Thank you very much, Mr. Chair.
My name is Darren Praznik and I'm president and CEO of Cosmetics Alliance Canada. We represent the cosmetics and personal care products industry in Canada.
After listening to so many of the other presenters here today, I can tell you I'm not here today to speak on many of the very important issues that they addressed. I'm here to deal with something much more mundane, which is how the act is actually implemented and carried through to encourage compliance.
I want to start off, first of all, by saying that we have been actively engaged in the CEPA process for well over a decade, since its inception. We are fully supportive of CEPA and the kind of evaluation of substances that have been in commerce and are new, which go into the products we make and others make. As other presenters have indicated, certainly a substance should be safe for both human health and the environment.
We support CEPA. We support the reform under this act. We supported it when it was introduced in the principle. Some amendments have been made that you'll be considering.
Of the amendments coming out of the Senate, the one that specifically gave us concern was clause 67.1, which calls for review of products on the basis of whether or not there was compliance with imports versus manufactured. I think it was premised on an erroneous bit of information. Products have to meet the same standard whether they're imported or manufactured in Canada. We don't think clause 67.1 really does anything, and the department of trade is not the appropriate mechanism. I've included some comments in my brief on how to make it more effective, if you choose not to eliminate it but to amend it.
The other issue I wanted to flag in my comments with respect to implementation and the encouragement of compliance—which I think everyone agrees is important—is that there are some fundamental principles and one of them is “best placed act”. I can't argue that enough, simply because when you create regulations under two sets of acts that apply to a product, whether they be on labelling or others, you create confusion. You're going to get contradictory requirements. We're already seeing some of that now. The environment department has started to create almost a second set of regulations over the Food and Drugs Act and Health Canada. It's leading to certain circumstances where things are just not working well and they're not supporting good compliance practices.
I would also like to bring to the attention of the committee, in my remaining time, that under CUSMA, these principles are recognized for cosmetics. I would flag, on page 3 of my document, four particular articles in CUSMA. One recognizes that each party under CUSMA “shall avoid adopting or maintaining unnecessarily duplicative...requirements with respect to cosmetic products”. The second is that each party shall use “a risk-based approach” for cosmetics.