Thank you, Mr. Chair.
We believe the elected MPs on the ENVI House of Commons committee are best placed to address real concerns in Bill S-5. We also believe government officials are best placed to determine the validity of the proposed amendments, ultimately. What we absolutely do not support are amendments made in haste and without substantive data supporting those amendments, amendments that go beyond the scope of the government's original bill.
Our industry supports the government's originally proposed amendments in Bill S-5. However, more clarity is needed on certain definitions and implementations. Some are impractical and not aligned with Canada's chemical assessment process as we see it.
For example, there's an unworkable chemical watch-list defaming regulated chemicals in commerce and lessening consumer confidence in all regulated products by the government. The bill limits time for robust chemical assessments that could lead to better outcomes. It identifies chemical substitutes without understanding the many technical challenges required in formulation and reformulation. There's duplicative labelling of consumer products already addressed in multiple and better-placed acts. It removes CBI protection for innovative chemistry, which precludes more sustainable alternatives or substitutes in future.
Based on years of staff working full time with technical committees, and bilateral and multilateral meetings with government on chemicals management, we understand what works. That includes how better data leads to better outcomes, and how industry and government must work together. It is much easier to oppose and condemn a mature and proven regulatory approach without substantive data, yet that is what you're being asked to do in many cases.
CEPA's chemicals management plan, or CMP, is one that is arguably better than others in the world. It is, in fact, copied in large measure by the United States, Australia, Mexico and Brazil. Brazil just announced last week that they're largely following the CMP process.
Canada's chemical assessment process is not easy. It has a very high standard for critical data required for chemicals management. It is complex, costly and very onerous. At times, it is frustrating when you lose a chemical used in hundreds of products in commerce in Canada. The process has taxed our sector greatly, with more than 1,500 substances assessed in the first three phases of the CMP of 4,200 substances. There were 525 of 1,500 in the most recent phase of CMP3.
However, we believe it is necessary. Our members support it because it is a risk-based approach to chemicals management that ensures that consumer products are safe. Our members in Canada and those exporting to Canada are mandated to provide substantive data collected over many years in sophisticated R and D facilities, countless studies, trial formulations and reformulations, etc.
It is impossible to suggest a hard stop for such a complex process that always seeks new data and better sources. It sometimes comes together at the 11th hour or past the designated timeline, but industry and government get to the assessment, get it done and—