Thank you, Mr. Chair.
One of the issues that the Auditor General just mentioned is the poor description on the form. We do question the need.... Even though it's not a formal requirement, many businesses spend time and effort trying to fill out that form properly. Meanwhile, another set of businesses basically put in whatever they want. It could be a part number, it could be sets, kits, whatever.
We suggested to CBSA that they should review that part of the form, because obviously it's not something that's useful to them. The description on the form cannot always be matched with the HS code. It means that when they do verification ex post, there's no value to the descriptive.
We did try, through text analysis, to match the descriptive with the HS code, and that's when we realized that it was often misdescribed. We had to basically abandon our objective, which was to try to see if the goods had been properly classified.
On the form side, as I mentioned earlier, importers have the ability to retroactively amend the form. This could be for up to four years. Under NAFTA, it's only one year. We were told by CBSA that the longer it takes to amend the form, the more likely it is that the amendment will be incorrect. That's one part of the problem associated with the amendment of the form. There's also the fact that it could allow importers to play with the float by underestimating the value of the goods shipped. On the last day, four years minus one day, they will submit an amendment to their import form. Then they owe money, but they had the money for four years in their pocket.