can be easily determined and the problem batch recalled

.

There are strong indications that the proposed changes will rejuv e nate producer and packer interest in required label detail s and in streamlining approaches to product labeling and overall presentation to reduce costs and increase effectiveness in the marketplace.

Adher e nce to a uniform standard for grading and classifying pure maple syrup will serve to reduce the likelihood of confusion among consumers when co mparing different sweeteners in the marketplace.14

Since the product will be more clearly defined in the marketplace, the probability of consumer fraud is
also lessened.

Federal government s in Canada and the U

. S

. or p rovinc ial or state governments may con sider putting in place third party accreditation for the standard grading and labeling requirement s to assist regulatory program efforts. The organized maple syrup industry in Canada and the United States has

a n important role in helping ensure that regula tions are followed.

How w ill t he Regulatory Proposal Resolve t he Issue? Adoption of the regulatory proposal will provide for the following:

 One uniform definition for pure maple syrup to contrast with other sweeteners

.

 Elimination of Grade B and Canada #2 Amber and adoption of G rade A syrup ( four colour classes) for retail sale

.

 Addition of intensity of flavour descriptors on the product label of syrups for retail sale

.

 Adoption of one P rocessing G rade with packing criteria for all off

- flavoured or othe rwise defective syrups not suitable for retail sale.

 Elimination of the patchwork of grades and nomenclature currently in existence

.

What a re t he Supporting References f or t he Proposed Changes ? The supporting references for the grade and nomenclature cha nges are:

 Canada

- U

. S

. Regulatory Cooperation Initiative for improved regulatory harmonization

 Consumer r esearch s tudy conducted by Cintech Agro a liment ai re on behalf of the IMSI and the Federation of Quebec Maple Syrup Producers (2009)

 Support of an experi enced m arketing c onsultant and o thers with e xtensive m arketing

e xperience

 Ohio State University C onsumer S tudy (1995)

 Documented feedback from maple producer and packer stakeholders over a 9 year period (2002

- 2011)

 Support of the IMSI’s Board of Directors (2009)

 Support of Maple Producer Associations

, Packers and others in Canada and the United States ( l etters of s upport to be provided)

 Varied and

, in some cases, out

- dated maple product labeling and sales regulations in Canada
and the United State s

Invo lvement of Regulatory Officials The support of government and regulatory officials provided to the commercial maple syrup industry
in both Canada and the United States has been invaluable but it is recognized that government regulatory personnel are spread ver y thin on the ground in both countries

. Operational experience over the past few years in both countries attests to th is fact. In recent years, the IMSI has expressed concern about diminished support from government regulatory officials.15

A significant number of state jurisdictions in the U

. S

. do not require grading of pure maple syrup

. Maple syrup industry officials in these jurisdictions will be strongly encouraged to adopt and apply the proposed IMSI grades standard.

Government and maple regulatory officials in maple syrup producing provinces and states will be encouraged by the IMSI to continue to support and enforce programs designed to safeguard the quality and safety of pure maple syrup.

Self Monitoring and Education Industry monitoring for q uality and safety of pure maple syrup is encouraged by the International Maple Syrup Institute. These efforts are intended to supplement, not replace government regulatory

programs. It would be ideal if the states and provinces could institute a third part y independent
accredit at ion for the grading and labeling of pure maple syrup

. This may be possible in some jurisdictions but not in others due primarily to fiscal constraints.

The International Maple Syrup Institute has sponsored a Maple Grading School i n Canada and the
United States since 2004. Maple producer and packer participa nts in the school ha ve emphasized the importan ce of the awareness and training offered by this school to fully understand and properly employ a grading system

. This school and ot her training programs in some provinces and state s may easily incorporate the proposed standardized grading system . They also provide working models for design ing a grading school to educate producers, packers, regulators and other interested parties on

t he proposed IMSI standard grading system

. The IMSI is aware that there is still , in some circumstances, a signifi c ant gap between government standards for regulatory compliance and the reality on the ground

. A more uniform and simplified approach to gradin g , combined with enhanced investments in maple producer and packer awareness and education

, will help alleviate this problem.

Grading of Maple Syrup and Third Party Verification /Audit Most maple syrup which is packed for the bulk trade is already graded by trained specialists. This includes classification of the syrup into syrup of good quality by colour class as well as the
identification of off

- flavours and defects. For example, Centre Acer in Quebec is responsible for grading all bulk syrup produced i n that province and the Vermont Agency of Agriculture, Food and Markets grades bulk syrup for packers in the State of Vermont. The expertise of specialists such as these, as well as others involved with the IMSI sponsored maple grading school

, can provide the
foundation for transferring grading expertise out to the broader maple industry in Canada and the
United States.

In the future, there is also the opportunity to involve other third party verifiers such as independent
consultants in both Canada and th e United States in both awareness/education aspects and verification/audit of grading . This would help transfer grading expertise and application of the grading standard to the broader maple industry in Canada and the United States for both retail and bulk syrup. Available financing and commitment by provincial and state producer and packer organizations as well as individual producers to support this service has not been pursued but may be a constraint

.16

Operational Trial Markets

A limited number of oper ational market trials in Canada and the United States are being planned and
will be conducted in 2011/2012 by the IMSI as a n integral step towards full implementation of standard grades

. These market trial s w ill be designed to engage maple producers and pa ckers directly in utilizing the proposed standard definition, grades and nomenclature in advance of implementation

.

These operational market trials are not prerequisite to the implementation of standard international grades but rather are to provide for early operational engagement

, as well as additional feedback from maple producers

, packers and consumers that should help ease the transition to standard grades . The market trials will help identify where ongoing communications and education/awareness effo rt is
most needed.

VII. SUPPORT AND CONTROVERSY REGARDING THE STANDARD IZED GRADES PROPOSAL

Public Interest and Maple Stakeholder Support It is anticipated that there will be widespread public interest and support for standardized grades and
nomenclatu re once the changes have been communicated to the broader public

. Consumers
worldwide will be the beneficiaries of a uniform approach to both grading and describing pure maple syrup for sale in retail market outlets

. Confusion should be minimized and consu mers should have the
information needed to purchase their preferred maple syrup more consistently. Timing of the change is particularly opportune with the rapid emergence of social media in recent years and enhanced opportunities for consumers to connect i n North America and most other countries worldwide. Social
media presents consumers from around the world an opportunity to compare their experience with pure maple syrup and other sweeteners. Communication will be simplified with the adoption of this

inte rnational standard.

Potential Controversy While there is no confirmation at this time, it is possible that one or more small state producer associations without mandatory grading and labeling may resist a move to standard ized grading

. Benefits may be l ess apparent i f grading of syrup is voluntary at present and membership is comprised mostly of very small producers . These producers may sell small quantities of syrup in their local or regional communities and may not be involved with inter state, inter pro vincial and international

commerce

. However, even the smaller maple jurisdictions should benefit from a standardized and
more effective approach to grading and labeling for the who le maple industry . A thriving maple industry at the regional and internation al level can increase demand for syrup at the local level

. E fforts to grow the industry at the state or provincial level may also be assisted which can lead to less competition in local and regional markets a s well as higher prices for maple syrup

. Smaller maple producers may also benefit indirectly from enhanced economies of scale through reduced equipment and supply costs, more support for research and development and greater investment in education and marketing, if the international maple syrup industry is prosperous and growing

.

Some individual maple syrup producers in both Canada and the United State s may resist the changes
because of inconvenience and some added cost in the short

- term. C olour classification kits and17

product labels /screen prints wo uld need to be changed or adapted to the new standardized grading
system. The cost of kits used to classify syrup for retail sale would range from about $50 (temporary kit) to about $400 ( more permanent kit )

. Some existing grading equipment such as the L ov ibond may only require adaptation to accommodate the new colour classes and other equipment such as the
Hannah M eter would require no modification. It is notewor th y that in Quebec maple syrup must be classified using the Lovibond and in other jurisdictions most maple producers currently use temporary kits to classify maple syrup. A transition period between the existing and proposed grading systems would be helpful to permit maple producers and packers to utilize labels in inventory

, become familiar
with ne w syrup classification equipment and familiarize their customers with the new maple grading
system.

Some maple syrup producers associate darker syrup with inferior quality of product

, particularly in the
darkest colour class

. Because of this

, they may no t be in favour of the new system which allow s the darkest colour classes to be sold retail on equal ground with the lightest colour classes. Producers must keep in mind that any off

- flavoured or defective syrup must be graded as P rocessing G rade. This
shou ld leave only the syrup of good quality for retail sale, even in the darkest colour class. This change to better reflect the needs of consumers and ingredient users requires a paradigm shift in thinking at the maple producer level. (T he concern on this poi nt has been minimal throughout our stakeholder
consultations. )

Some maple producers and others may simply resist change to the status quo. This is seen as very normal and should be expected to a degree, wherever significant change is proposed.

The IMSI has been very active in raising maple syrup industry stakeholders’ awareness regarding the proposed changes (rack cards, fact sheets, presentations, etc.), with a special emphasis since October

2009. This awareness work will continue in the lead

- up to imp lementation

. Through a wareness and
education efforts of the IMSI and its members

, it has been found that the vast majority of individual maple producers and packers support the changes once they have had the rationale explained to
them. This is the main re ason that the IMSI has invested considerable time and resources in raising awareness regarding the proposed changes among maple industry stakeholders, particularly since

2009.

VIII. IMPACTS OF THE CHANGE TO STANDARDIZED GRADES

On the Consumers and Ing redient Users

 Pure m aple s yrup w ould be more distinct ly differentiated from other natural and artificial
sweeteners in the North American and w orld m arket p lace

.

 Consumers w ould be provided with four distinct classes of excellent quality syrup in retail

ma rkets

, aligned with their preferences

.

 Standard grades and nomenclature would contribute to market expansion for pure maple syrup by increasing markets for darker syrups and helping better distinguish pure maple syrup
from table syrups

.18

 The G rade B and Ca nada #2 Amber designation s, which impl y lower quality syrup

, will be removed from maple regulations in Canada and the United State s

. Some consumers and ingredient users prefer these syrups over the U

. S

. Grade A or Canada #1 syrups.

 Consumers and ingredient users will be provided with a basic indication of taste intensity on the product label which will help them more consistently purchase syrup in accordance with their taste preferences and needs.

 Communication among consumers and ingredient users regardin g the characteristics of pure maple syrup will be greatly facilitated

, especially across s tate / p rovincial jurisdictional boundaries and internationally

. It is hoped that confusion will be greatly reduced and replaced
with uniformity and clarity

.

 Consumers will benefit from m aple syrup producers and packers plac ing more emphasis on tasting their syrups and keeping off

- flavoured or otherwise defective syrup out of the retail marketplace

. A doption of a uniform P rocessing G rade for the maple syrup industry with label and packing requirements will assist with this.

 There may be some short

- term confusion regarding the changes in relation to the existing grading system s . T his will be minimized through effective awareness, education and

communication activities

. P ro vision of a transition period for the changes would also be advantageous so that the adjustment from the existing system to the new standard is
facilitated

.

 It is highly desirable that a doption of the new standard system be concurrent in all maple producin g jurisdictions

. D elayed implementation in some jurisdictions may cause unnecessary confusion.

On Trade Partners/Economy Impact as a Trading Language for the Sector :

 A standard grading and nomenclature system for pure maple syrup will facilitate inter st ate,
inter provincial and international communication across the value chain for pure maple syrup

.

 The standard requirement s can be easily translated to the common languages used in
international commerce

.

Impact on International Regulatory Cooperation wil l Reduce Technical Barriers to Trade and Improve Competitiveness:

 M odernization

, uniformity and streamlining of maple syrup labeling and sales regulations

.

 Moderniz ation and standardiz ation of maple regulations will facilitate inter state,
inter provincial a nd international communication and cooperation

.

 Part of the r egulatory requirements for labeling will be uniform

, more easily underst ood and
less of a n obstacle to trade

.

 A s tandard definition for pure maple syrup and some related labeling requirements wi ll be distinctive and provide a better contrast against competing sweeteners.

Impact on International Trade Agreement or Obligations:

 Sets the stage for possible application for international Codex standard for pure maple syrup

.

Impact for Interstate, In terprovincial and International Trade:

 More standardized product labeling requirements

.19

 Common trade language

.

 Easy to translate into main languages spoken in North America and around the world

.

Impact on Small versus Large Maple Producer and Packer Op erations:

 Medium and large r

- size d maple producer and packer operations will be the primary
beneficiaries , as they are more likely to be involved in inter state, inter provincial or international trade

.

 Enhanced sales of pure maple syrup in North America and overseas in the medium and long

term (medium scale or larger operations)

.

 All maple syrup producers and packers will benefit from a more uniform definition and standard for pure maple syrup since the standard defines the product in accordance with

consume r needs and expectations

.

 All temporary and some permanent maple grading kits will need to be replaced at a cost for maple producers and packers

.

 The changes will facilitate more standard screen print and product labeling requirements for
those involved in inter state /interprovincial or international trade

. The degree of benefit will vary with the jurisdiction and maple establishment.

 There will be some inconvenience and expense associated with the replacement of screen printing and product labels to meet t he new requirements. Cost will vary with the size of the
establishment

. Provision of a transition period for the change would allow producers and packers to use up the i r label inventory

.

 Maple producers

, packers and other maple syrup industry stakeholders will have a role in helping educate pure maple syrup consumers and ingredient users about the new standard grading system

. T his should be seen as an opportunity

, not a challenge

, and represents a continuation of consumer awareness and education efforts

.

Preventing Anyone from Accessing Their Current Markets for Maple Syrup:

 No impact foreseen

Stimulating Access to New Markets for Pure Maple Syrup:

 A uniform standard

, including taste descriptors

, should help increase the market share for pure maple syru p when compared to other sweeteners

.

 A standard international grading system will simplify communication and should lead to enhanced collaboration among potential trading partners

.

 The implementation of this proposal should create positive media attentio n with increased visibility that should stimulate sales and market access.

 Enhanced quality assurance

.

On Governments Reducing Administrative Burden and Duplication:

 Maple product labeling and sales regulations will be updated and streamlined

, reducing unnecessary duplication among f ederal, s tate and p rovincial regulatory bodies

.20

Alignment of the Standard Grades Proposal with Current Provincial/State Standards:

 Changes will be required in s tate and p rovincial maple regulations to accommodate the chang es

.

 States and provinces without current maple regulations may adopt and apply the new
standard

.

Enforcement of the New Maple Grading Standard:

 Since there will be only one G rade A maple syrup with four classes of syrup for retail sale

, demands on gove rnment enforcement personnel should be lessened . Most issues with the classification of syrup should be resolved in most part by marketplace forces

.

 Any remaining issues not resolved by the market forces would need to be resolved by the government enforce ment personnel. Program updates or implementation will be required, with some cost involved (e.g. manual, new grading equipment, training, etc.).

 Potential to expand the IMSI sponsored maple grading school and make it accessible to all regulating parties

.

 Government regulators should focus on issues related to keeping off

- flavoured or otherwise defective syrups out of the retail marketplace using a combination of education and regulatory
methods

.

 Potential for third p arty m onitoring in s ome jurisdictions

.

Impact on Federal Departments, Agencies, other Countries:

 Improved coordination of standards between f ederal and s tate / p rovincial levels

.

 Improved coordination of standards between Canada and the United States

.

 Other countries may adopt the standard

.

Coordination of Implementation Among State, Provincial and Federal Regulators:

 The IMSI is coordinating the submission of this regulatory document to appropriate government agencies in Canada and the United State s (Canadian Food Inspection Agency

, Ontario

, Quebec

, United State s Department of Agriculture

, Vermont

, New York

, New Hampshire and Maine ). The document is also being distributed to all other states and provinces with a commercial maple syrup industry

.

Fit with Initiatives to Re

- Draft Maple Regulat ions:

 Very g ood f it with m aple r egulatory a mendments o ver the p ast five years (Maine)

.

 Very good fit with o ngoing r evision of m aple r egulations

.

Reasons for Governments to Place High Importance on these Regulatory Changes:

 The c oordination of changes to maple regulations at the s tate, p rovincial and f ederal level s is highly desirable

.

 Coordinat ion of implementation of standard grades in Canada and the United State s is highly
desirable to achiev e a smooth transition to the change.

 The IMSI has targeted th e i mplementation of stand ardized grades for the 2013 maple production season (January 2013)

.21

Costs and Savings (Qualitative and/or Quantitative):

 The maple syrup industry and government partners have invested an estimated $500

, 000 ($$ and

in

- kind) direc tly or indirectly in related research

, develop ment of this proposal and planning for implementation of standard ized maple grades and nomenclature

.

 New grading kits required (producers and packers)

.

 N ew silk screens and labels required

.

 Packing and labeling c osts r educed for export

.

 Enhanced training regarding sensory evaluation and tast ing of syrups for proper identification of
off

- flavours and grading of maple syrup.

 Public

, consumer , ingredient user and maple industry stakeholder awareness and education

r equirements

.

 Enforcement costs should decrease or stay the same

. M ore emphasis being placed on excluding
off

- flavoured or otherwise defective syrups from retail sale should be offset by reduced costs in regulating colour class and grade distinctions among different retail syrups

.

 Reduced labeling costs and more streamlined approaches to labeling expected after a period of
two years

.

IX. IMPLEMENTATION AND EVALUATION OF THE PROPOSAL

The IMSI has developed an implementation plan for the standardized gr ades proposal

, extending
from 2009 to 2014 (Appendix D ). The implementation plan has five main components , as follows : 1) Maple syrup industry awareness and educ ation

– materials and activities 2) Operational market trials in advance of full implementation 3) Regu latory submission 4) Preparation for proposed changes

- maple syrup industry stakeholder awareness and education (materials and transfer, operational market trials, planning for new colour classification kits) 5) Communications p lanning and o utreach to maple syr up industry stakeholders (ongoing), and

consumers (once regulatory approvals have been obtained)

The I MSI will also monitor and evaluate the impact of full implementation of the proposal over the next five years t o identify problems, if any, and recommend corrective action as necessary.22 X. APPENDIX

APPENDIX A: 2011 LIST OF IMSI MEMBERS AND

MAPLE GRADES AND NOMENCLATURE COMMITTEE MEMBERS

2011 IMSI Members in the United States Connecticut Maple Producers Association New Hampshire Maple Syrup Producers Association Maine Maple Syrup Producers Association Massachusetts Maple Producers Association Michigan Maple Syrup Producers Association New York State Maple Producers Association Ohio Maple Syrup Producers Association Vermont Maple Sugarmakers Assoc iation Leader Evaporator Company Incorporated University of Vermont Proctor Maple Research Cent er Wisconsin Maple Syrup Producers Association AEC Specialty Food Products Andersons Maple Syrup Inc.

Butternut Mountain Farms Bascom Maple Farms Maplelan d Farms Brookview Sugarhouse Richard’s Maple Products Maple Grove Farm Mead’s Maple Syrup Norman's Sugarhouse Green's Sugarhouse Green Mountain Sugarhouse Girard's Sugarhouse
Wildwood Farms Couture's Maple Shop/B&B Longview Forest Products Percepti ons Inc.
Hall Farms

J M Harran Kathy Hopkins Gary Graham Larry Myott
Sumner Dole
Tim Perkins

Stu Peterson 2011 IMSI Members in Canada Nova Scotia Maple Producers Association New Brunswick Maple Producers Association Federation of Quebec Maple S yrup Producers Ontario Maple Syrup Producers Association

Centre Acer Les Équipements Lapierre Inc. Maple Pro/CDL
Dominion and Grimm
Citadelle L.B. Maple Treat Inc Turkey Hill Sugar Bush Ltd
Natunola Agrofor Intl Erabliere Le SiRoytier Inc

. Norman Hug hes Avard Bentley

SK Exports Inc.

Rino Leclerc

IMSI’s Maple Grades and Nomenclature
Committee Members Dave Chapeskie, Executive Director, IMSI (Chair) John Henderson, Risk Management Specialist, OMAFRA Jerry Kless, Director, Sales & Marketing, Citad elle Bernard Perrault, Director, Federation of Quebec Maple
Producers Ray Bonenberg, IMSI Director, Ontario Maple Syrup
Producers Association Arnold Coombs, Chair, Vermont Maple Industry Council Henry Marckres, Supervisor, Vermont Agency of Agriculture , Food &Markets23

Randy Heiligmann, Professor Emeritus, Ohio State University Eric Prud’Homme, Canadian Food Inspection Agency Chere Shorter, United States Department of Agriculture24 APPENDIX B : WORLD PRODUCTION OF PURE MAPLE SYRUP

World Production of Pure Maple Syrup (2009)

CANADA % of

total UNITED STATES % of
total
Number of Taps 50 million 85.3 % 8.65 million 14.7%
Production 9.08 million gallons

(10.9 million US gallons) 82.4% 2.33 million US gallons 17.6%

Value $353 million (Canada Total)

$304.9 million (Quebec) 82.0% $77.5 million 18.0%

Capital Investment : $3.5 billion (excluding lan d)2526

APPENDIX C : COMPARISON OF PROPOSED STANDARD MAPLE GRADES AND NOMENCLATURE WITH

EXISTING MAPLE GRADES AND NOMENCLATURE IN CANADA AND THE UNITED STATE S

Light

Transmittance United States

and all States Not Individually

Listed Vermont c

and Oh io a New

Hampshire c New York Maine Canada

All

Provinces IMSI

Proposed Option

> 75.0% U.S. Grade A

Light Amber Vermont

Fancy

Ohio Grade A Light Amber Grade A

Light Amber Grade A

Light Amber Grade A

Light

Amber Canada No.

1 Extra Light Grad e A

Golden

Delicate taste

> 75% Tc

60.5

- 74.9% U.S. Grade A

Medium Amber Grade A

Medium

Amber Grade A

Medium

Amber Grade A

Medium

Amber Grade A

Medium

Amber Canada No.

1 Light Grade A

Amber

Rich taste

50

– 74.9%Tc

44.0

- 60.4% U.S. Grade A

Dark Amber Grade A

Dark Amber Grade A

Dark Amber Grade A

Dark Amber Grade A

Dark

Amber Canada No.

1

Medium Grade A

Dark

Robust taste

25

– 49.9%Tc

27.0

- 43.9% U.S. Grade B for

Reprocessing Grade B Grade B b Extra Dark for Cooking

or Grade B

for Reprocessing Grade A

Extra Dark

Amber Canada No.

2

Amber Grade A

Very dark Strong taste

< 25.0%Tc

<27.0% U.S. Grade B for

Reprocessing Commercial

Grade Grade B b Extra Dark for Cooking

or Grade B

for Reprocessing Commercial

Grade Cana da No.

3

Dark Processing

Grade Any colour

class Any off

flavoured syrup

Fails Other

Grade Requirements

Due to Unacceptable Density, Color or

Flavor Substandard Substandard Substandard Substandard Substandard

Reference: North American Maple Sy rup Producers Manual, 2006

a Grading is mandatory in Vermont but optional in Ohio. In Ohio, producers may sell syrup ungraded or graded with Ohio’s
or the USDA grading standards.

b Table grade syrup; may be packaged in consumer size containers.

c Vermont and New Hampshire require 66.9° Brix minimum density.27 APPENDIX D : IMPLEMENTATION SCHEDULE