• Specify responsibilities by industry role and product types. The primary record keeping responsibility should be on the company first placing the product on the Canadian market—either a domestic manufacturer or an importer of any type of composite wood product. Under language proposed by The Right Reg Coalition, the government would have the ability, through normal commercial transactions, to trace a product being sold at retail to copies of records kept on Canadian soil at the point of manufacturing or importing.

​​

• Add “reasonable precautions” to all company’s responsibilities. The Right Reg proposed rewriting Sections 26-30.  Our recommended language eliminates potential stakeholder confusion and clarifies responsibilities and provides the Government with an established mechanism of enforcement, all without increasing the administrative burden on small Canadian businesses 

​​

• Completely reject the suggested “Attestation” system. This proposal, while well intended, would actually significantly increase the burden on Laminators and Retailers, most of whom are small businesses, to assume responsibility for a complex supply chain which can extend several companies back. 

​​

• Request a change to Section 19. The Right Reg requests the supervision of the third party certifier in the creation of the Declaration of Certification and requesting the recognition of a TSCA Title VI certificate as acceptable will align with current best practices in the industry as companies are used to reviewing and collecting that document.

​

Review the entire submission here.