Canada—United Kingdom Trade Continuity Agreement Implementation Act

An Act to implement the Agreement on Trade Continuity between Canada and the United Kingdom of Great Britain and Northern Ireland

This bill is from the 43rd Parliament, 2nd session, which ended in August 2021.

Sponsor

Mary Ng  Liberal

Status

This bill has received Royal Assent and is now law.

Summary

This is from the published bill.

This enactment implements the Agreement on Trade Continuity between Canada and the United Kingdom of Great Britain and Northern Ireland.
The general provisions of the enactment set out rules of interpretation and specify that no recourse is to be taken on the basis of sections 10 to 15 or any order made under those sections, or on the basis of the provisions of the Agreement, without the consent of the Attorney General of Canada.
Part 1 approves the Agreement, provides for the payment by Canada of its share of the expenditures associated with the operation of the institutional and administrative aspects of the Agreement and gives the Governor in Council the power to make orders in accordance with the Agreement.
Part 2 amends certain Acts to bring them into conformity with Canada’s obligations under the Agreement and contains a transitional provision.
Part 3 contains a coordinating amendment and the coming-into-force provision.

Elsewhere

All sorts of information on this bill is available at LEGISinfo, an excellent resource from the Library of Parliament. You can also read the full text of the bill.

Bill numbers are reused for different bills each new session. Perhaps you were looking for one of these other C-18s:

C-18 (2022) Law Online News Act
C-18 (2020) Law Appropriation Act No. 2, 2020-21
C-18 (2016) Law An Act to amend the Rouge National Urban Park Act, the Parks Canada Agency Act and the Canada National Parks Act
C-18 (2013) Law Agricultural Growth Act
C-18 (2011) Law Marketing Freedom for Grain Farmers Act
C-18 (2010) Increasing Voter Participation Act

Votes

March 10, 2021 Passed 3rd reading and adoption of Bill C-18, An Act to implement the Agreement on Trade Continuity between Canada and the United Kingdom of Great Britain and Northern Ireland
Feb. 1, 2021 Passed 2nd reading of Bill C-18, An Act to implement the Agreement on Trade Continuity between Canada and the United Kingdom of Great Britain and Northern Ireland

Canada-United Kingdom Trade Continuity Agreement Implementation ActGovernment Orders

January 28th, 2021 / 11:10 a.m.

Outremont Québec

Liberal

Rachel Bendayan LiberalParliamentary Secretary to the Minister of Small Business

Mr. Speaker, allow me very clearly and on the record thank the former minister of trade for the work he has done, particularly with respect to CETA, which is a very good agreement, good for Canada and good for Canadian exporters. I hope he agrees.

That is perhaps one of the reasons why I find it perplexing to suggest that successfully transitioning the very favourable provisions of CETA into a transitional agreement with the United Kingdom appears to have disappointed him. CETA is a good agreement and the transitional agreement replicating CETA is good for our Canadian exporters.

Does my colleague agree?

Canada-United Kingdom Trade Continuity Agreement Implementation ActGovernment Orders

January 28th, 2021 / 11:10 a.m.

Conservative

Ed Fast Conservative Abbotsford, BC

Mr. Speaker, I do not fully agree with her assertion, but I do agree with her that CETA was a groundbreaking agreement and has benefited Canada and the European Union.

However, the delays caused by the Liberal government meant that we could not negotiate an even more ambitious agreement with the U.K. Circumstances are at play in the Canada-U.K. relationship that make it a perfect opportunity for Canada to expand things like mobility of people, investment opportunities among our countries and regulatory co-operation and the mutual recognition of credentials, something that is much more difficult to do when we are dealing with the 27 countries of the European Union rather than the U.K., with which we share many values and many common social and economic characteristics.

Canada-United Kingdom Trade Continuity Agreement Implementation ActGovernment Orders

January 28th, 2021 / 11:10 a.m.

Bloc

Mario Simard Bloc Jonquière, QC

Mr. Speaker, there was a question asked earlier that has remained unanswered. Perhaps my colleague could enlighten me on the matter.

Specifically in the context of CUSMA, we ran into a problem when aluminum was left without any protection. Perhaps the best solution is to ensure that Quebec is at the table during these kinds of negotiations to advocate for its own economic interests—and we will see this next year, since this is a temporary agreement.

Would my colleague agree that the provinces should play a larger role in the negotiation process and that this should be formalized going forward?

Canada-United Kingdom Trade Continuity Agreement Implementation ActGovernment Orders

January 28th, 2021 / 11:15 a.m.

Conservative

Ed Fast Conservative Abbotsford, BC

Mr. Speaker, I certainly agree with my colleague that Quebec has a very special interest in Canada's trade negotiations, and I can only speak from my own experience negotiating the trade agreement between Canada and the European Union where Quebec was a key integral part of our negotiating team. In fact, a lot of Canadians do not realize that Quebec is among the most pro-trade-oriented provinces in our federation.

Quebec understands trade and our previous Conservative government always consulted significantly with Quebec. That is why Quebec was always able to support our efforts to negotiate things like CETA, agreements like the TPP, agreements like our trade agreements with Peru, Colombia, Jordan and other countries around the world. The key is collaboration. If we do not get that right, we will get an agreement that does not reflect the best economic interests of Canadians. We want to ensure we always focus on the economic interests of Canadians.

Canada-United Kingdom Trade Continuity Agreement Implementation ActGovernment Orders

January 28th, 2021 / 11:15 a.m.

Conservative

Cathay Wagantall Conservative Yorkton—Melville, SK

Mr. Speaker, I always appreciate anything my colleague shares in the House and his incredible work on trade on behalf of Canada.

He spoke about our relationship with the CPTPP and how important it would be to have the U.K. engaged in that well. The government talks about a whole-of-government approach. In this case, when it comes to trade, what I am hearing is that we need a whole-of-the-world approach.

I would like to hear a little more from him with regard to the impact Canada could have on the U.K. participating in that way.

Canada-United Kingdom Trade Continuity Agreement Implementation ActGovernment Orders

January 28th, 2021 / 11:15 a.m.

Conservative

Ed Fast Conservative Abbotsford, BC

Mr. Speaker, that is an excellent question. Because Canada and the U.K. are among the most trusted trade partners in the world, it is absolutely imperative that we find opportunities to promote our trade interests beyond our bilateral agreement. That is why I am very supportive, personally, of the U.K.'s interest in joining the CPTPP.

Sadly, the World Trade Organization has floundered badly. Its adjudicative powers, effectively, were emasculated by the administration of Donald Trump, so we do not have a robust global system of rules-based trade, which is why a lot of countries over the years have resorted to bilateral and plurilateral agreements such as CETA, the agreement we are debating today and the CPTPP.

I very strongly promote opportunities to take our trade agreements and use them as vehicles to promote freer and fairer trade all around the world, because Canada is among the best countries in the world at doing this.

Canada-United Kingdom Trade Continuity Agreement Implementation ActGovernment Orders

January 28th, 2021 / 11:15 a.m.

Bloc

Simon-Pierre Savard-Tremblay Bloc Saint-Hyacinthe—Bagot, QC

Mr. Speaker, I am very pleased to rise today as the Bloc Québécois critic for international trade and speak about the Canada-U.K. trade continuity agreement, or CUKTCA.

CUKTCA seeks to ensure that the flow of trade between Canada and the United Kingdom remains unimpeded. Let us remember that Canada and the European Union are bound by a free trade agreement, the Comprehensive Economic and Trade Agreement, or CETA, and that the United Kingdom's decision to leave the European Union put an end to the provisions that connected London and Ottawa.

I will divide my speech into three parts. First, I will address the serious problem with the transparency of the negotiation process. Next, I will talk about the agreement itself and, finally, I will close by talking about the real meaning of Brexit from a historical perspective and about the precedent it sets with respect to Quebec.

First, let us talk about transparency. Members of the Standing Committee on International Trade discussed the transitional trade agreement with the parties directly involved without any documents whatsoever. It was truly a theatre of the absurd. We were asked to study the agreement without access to its content. We received witnesses who offered comments and recommendations on the agreement, but we had no real information on the content of the agreement. We were only told that the deadline was fast approaching and that we had to adopt the agreement by December 31.

We might also say that we were asked to give the government carte blanche, even though it sacrificed supply management on three occasions and in the latest free trade negotiations it abandoned Quebec's key sectors, like aluminum and softwood lumber. That is why we are reluctant to blindly trust the government.

In fact, the committee had to submit its report on the transitional agreement on the very day we received the text of the agreement and before we even had a chance to read it. The Bloc Québécois was very clear on the fact that we would not just stamp an agreement without reading it or having the time to study and analyze it, in other words, without being able to do our job as parliamentarians.

The members of the House of Commons are responsible for defending the interests and values of their constituents, but they are being forced to approve agreements at the end of a process in which they have no real say, despite the efforts of the Bloc Québécois, which tabled a number of bills regarding this matter between 2000 and 2004.

Under the 2020 agreement between the Liberal Party and the NDP, the Deputy Prime Minister undertook to provide more information to MPs, and that is a step in the right direction. However, as the recent agreement showed, it is clearly inadequate.

We need mechanisms to involve parliamentarians and the provinces in the next round of talks. It is vital for the government to keep parliamentarians informed every step of the way. Requiring this would reduce the risk of parliamentarians having to voice their opinions on agreements without having all the necessary information to make an informed decision. This would make the negotiation process more transparent.

The Bloc Québécois is calling for Parliament to adopt procedures that would increase democratic control over agreements. The minister responsible for ratifying an agreement should be required to table it in Parliament together with an explanatory memorandum within a reasonable period of time. Parliament's approval should be required before any agreement can be ratified.

Quebec was allowed to send a representative to the negotiations with Europe in the lead-up to the ratification of CETA between Canada and the European Union in 2017. However, it was the European Union, not Canada, that wanted Quebec there. Quebec has not had this opportunity again, but it should.

We believe that Quebec and the provinces must be invited to the bargaining table, since they have official standing to block an agreement that would interfere with their jurisdictions. Quebec's jurisdictions extend beyond its borders, as the Privy Council in London acknowledged decades ago in a decision that led Quebec to adopt the Gérin-Lajoie doctrine.

Of course, it is not a perfect system.

During the CETA negotiations, Quebec's representative said that Quebec's delegation was there to be a cheerleader for the Canadian delegation and its actions essentially amounted to backroom diplomacy. In other words, Quebec's role mattered, but not at the table where decisions were being made.

The only way Quebec will be able to advocate for itself on the world stage is by gaining independence. The Canadian negotiator will always be predisposed to protect Canada's economic sectors at the expense of Quebec's.

Now I want to talk about the agreement. I remind members that international trade has played a huge part in modernizing Quebec's economy. We made a strategic choice that gave SMEs access to new markets, most importantly the U.S. market, of course, which allowed us to break our total dependence on Canada's trade and economic framework.

The Bloc Québécois fully subscribes to the idea that free trade is necessary, but we do not mistake politics for religion. If a free trade agreement threatens Quebec in any way, we will not hold back from pointing out its biggest flaws and speaking out against them. We believe that the environment, public health, agriculture, culture, first nations, workers and social services must never be treated like commercial goods. We also believe that nothing justifies giving up our sovereignty for the benefit of multinationals.

What does this mean for the Canada-United Kingdom Trade Continuity Agreement, or CUKTCA? I will start with some background. There are already a number of trade agreements and treaties between Canada and the U.K., both with and without the European Union. The United Kingdom is Canada's biggest European trading partner, but let us put things in perspective. Investment and imports and exports of goods and services between Canada and the U.K. actually represent a relatively small percentage of each country's economy. Still, the United Kingdom is an important partner.

Ontario is the most affected province because it exports unwrought gold. That sector accounts for more than 80% of Ontario's exports to the United Kingdom. The U.K. imports a lot of cars and pharmaceuticals from Ontario, but their significance in the U.K. economy is fairly limited.

The United Kingdom is Quebec's second-largest trading partner. However, imports and exports of goods with the United Kingdom have been declining for the past 20 years. The U.K. now accounts for only 1% of Quebec's total exports and 3.5% of Quebec's total imports. In other words, Quebec has a trade deficit with the United Kingdom.

One sector that is really important is the aerospace industry, which provides the most stable trade between Quebec and the United Kingdom. Our aerospace sector is both a customer of and supplier to the United Kingdom, so maintaining that trade relationship is crucial for this strategic industry, which is struggling. Many research partnerships have been established, and the industry welcomes the idea of an agreement. Of course, the aerospace sector needs a proper aerospace policy, and we continue to fight for that in the House. This agreement is good for our aerospace sector, which in itself is a good enough reason for us to support it at this time.

Our personal financial services sector and our engineering firms may also benefit, since investments in infrastructure could explode in a post-Brexit United Kingdom.

Other reasons we welcome this agreement include the fact that the investor-state dispute settlement mechanism will not apply immediately. This mechanism allows a foreign multinational to take a country where it has invested to an arbitration tribunal if a policy or law made by that country impinges on its ability to make a profit. Any law intended to protect the environment or to enhance social justice or worker protections could be targeted. This upends democracy by giving multinationals sovereign powers. We are against that.

Under the CUKTCA, this mechanism would not come into force until at least three years after the agreement has been adopted, on condition that the mechanism is in effect under CETA, which is to say it will not happen. Since Canada and the United Kingdom are supposed to start negotiations this year to conclude a permanent agreement, we can say that it will likely not come into force.

Nevertheless, that should not be one of the items that Canada will defend when negotiating the permanent agreement. The Bloc opposes it and will stand firm against it. I moved a motion to study this mechanism at the Standing Committee on International Trade, and it was adopted. We should be studying it relatively soon. I truly hope that we will never again include this mechanism, which was removed from the Canada-United States-Mexico Agreement last year. In this case, Canada and the United Kingdom are western democracies with well-developed legal systems. There is therefore no reason that differences between a foreign investor and a host country cannot be decided within the existing legal system.

There is also the thorny issue of supply management. We support the pure and simple, ironclad protection of supply management, and therefore the preliminary exclusion of agriculture from the negotiating table, except for the sectors that would find it advantageous and would specifically ask to be included. CETA, the Comprehensive Economic and Trade Agreement, was detrimental to our agricultural model, and it caused real losses to our farmers. We would not have agreed to give up additional market share in the CUKTCA, the Canada-UK Trade Continuity Agreement.

Fortunately CUKTCA does not include such provisions. The United Kingdom was not granted additional market access for cheese or other supply-managed products. However, some testimony during meetings of the Standing Committee on International Trade suggested that British cheese producers were pushing for more exports to Canada. In all likelihood, this problem will be put off until next year, new breaches in our agricultural model will be on the table in final negotiations, and London will put those demands at the top of the list. This is timely, because the Bloc introduced a bill to prohibit any future breaches in supply management. The House needs to walk the talk, so I hope it will pass the bill.

I now want to talk about local products. From the beginning of the pandemic, for several months now, people have been singing the praises of buying local, which is great. We need to practise some degree of economic nationalism, which comes more naturally for Quebec than it does for Canada.

Under CETA, Quebec lost a large share of the Canadian content requirement in the procurement of public transit vehicles. In the past, an agreement between the Government of Quebec and the Société de transport de Montréal required that 60% of the content in the city's subways and buses be Canadian. CETA now stipulates a local content requirement of no more than 25% in Quebec and Ontario, simply because of a grandfather clause. What is more, Quebec can also require that the final assembly take place in Canada. The other provinces are not included in that provision because they do not have any provincial legislation to that effect. The local content requirement of 25% under the grandfather clause is a step backward, but it could have been much worse had Quebec not been at the CETA discussion table.

The same provision is included in CUKTCA simply because it was copied and pasted from CETA. It is pretty clear that this will not be one of Canada's priorities in future rounds of negotiations for the permanent agreement, which once again shows the fundamental importance of inviting Quebec to the negotiating table.

The agreement aside, Quebec and its plan for independence can learn some lessons from the process itself. Of course, the United Kingdom and Quebec are in very different situations. Every U.K. citizen is free to praise or condemn Brexit. They are free to vote as they wish. The fact remains that Brexit is a historical first. We are talking about a state that left a customs union to which it belonged and is therefore no longer part of certain trade agreements. In that regard, the U.K.'s situation is similar to that of Quebec. Opponents to the plan, who have always played on economic fears, say that Quebec would not have enough public funds and that it is better off giving its money to Ottawa or spending it on the monarchy.

As for trade, we were told that Quebec would not automatically be a member of agreements signed by Canada, which would mean a blank slate and starting from scratch with trading partners. However, those trading partners would have no desire to cut ties with Quebec.

What guarantees are there with respect to treaties? Some time ago, a constitutional expert named Daniel Turp, a former member of the House of Commons and the National Assembly of Quebec, explained that countries would presume continuity if the new country expressed its desire to maintain the relationship in a given treaty. Mr. Turp's thesis focused on multilateral agreements, however. The jury was still out on trade agreements.

The only precedent for trade agreements dates back to 1973, when Bangladesh seceded from Pakistan and became independent. Pakistan was bound by the General Agreement on Tariffs and Trade, better known as GATT, and Bangladesh automatically became a member from one day to the next. However, GATT was a multilateral treaty that did not need to be renegotiated to admit a new member. What would happen with a bilateral treaty? That is the question the British are answering now.

To sum up, Canada has already signed an agreement with the European Union, namely CETA. To ensure that the U.K.'s departure from the EU does not leave a void in relations between London and Ottawa, an interim agreement is being reached very quickly between the two countries, one that incorporates the content of CETA and will remain in force in the short term until both partners renegotiate a permanent agreement, thereby ensuring stability until then.

Brexit is showing Quebec the way forward when a trading nation achieves or reclaims its sovereignty. A newly independent Quebec would of course emulate this approach and quickly reach interim agreements to ensure that our businesses have access to markets while waiting for permanent agreements to be renegotiated with our partners.

Far from being caught off guard, the United Kingdom has already signed trade deals with 60 of the 70 countries the EU had deals with. One could say, then, that the U.K. was definitely not caught with its pants down, if you pardon me the expression. It even has an agreement with Japan now, where the EU had no such agreement.

Because they are provisional, transitional arrangements do not preclude newly independent countries from going back to the negotiating table, preferably sooner rather than later. Is there a fundamental problem in renegotiating what someone else has already negotiated for us? That is what the United Kingdom is going to do with Canada this year. If we did that too, we could support sectors that are important to Quebec, such as agriculture, aluminum and lumber. Indeed, there are many more advantages than disadvantages to defending only one's own interests at the negotiating table.

The Brits and Canadians are therefore quite unwittingly overlooking an argument that is often repeated to argue against Quebec independence. When it comes to trade sovereignty, if Brexit has given us a sneak preview of “Québexit”, why not go for it?

Canada-United Kingdom Trade Continuity Agreement Implementation ActGovernment Orders

January 28th, 2021 / 11:35 a.m.

Conservative

Cathay Wagantall Conservative Yorkton—Melville, SK

Mr. Speaker, I appreciated hearing everything the member said. We have a lot to work through as a country in dealing with trade. I appreciate his concerns; I truly do.

The Liberal government calls this a transitional agreement, yet there is no end date and no penalty for not moving forward with negotiations or not getting a new agreement finalized.

Does the member have any concerns about the misconception of calling this a transitional agreement?

Canada-United Kingdom Trade Continuity Agreement Implementation ActGovernment Orders

January 28th, 2021 / 11:35 a.m.

Bloc

Simon-Pierre Savard-Tremblay Bloc Saint-Hyacinthe—Bagot, QC

Mr. Speaker, I thank my colleague for the question.

That just adds to the absurdity of it all. Before the holidays, we were asked to study an agreement without access to the document. We were told that it was just transitional. To say that is to minimize the importance of it. We were told to adopt it before December 31, that it was urgent. Fortunately, that did not happen. We were firm on this. However, there is no firm commitment to go back to the bargaining table. Of course, that is a problem. I share my colleague's concerns on that.

Canada-United Kingdom Trade Continuity Agreement Implementation ActGovernment Orders

January 28th, 2021 / 11:35 a.m.

Liberal

Mark Gerretsen Liberal Kingston and the Islands, ON

Mr. Speaker, unlike my Conservative colleague who just asked a question, I do not appreciate the comments the member made, especially those toward the end of his speech when he talked about reasons for Quebec being its own country. I realize that is one of the main objectives of the Bloc, but the reality of the situation is that Canada is as great as it is because of all the partners here. It is as great as it is because Quebec is part of it. I, for one, certainly never want to see us even talk about going down that road, especially at a time like this when we are getting through a pandemic.

Although the nature of these agreements always puts us in a position where negotiating seems to conflict with our ability to discuss them in the House, this trade agreement is a good thing for all of Canada. It is a good thing for Quebec. It is a good thing for Ontario. It is a good thing for Alberta and B.C. It is good for the entire country. It is an opportunity for us to come out of this pandemic and grow our economy so we can recover in a meaningful way.

Canada-United Kingdom Trade Continuity Agreement Implementation ActGovernment Orders

January 28th, 2021 / 11:40 a.m.

Bloc

Simon-Pierre Savard-Tremblay Bloc Saint-Hyacinthe—Bagot, QC

Mr. Speaker, my goodness, I do not know where to begin. I was talking about all the benefits of the agreement and I said that it was very good for Quebec. I do not see what more I could add.

Canada is a great country. Quebec will be a very great country as well. I must admit that I do not understand my colleague's arguments at all. I find it funny to hear him note that the Bloc Québécois is in favour of Quebec's independence. It is about time my colleague figured that out. The Bloc Québécois has been around for 30 years. I invite my colleague to consider a career as an investigative journalist.

Canada-United Kingdom Trade Continuity Agreement Implementation ActGovernment Orders

January 28th, 2021 / 11:40 a.m.

NDP

Alexandre Boulerice NDP Rosemont—La Petite-Patrie, QC

Mr. Speaker, I thank my colleague for his speech. I would like to say that his last comment made me laugh.

In my opinion, the free trade agreement with the United Kingdom demonstrates that instead of learning from their mistakes, the Liberals are repeating them. The NDP shares the concerns about protecting supply management, which we defended tooth and nail. Former MPs Brigitte Sansoucy and Ruth Ellen Brosseau, in particular, vigorously defended it.

I would like to talk about two other things.

Our dispute resolution mechanism allows investors and large corporations to take advantage of us. It undermines our democracy and the representation of our citizens. Under the free trade agreement with the European Union, Quebeckers and Canadians will pay more for prescription drugs. In my opinion, in a health crisis, it is truly ridiculous to make the same mistake and accept an agreement that will increase the cost of drugs that sick people need.

I would like to hear what he has to say about that.

Canada-United Kingdom Trade Continuity Agreement Implementation ActGovernment Orders

January 28th, 2021 / 11:40 a.m.

Bloc

Simon-Pierre Savard-Tremblay Bloc Saint-Hyacinthe—Bagot, QC

Mr. Speaker, I thank the member for Rosemont—La Petite-Patrie for his question. I also thank him for his ongoing support of supply management.

If the investor-state dispute settlement system were implemented immediately, I would have been much harsher. However, since the process is fraught with challenges, we might as well say that will not happen with this agreement.

As I mentioned earlier, the CETA countries must absolutely agree on the terms and conditions of a mechanism. That is by no means certain. Since it could take three years, we can imagine that a permanent agreement will be renegotiated before that. The road ahead is fraught with challenges.

With respect to drugs, the price increase will not be immediate. We obviously share my colleague's concern on this matter. When the agreement is implemented in a few years, we will need a compensation program and Ottawa will need a program to compensate those who will bear the brunt of the hike in drug prices. We agree on principle that it makes no sense to hike drug prices in the middle of a pandemic.

Canada-United Kingdom Trade Continuity Agreement Implementation ActGovernment Orders

January 28th, 2021 / 11:40 a.m.

Bloc

Louise Charbonneau Bloc Trois-Rivières, QC

Mr. Speaker, I thank my colleague for his enlightening speech on the CUKTCA. He knows this topic well.

Could the member talk more specifically about how milk producers will be affected and about how the United Kingdom will continue to be able to send its cheeses here until 2023? I would like to hear his thoughts on that provision in the agreement.

Canada-United Kingdom Trade Continuity Agreement Implementation ActGovernment Orders

January 28th, 2021 / 11:40 a.m.

Bloc

Simon-Pierre Savard-Tremblay Bloc Saint-Hyacinthe—Bagot, QC

Mr. Speaker, I thank my colleague from Trois-Rivières.

Current cheese exports are based on quotas given up in the agreement with Europe. After that, there was an agreement between Europe and the U.K. about previously allocated quota. It is a step backward, but that is because of the previous agreement.

There is no additional step backward in this agreement. That is one reason we are supporting it at this stage. Even the slightest step backward would have been grounds for us to oppose it. The agricultural model is much too important to be sacrificed even a little bit. We have been very clear about that.

This is only putting the problem off until later, though. We know British exporters want more, which means the problem will probably surface again in a year. London will fight for it during the next round of negotiations, which is why we need to pass the Bloc's bill banning any further breaches in supply management.