Comments from: Canada Border Services Agency

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Canada Border Services Agency

(Stamped) MAR 15 2007

Mr. Raymond Pierce
Deputy Commisioner of Competition
Competition Bureau - Fair Business Practices Branch
Place du Portage Phase I - Floor 17 Zone 8
50 Victoria Street
Gatineau, Quebec

Dear Mr. Pierce:

I am replying to your letter of January 18, 2007 in which you requested the Canada Border Services Agency's (CBSA) views and expertise on the discussion paper on the proposed amendments to the Textile Labelling and Advertising Regulations.

In July 2003, following discussions with staff of your branch, the CBSA reviewed and modified the approach to administer the Consumer Packaging and Labelling Act and Regulations, the Textile Labelling Act and the Textile Labelling and Advertising Regulations. As a result, we have been working in cooperation with the Competition Bureau to ensure that a targeted and risk management approach is used to administer these programs at the border.

We have experienced the paper Ammending the Textile Labelling and Advertising Regulations, and have comments on only one section. In section 4 "Imported Consumer Textile Articles" the proposal is that the partial exemption for unlabelled imported consumer textile articles be revoked, thus requiring all imported consumer textile articles to be properly labelled at time of entry. It is indicated that the importer would agree to provide notification of entry, apply the label in the appropriate manner and notify the Bureau. The CBSA would like to ensure that the onus of notifying the Bureau will be on the importer. Therefore the CBSA's role would continue to be limited to sharing import information and targeting identified high risk importations on behalf of the Competition Bureau.

Thank you for the opportunity to comment on the discussion paper. Should you require any additional information, please do not hesitate to contact Mr. Raymond Bédard, Director, Partnerships Division, Border and Compliance Admissibility Branch at (613) 954-6856

Yours sincerely,

(signature)
Alain Jolicoeur
President