Comments from: Commissioner of Official Languages

(PDF: 186 KB)

MAR 27 2007
Our ref.: 1235-1
ClTS (WebCIMS) No.: 71067

Mrs. Carole Gaetz
Competition Law Officer
Competition Bureau
2000 - 300 West Georgia Street
Vancouver, British Columbia V6B 6E1

Dear Mrs Gaetz:

At your request, I am writing in order to share with you my comments on the Discussion Paper provided to me with respect to proposed amendments to the Textile Labelling and Advertising Regulations (TLAR). Given the scope and nature of my mandate, I will limit my comments to those proposed modifications that appear, to my view, to raise issues pertaining to the status and use of the official languages of Canada.

My office was consulted by representatives of the Competition Bureau in October 2004 and put forward its recommendations with respect to a proposed amendment to Paragraph 11 (4) of the TLAR in light of the recommendations of the Standing Joint Committee for the Scrutiny of Regulations (SJCSR).

As my predecessor had outlined in a letter to Mr. Jay Jackson, Senior Competition Law Officer, in 2004, the current wording of section 11 of the TLAR could conceivably be viewed as inconsistent with the duties set out in section 26 of the Official Languages Act (OLA). Accordingly, I am pleased to note that the Competition Bureau is proposing that the current exemptions from bilingual labelling be removed and I endorse the recommendation of the SJCSR to this effect.

I would endorse the proposed amendment that would see the revocation of subsections 11 (4) and (5) of the TLAR thus removing the existing exemption from bilingual labelling. By repealing subsections 11 (4) and (5) of the TLAR, the Competition Bureau would be, in my opinion, respecting its obligation set out at section 26 of the OLA.

I am confident that, as the studies my office has conducted in the past demonstrate, Canadian businesses - regardless of their size - recognize that the value of being able to reach the entire Canadian market far outweighs the costs associated with bilingual textile labelling, particularly where the health and safety of the public is involved. Furthermore, please note that I also endorse all the proposed changes outlined in the Discussion Paper provided to me that seek to ensure a greater consistency between the French and English versions of the TLAR.

I thank you for seeking my opinion on this matter. My staff will monitor the progress of this file and I look forward to learning of the implementation of the proposed regulatory amendments. The French version of this letter is enclosed for the convenience of your staff.

Yours sincerely,
Graham Fraser
Encl.