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Consultation on a Proposal to Verify Labour Standards in the Apparel Industry - Outcomes and Recommendations

Background

In February 2001, the Ethical Trading Action Group (ETAG) - a broad coalition of church, labour, and non-government organizations (NGOs) concerned about “sweatshop” labour practices, or ethical sourcing, in the manufacture of apparel - launched a new initiative to support labour standards in the international apparel industry. The initiative proposes that the Canadian government amend the current Textile Labelling and Advertising Regulations of the Textile Labelling Act to require manufacturers to disclose the addresses of all manufacturing sites involved in the production of a garment on the labels of apparel sold in Canada. Through this proposal, the group is seeking to facilitate the verification of the international labour standards and practices in place at manufacturing sites that supply apparel to the Canadian market.

A study was commissioned by the Competition Bureau, on behalf of the Minister of Industry, to assess this proposal and to identify the implications that the implementation of these amendments would have for consumers, governments, the domestic apparel industry, international trade and on the implementation of various trade agreements. In the study, which was released on May 30, 2003, the Conference Board sought to clarify the policy objectives of the ETAG initiative, set evaluation criteria and test whether these criteria would be met. The Conference Board also sought to propose alternative policy measures that would effectively address ETAG’s policy objectives.

In May 2003, the Competition Bureau asked the Public Policy Forum to lead a national consultation on the outcomes of the Conference Board study and craft strategic recommendations as to how the government should address the issue of fair labour practices in the apparel industry. The consultation process included the following activities:

 

·        Produce a Discussion Paper that summarized the issues and the results of the Conference Board study. This paper was posted on the PPF Web site (Annex V).

·        Solicit Written Submissions from interested organizations and individuals. Eighteen submissions and three letters were received as a result of this process, and the submissions were posted on the PPF’s Stakeholder Consultation Web site. (List of submissions, Annex I)

·        Draft a Convening Paper to summarize the issues, concerns and areas of consensus that emerged from the written submissions (Annex VI).

·        Convene and conduct a Multi-stakeholder Roundtable on November 28, 2003 in Toronto, Ontario. Participation at this roundtable was by invitation only. (List of Participants, Annex II; Agenda, Annex III)

·        Produce a Final Report (this document), including a number of strategic recommendations, on the basis of the submissions and the outcomes of the multi-stakeholder roundtable. This document has been submitted to the Commissioner of Competition and is posted on the PPF Web site at www.ppforum.ca.

 

Discussion Paper

The discussion paper was drafted by the Public Policy Forum on the basis of a literature review, an analysis of the Conference Board paper, and consultations with key stakeholders. This paper was intended to provide a summary of the Conference Board’s findings and to capture initial feedback from key stakeholder groups. Its purpose was to serve as a neutral and informative guide for stakeholders wishing to make a submission to the process.

 

Submissions Phase

The submissions phase of the Public Policy Forum consultation provided the stakeholder community with an opportunity to comment on the findings and recommendations contained in the Conference Board report. For the sake of comparability and clarity, stakeholders were asked to structure their submissions around five key questions:

 

1.  Using the information provided by the Conference Board report and your own experience and observations, do you believe that the regulated public disclosure of factory locations is critical to the success of voluntary or other initiatives designed to curb unfair labour practices in the apparel industry? Please explain.

 

2. In light of the Conference Board’s observations and given that unfair labour practices are an issue in sectors other than apparel manufacturing (footwear, toys, novelties, etc.), what would be the most appropriate means to achieve the mandatory disclosure of factory locations if that were determined to be a desirable objective?

 

3. In the absence of the regulated disclosure of factory locations, what role should the federal government play in ensuring the success of initiatives designed to improve labour conditions in the apparel industry, over and above its current activity?

 

4. What role could and should non-governmental organizations (such as ISO and the ILO) play in promoting resolutions to the challenge of unfair labour practices in the apparel industry?

 

5. What role could and should the apparel industry play in promoting resolutions to the challenge of unfair labour practices in its supply chains?

 

Convening Paper

The convening paper for the multi-stakeholder roundtable held on November 28, 2003, provided an overview and amalgam of the key issues and ideas that stakeholders identified in their submissions. Every effort was made to capture the key concerns of various stakeholders; however, the purpose of this document was not to relay the individual concerns of every stakeholder, but rather to provide a sense of the areas of commonality and difference, and to provide a useful vehicle to inform the discussion which took place at the roundtable. (The text of the convening paper is appended to this document as Annex VI.)

In general, stakeholders accepted the proposition that the Canadian public is interested in buying apparel that is produced using fair labour practices. There was also general support for the notion that the issues of corporate social responsibility and corporate citizenship are increasingly important to the Canadian public, and that the public has high expectations that industry will take action. Other comments made in the submissions were captured under three broad headings:

 

Principles - The underlying reasons why actions such as amendments to the Textile Labelling Act are/are not necessary and/or useful. The principles that were identified included:

·      transparency;

·      accountability;

·      equity/equality; and

·      efficiency.

 

Objectives and Goals - The ends the proposed amendments are meant to achieve:

·      improved labour conditions, both internationally and domestically/the enforcement of international labour standards; and

·      informed choice.



Issues and Concerns -Specific thoughts and concerns on the proposed amendments to the Textile Labelling Act:

·      labour standards as an issue in other sectors;

·      differential impact on SME’s;

·      cost;

·      efficacy of the database as an information tool;

·      need for credible, third-party, multi-stakeholder monitoring and compliance;

·     the proprietary nature of supply chain information;

·     the complexity of large supply chains;

·     the use of voluntary codes;

·     the need to mitigate shareholder risk;

·      public reporting;

·     the International Labour Organization; and

·     ongoing multi-stakeholder dialogue.

 

Outcomes and Recommendations

The final phase of the consultation consisted of the production of a Final Report and Recommendations based on the submissions and the multi-stakeholder dialogue (this document). This report has been submitted to the Competition Bureau in February 2004, and released in July 2005. It is posted on the Public Policy Forum Web site at www.ppforum.ca

 

Table of Contents I Key Findings from the Multi-Stakeholder Session