Probably the best way for me to answer that is by saying that when we do an audit we look at what the process in place is. We're not really looking at whether there should be more or fewer line items. That's the policy side of things. It's for the government to decide how they want to apply the whole tariff rate.
Our bigger issue is that a system exists on paper that says how tariffs are going to be applied, but then the organizations can't actually make sure that this system is working in practice. That's probably a significant irritant for Canadian businesses. They think they are working under one set of rules, but if that set of rules isn't actually applied the way it's written on paper, it causes them frustration.
As to the overall question of efficiency, we touched on it in a couple of places in the report. One was a case in which the agency, I believe, said that it costs them more to apply the $20 threshold than they actually collect. I think that essentially is the case up to a threshold of $200: it costs more to apply the rules than they collect. Now, that may be fine, but I think this is a piece of information that is useful in setting overall policy.
They have a place on the form for descriptions to be entered when something is coming into the country, but most of that information is not useful. We found, I think, 1.1 million lines for which they had multiple descriptions but only one classification code. They might have 50 items in their description, but only one classification code.
Then there was another large percentage of them in which all they put in the description was something like “kits”. You can't apply a classification code when all you're describing is “kits”. Why bother asking importers to fill in the description, then? It's not required, as I understand it, but it's still there, and importers are filling it in.
Canada Border Services Agency also identified that if they had more compliance officers, they could collect four to 10 times the salary of that officer in additional duties.
I think we touched, then, on some of the issues about efficiency, but our main message in the whole audit is to somehow try to get the system to work in practice the way it's supposed to work or is described to work on paper.