Thank you, Mr. Chair and members of the committee, for including the Canadian Association of Importers and Exporters, I.E. Canada, on your agenda to allow for input on this important topic.
My name is Kim Campbell. I am the past chair of our association. We appreciate the opportunity to appear before this committee to share our thoughts on programs, tools and measures that could support the growth of Canadian business here and abroad.
I.E. Canada is a national trade organization that has been speaking on behalf of Canadian trade for almost 90 years. Our members include importers, exporters, Canadian manufacturers who both import and export, wholesalers and distributors, and retail importers and exporters in Canada. As well, we represent both the largest and small and medium-sized businesses. Our members import and export across most commodities and product lines.
I.E. Canada endeavours to be a trusted facilitator between business and government, to inform and influence outcomes of policy and real-world application for the movement of goods across Canada's international borders. The private sector needs transparency, predictability and ease of use in all our interactions with government, but this really is more so at the border.
The current business environment remains challenging for our members as we continue to recover from the pandemic, and we have had subsequent border disruptions such as B.C. floods, protests and port and rail labour disputes. Each one validates the importance of an open and fluid border. When only one part of it is disrupted, it causes increased costs, lost sales, food insecurity and economic hardship across the entire supply chain.
Canada has set ambitious targets for increasing its overseas exports, with a goal of achieving a 50% increase by 2025. To meet these targets and ensure we have a properly functioning border, we believe the Government of Canada must do something different.
We need more collaboration and coordination, with a strong mandate to create a best-in-class supply chain. This can only be achieved with industry inclusion in the mandate and a voice at the table. Too often, we are disappointed at the lack of engagement and dialogue. We must do better. It is our belief that there must be accountability and oversight to ensure we are achieving our desired outcomes. Having agencies and departments work in silos with no overarching mandate has not proven effective to date.
We would like to share some current challenges that we believe impact the supply chain and the unused opportunity to leverage CUSMA, which provides a framework for customs and trade facilitation.
CARM has been described by the Canada Border Services Agency as a digital innovation that aims to transform the process of assessing and collecting duties and taxes on commercial goods imported into Canada. This initiative is a multi-year project that will change how duties and taxes for imported goods are collected and managed. It was to reduce the cost of importing to trade chain partners.
Unfortunately, we have a project that is vastly over-budget, late and missing key registration and performance targets. Businesses continue to absorb unnecessary costs trying to implement due to CBSA's inability to follow a recognized IT project methodology. CBSA continues to change plans, which has forced industry to reinvest multiple times. Policy decisions will add direct costs that importers do not have to contend with today.
The solution itself is complicated, confusing and layered with manual processes that are currently automated. Despite not proving the CBSA is ready to implement, because we are missing policies, regulations, implementation plans and have not achieved acceptable testing results, they will implement this project on May 13, 2024, with a big bang approach.
Their decision to make it a requirement for importers to create a portal account and obtain their own financial security for the goods to move past the border without payment of duties and taxes is expected to cause large-scale border disruption. Today, almost 100% of shipments move unimpeded past the border, and all processes are digitized. On May 13, for those shipments that do not meet the new criteria, they will be forced to release their goods at the border by paper and to pay duties and taxes.
CBSA has recently implemented a mandatory filing of a dataset before goods enter Canada. This is required to be done by freight forwarders, who play a critical role in the logistics industry by ensuring the smooth and efficient movement of goods from point of origin to the final destination.
Penalties are now being assessed when CBSA believes their policy is not being followed. The penalties are significant and escalating. Although CBSA continues to state that AMPs are not punitive, industry does not agree. Unfortunately, many freight forwarders are now having to consider bankruptcy and, in addition, many transportation companies are reconsidering Canada as a place to transport goods because the stakes are too high.
The downstream impacts are significant, as importers and exporters have fewer options for shipping goods into and outside of Canada. Industry continues to raise this with CBSA, but to date—