Thank you very much, Mr. Chairman, and members of the committee, and thank you very much for giving me and my members the opportunity to have input on this very important topic.
My name is Joy Nott, and I'm the president and CEO of the Canadian Association of Importers and Exporters, otherwise known as I.E. Canada. It's a privilege to appear today to testify with respect to the March 18, 2015, announcement of support to help boost Canadian exports by providing both financial assistance for SMEs and by further funding the trade commissioner service.
I.E. Canada, the Canadian Association of Importers and Exporters, is a national trade association that's been speaking on behalf of the Canadian trade community for more than 80 years. Our members include importers, exporters, Canadian manufacturers who both import and export, wholesalers, distributors, retail importers, and supply chain service providers.
Our members employ over one million Canadians and contribute approximately $270 billion in annual revenue to the Canadian economy, which translates to approximately $40 billion in annual taxes paid federally, not including the GST and duties.
We represent some of the largest importers and exporters in Canada as well as small and medium-sized businesses. Our members import and export across most commodities and product lines.
While most trade associations focus on the policy end of lobbying, I.E. Canada has a long history of both commenting on high-level policy issues as well as actively looking into facilitating international trade at the operational level where exporters often face the largest hurdles. The phrase, while cliché, the devil is in the details, resonates to most Canadian exporters who have experienced both the best and the worst that policy has to offer once it's translated to its most basic level, operational policy.
In short, I.E. Canada is very pleased to read the announcement that was made by the Prime Minister in Mississauga on March 18. Many of the points in his announcement are welcome news to small to medium-sized exporters who are still struggling to find their export footing in a global economy that is still somewhat soft. Any help offered no matter how small is both needed and appreciated.
I would like to divide my comments today into two general sections: first, the new export market development program providing a total of $50 million over five years; and second, the additional financial support for the trade commissioner service.
While Canadian exporters face a number of different challenges when wanting to expand their sales beyond the domestic Canadian marketplace—and I'm sure that's not a surprise to anyone in this room—I would like to spend a moment, looking at what the challenges actually are and commenting on how this money might best be spent and most importantly tracked in order to help Canadian exporters in a substantial way moving forward.
Canadian exporters face challenges from both the foreign markets they seek to enter and the Canadian domestic regulatory environment they must wade through in order to be able to compliantly export product from Canada.
As an example, with the new Safe Food for Canadians Act, exporters who wish to export a product that requires a licence, for example, meat, fish, and seafood, must have a CFIA licence in order to export under the act. In order to get that licence, they must show they have implemented a preventative control plan. This preventative control plan must include, at a minimum, a fully documented product and process manual and a process to ensure traceability, recall and complaints of any product they export. Many SME exporters do not have the staff or the funds to comply with the above requirements making Canadian domestic regulation yet another hurdle they must conquer before they can actually export.
Another example would be the SME companies who deal in articles of defence, which would fall for various reasons under the U.S. international traffic in arms regulations, otherwise known as the ITAR. In order to be able to handle goods that fall under this regulatory umbrella, of which many defence articles that float through the North American supply chain do, the SME must not only work with Public Works and Government Services Canada to register for the controlled goods program, which would make them subject to numerous record-keeping and audit requirements, but on top of that they would have to deal with the Department of Foreign Affairs, Trade and Development to obtain any export permits that are required when exporting to countries other than the United States.
While the above two examples are not a comprehensive list of domestic export hurdles facing SMEs, we must be clear that the reasons behind these regulations may be valid and may be required in order to keep Canadians and our trading partners safe. We understand that.
The scope and the minutiae, however, of some of the requirements can really bog down SMEs that simply don't have the in-house expertise to either understand all the rules or to set themselves up in such a way that they can successfully comply with the rules while simultaneously thriving in a competitive export sales environment.
While there are many programs and attempts to make exporting both easier and more appealing to Canadian SMEs, there seems to be a gap in that no single body oversees the export regulatory regime. There is no government export ombudsman, for lack of a better term. We believe there should be one checkpoint through which all government agencies that wish to apply any sort of requirement on exporters should have to go, to explain and prove why another regulatory requirement needs to be placed on exporters, before any new regulation or legislation is passed.
DFATD should be tasked with maintaining some sort of an inventory of all these export-focused regulations, and working with the red tape reduction initiative to streamline and remove domestic barriers wherever possible.
With respect to foreign market barriers, I'm sure it's no surprise to anyone here that another major hurdle faced by Canadian exporters is the regulatory environment in the country of import. Challenges range from non-tariff trade barriers meant to discourage importers into the foreign market to government websites with vitally needed regulatory information available only in languages other than English or French. These sorts of barriers, while often expected and impossible to avoid, result in the Canadian SMEs having to hire subject matter experts in the foreign market to help them understand what must be done in order for their products to successfully enter that market.
The trade commissioner service does a wonderful job of helping Canadian SMEs find local lawyers, customs brokers, tax accountants, and other trade and subject matter experts to help them negotiate and navigate the new market and its complex rules. While the trade commissioner service's assistance is helpful, it takes money to engage these experts. Depending on the complexity of the goods being exported, these professional service fees can add up to relatively significant amounts fairly quickly.
We are pleased to see a recognition that SME exporters require financing, which they often cannot find through mainstream financial lending streams. They need funding to help them hire subject matter experts so that they can wade through either the domestic regulatory environment or the foreign regulatory environment. One recommendation we would make with regard to this program is that metrics be kept to track how much of the $50 million is spent helping Canadians work through domestic programs, and that those efforts be directly linked to the red tape reduction initiative and the DFATD export regulation inventory mentioned earlier.
Moving on now to the additional financial support for the trade commissioner service, we would like to make a few comments relative to the service overall. For starters, the trade commissioner service is one of the best-kept secrets of the Canadian government. While we see television commercials and other media highlighting all sorts of government services available to Canadians, there's rarely any mention of the Canadian trade commissioner service to explain what they do and how they can help SMEs, and in fact all Canadian exporters. We would strongly suggest that better marketing around the services available to SMEs be undertaken.
The Honourable Minister Fast has said on various occasions that historical trade agreements require historical trade promotions, and we agree that's true. In recent months Canada has implemented or negotiated some of the most important trade deals in Canadian history. The programs announced on March 18 are headed in the right direction to take negotiated deals and turn them into economic growth for Canada.
Persuading SMEs that their businesses are big enough or important enough to actually consider exporting is a different matter. In a rapidly changing and evolving world of international trade, strategies and solutions that worked as recently as 10 years ago may be sorely out of step with the new reality that Canadian exporters of all sizes face. The Internet has levelled the playing field globally, so the ways in which we position our exporters and the tools we as Canadians provide them have to be ahead of the curve to strategically place our exporters in a favourable position.
If we want to pull ahead in the global foot race in which every country in the world that trades is taking part and truly give Canadian SMEs an edge when entering these markets, we should consider working more in tune with the host country and its focus on exporting its products and services to Canada to identify mutually beneficial opportunities.
Formally and openly accepting the fact that signing trade deals means goods will be imported into Canada can be used as a strategic advantage as opposed to merely being seen as a lag on key economic factors. Strategically choosing which imports we facilitate in exchange for being able to target exports is a sound business strategy that should be in place along with a government strategy. Our goal as a country should be to plug into global supply chains, which often means exporting but does not relate exclusively to exporting.
Sometimes in order to be plugged in globally, we must import into Canada. DFATD's own statistics indicate that 48% of Canadian exporters must import in order to be able to execute their exports, but still our trade strategies only involve promoting exports and disregard how we can use imports.
I'll just wrap up by saying that we have an opportunity to use our Canadianness and the fact that we are known around the world. We sew flags on our knapsacks when we travel around the world and we're proud of saying that we're Canadian. We're known as being friendly and easy to deal with, and I think we have an opportunity to use our Canadianness to engage our trading partners in ways other countries don't.
With that, I will wrap up.