Thank you, Madam Chair and members of the committee.
As chairman of the Canadian Toy Association, I appreciate this opportunity to help advance our shared goal of improving toy safety by addressing Bill C-6, an act respecting the safety of consumer products. With me, also from the Canadian Toy Association, is Arthur Kazianis, who will assist in answering members' questions this evening.
The Canadian Toy Association's 110 members are manufacturers, importers, and distributors of toys, generating about $1.8 billion of annual retail sales in Canada. Although the Canadian industry is large, our core members are actually smaller Canadian businesses.
CTA's members are vitally concerned about toy safety. Since recalls by some large multinational toy companies two years ago, our members have worked hard to further enhance toy safety. Toy manufacturers have increased their investment in safety throughout the product development process, including the evaluation of product designs and testing prototypes throughout the manufacturing process. This includes testing raw materials, preproduction samples, in-process goods, and finished products. Toy manufacturers also audit the compliance of their vendors and suppliers, ensuring that they are following safety procedures.
There is consensus among experts that this focus on safety throughout the product development process is the best way to ensure safety. These measures have greatly improved our members' ability to ensure toy safety in a global economy. Apart from these private initiatives, CTA recognizes that the government can further advance our mutual goal of enhanced toy safety. CTA accordingly supports the government's initiative to update Canada's consumer product safety law, and we welcome this opportunity to work with the government and Health Canada.
I would like to emphasize that this legislation will be guiding the government and stakeholders for many years to come, and we therefore urge the committee to take its time while reviewing this bill to avoid any unintended consequences. There are many significant issues within this bill that will impact Canadian businesses.
There are three areas in which CTA thinks Bill C-6 could be improved: the reporting of incidents; preservation of confidential business information; increased alignment of international safety standards and procedures.
As to incident reporting obligations, we recognize that genuine safety issues must be reported to the government in a timely manner. At the same time, our members receive and carefully analyze thousands of reports from consumers each year, the vast majority of which do not raise genuine safety issues. It is important to ensure that the government is promptly notified of safety issues without causing the toy industry to flood the government with every report from consumers around the world.
We have discussed this issue with Health Canada, which recognizes this need for balance. However, CTA believes that Bill C-6 itself should at least provide clear guidance to better inform Health Canada's implementation.
As to preserving confidential business information, Health Canada unquestionably must have the power to disclose information as necessary to protect consumers from danger. At the same time, publication of unsubstantiated consumer reports that have not been investigated properly may give rise to false alarms. This could corrode the credibility of Health Canada and create unnecessary anxiety, or even panic, among consumers. It could also seriously damage good toy companies that have spent years building their reputation.
We urge that Bill C-6 be amended to make clearer the scope of commercial information the minister could disclose, and to require the government to notify a company if and when its confidential information is going to be released.
As to the alignment of international safety standards, the toy industry operates in a global economy. Aligning international safety standards and procedures, which often address the same issues, would benefit regulators, industry, and Canadians. It would eliminate the need to duplicate toy testing where the tests are only slightly different. It would facilitate trade and reduce costs to consumers, and it would enable closer cooperation and enforcement by Health Canada and its counterparts around the world.
Indeed, increased alignment of international standards is an explicit goal of Health Canada. For example, one of the objectives in the 2005 memorandum of understanding between the United States and Health Canada regarding consumer product safety is to make our standard-related measures as compatible as feasible.
While there are many different voluntary and mandatory safety standards for toys, the standards established by the respected International Organization for Standardization, commonly known as ISO, have been adopted in more countries around the world than any other. Even those countries that have set their own standards have turned to variations on the ISO standards. The European Union has largely adopted a variation of those standards, and the United States has recently implemented standards that closely track to the ISO standards as well.
CTA and its members urge Canada to take advantage of the experience reflected in standards already adopted by other countries. Canada, of course, must be free to adopt its own different standards to the extent necessary to protect its youngest citizens, but in light of the advantages of aligning international standards, departures from accepted existing standards should be the exception rather than the rule.
Madam Chair, in summary, the CTA applauds these efforts and supports the principles in Bill C-6. Again, we urge the committee to take its time while reviewing this bill to avoid any unintended consequences.
As we go forward, we want to work with the government to refine and improve the bill in the three areas I mentioned.
First, we request the clarification of reporting objectives. We want to ensure that Health Canada obtains the information it needs to protect consumers but does not, at the same time, create a crippling volume of consumer reports that do not reflect a safety issue.
Second, we request that Bill C-6 ensures that confidential business information is released publicly only to the extent necessary to address a genuine safety risk, and that advance notice be provided to the affected businesses.
Third, we believe Canadian consumers and companies, as well as the government, would benefit greatly from increased alignment with international safety standards and procedures. At the same time, we must preserve our ability to depart from international standards where it is necessary to do so.
On behalf of the CTA members, I want to thank you, Madam Chair, and the other members of the committee for the opportunity to speak here today on a matter that is vitally important to all of us, particularly the CTA and its members.
Arthur and I would be pleased to respond to members' questions at the end.
Thank you.