Comments from: Saskatchewan Industry & Resources

(PDF; 219 KB)

March 30,2007
Saskatchewan Industry & Resources
300, 2103 - 11th Avenue
Regina, Canada
S4P 3Z8

Mrs. Carole Gaetz
Competition Bureau
2000,300 West Georgia Street
VANCOUVER BC V6B 6E1

Dear Mrs. Gaetz:

Industry and Resources appreciates the opportunity to review and respond to this
discussion paper. The Government of Saskatchewan is striving for a streamlined
regulatory and service framework that facilitates economic growth in the competitive
environment of the 21 st century, while safeguarding public health and safety, workers,
and the environment. Policy approaches that place Canadian industry and consumers at
a disadvantage without a clear benefit should be avoided. Additionally we believe that
adopting standards that conform to international standards is the best overall approach.

Bearing these points in mind the following are our responses to the specific questions
asked in the discussion paper.

Question:

1 a) Yes: The provisions are covered elsewhere

2 a) Yes: The regulations timeline is now obsolete

3 a) No: Floor covering labeling performs no function for the consumer after
the point of sale. The information a label could provide is of no value
after the flooring is installed as it is not visible. This type of
information is best provided in the bill of sale where it could be
retrieved later for cleaning and recycling information.

3 b) Yes: The French terminology should mirror the English version.

4 a) No: The partial exemption for unlabelled imported consumer textile
articles should not be revoked. This has not been a concern to
consumers in Saskatchewan. If it is revoked significant costs will be
added to the system.

5 a) Yes: Secondhand articles should be exempted from labeling. These items
may have already been washed many times and any shrinkage or
damage is likely already done. Most reused articles that are sold are
done so by charity organizations who can little afford the cost of
labeling used clothing

6 a) No: A provision to require internet textile sales to be labeled is almost
unenforceable. Such regulations are bad regulations. The only
enforcement possible would have to be done (when declared values
are high enough) by customs agents working within the post office
system which is already badly backlogged. If "inadequate" labeling is
found it can only result in shipments being returned and Canadian
customers losing their purchases. Invariably such consumers have
difficulty getting reimbursed. All internet sales are considered a
"buyer beware" situation in any regard such labeling requirement will
protect no one.

7 a) No: Exemptions from bilingual labeling should not be removed. Bilingual
labeling protects few consumers in most western markets. These
requirements add costs to manufacturers who export largely to
American and world markets. Efforts should be directed to meeting
international standards for textile labeling. These would have further reaching long-term benefits.

8 a) Yes: This is a regulatory streamlining activity.

9 a) Yes: This is a regulatory streamlining activity.

10a) Yes: International textile labeling standards should be encouraged. These
would also help address the bilingual concerns.

11a) Yes: This is a regulatory streamlining activity.

12a) No: Comment: We do not feel qualified to comment on the down vs.
feathers questions. What do your industry spokespeople have to say in
this regard? Their solutions are likely the most practical and
workable.

Yours sincerely,

(Signature)
Greg Riemer
Manager Regulatory Reform
Industry and Resources.