Comments from: Canadian Textiles Institute

From: Elizabeth Siwicki esiwicki@textiles.ca
Sent: Tuesday, April 17, 2007 10:29
To: Gaetz, Carole: VAN
Subject: COMMENTS ON PROPOSED AMENDMENTS TO TEXTILE LABELLING AND ADVERTISING REGULATIONS

CTI is the national association representing Canadian textile manufacturers.

Upon receipt in January of  the Competition Bureau's discussion paper outlining  proposed amendments to the Textile Labelling and Advertising Regulations, I circulated it and a summary of the key proposals to our members to obtain their input.

I have had little response, probably because most of the textile manufacturers we represent make products that are sold to other manufacturers and do not find their way directly to the consumer.  I assume you will have had more substantive comments from the Canadian Apparel Federation (representing Canadian apparel manufacturers) and the Canadian Carpet Institute (representing Canadian carpet manufacturers).

Here are the comments that I received:

• with respect to item 4: Imported Consumer Textile Articles (page 7 of the discussion paper), one of our members who also distributes imported consumer textile articles, has noted that "on occasion, vendors misunderstand or make mistakes with the labelling of textile products which are not caught until the goods arrive in Canada.  If this change was made, then it would be very costly and punitive to the supplier to return the goods and have them corrected.  The most cost-effective way to handle this is to re-label the goods in Canada before distribution."   This situation would occur with goods that are labelled, but which do not comply with the requirements.
  
• with respect to item 7: Bilingual Labelling (page 8 of the discussion paper),  it has been noted that some Canadian consumer textile product manufacturers service a number of small retailers in several provinces where English-only packaging is acceptable, or sell to retailers who service local demand only.  In both cases, the volumes on these types of transactions is low, but the costs associated withcreating and printing mandatory bilingual packaging could make them unviable.

Two additional comments:

• with respect to item 7: Bilingual Labelling (page 8 of the discussion paper),  it has been difficult for us to provide members with clear guidance on whether or not the existing bilingual labelling requirements apply in particular markets because there is no list of "areas where only one official language is used continuously for the purpose of making consumer purchases"..  While it is clear that they apply in Quebec (where products are also subject to provincial laws) and it can easily be deduced that markets such as Ottawa would also require bilingual labelling,  this is not so for many other areas of the country.  If the exemption is to remain, there should be a more definitive list readily available to firms.
  
• with respect to item 10: Recognition of Equivalent Identification Number Systems (page 10 of the dsicussion paper), it is unclear whether the intent is to allow this only for NAFTA countries or for all foreign systems.  Although in the preamble it says "all foreign countires....provided the registration system...is substantially equivalent....", there is subsequent mention of the work of the NAFTA Security and Prosperity Partnership which has called for "mutual acceptance".  CTI recommends that Canadian acceptance of foreign equivalent systems should be contingent on reciprocal acceptance of the Canadian system by the foreign country.  We would also like to see clear guidelines with respect to how "substantially equivalent" will be interpreted.

If you have any questions about our comments, or would like further information, please do not hesitate to contact me at 613-232-7195, ext. 111, or at the e-mail address above.

LIZ SIWICKI
President, Canadian Textiles Institute