Thank you very much.
My name is Bruce Rebel and I'm the vice-president and general manager of the Association of Home Appliance Manufacturers Canada. We are located here in Ottawa. Our members consist of some of the larger appliance manufacturers. I think you will recognize many of the names such as Whirlpool, Samsung, LG, etc. Those are our typical members.
I will get right into my comments.
Chair Maloney and members of the committee, good morning and thank you for the opportunity to testify on behalf of the Home Appliance Manufacturers Canada. AHAM represents manufacturers of major portable and floor-care home appliances as well as suppliers to the industry. Our membership includes more than 150 companies throughout the world. AHAM produces more than 95% of the household appliances sold in Canada.
Home appliance manufacturers selling products in Canada design and manufacture products for the entire Canada-U.S. market, not for any one specific province, state or jurisdiction. With manufacturers making identical or similar products available throughout Canada and the U.S., alignment and harmonization of product energy test procedures and energy standards between provinces and between Canada and the U.S. is critical to avoid costly duplicative testing and reporting. Appliances designed for just one province would be significantly more costly, would lead to longer wait times for products and likely would lead to drastic reduction in product choices. In the end, it's the same appliance whether it's plugged in in Victoria or St. John's.
AHAM member companies are constantly striving to improve their products, whether it be for safety, energy efficiency or transitioning to refrigerant gases with low global warming potential. The pace of advancement in product technology requires a regulatory framework that can keep pace with the changes and improvements our members are introducing and with the changes that are occurring with our largest and most important trading partners.
The U.S. Department of Energy must, by statute, regularly review and consider revising its energy efficiency standards and test procedures, which, more often than not, results in new product energy efficiency performance levels being established and amended product test procedures being enacted.
The Government of Canada works hard to facilitate a cohesive regulatory framework for product energy efficiency and recently made significant strides in this area. I want to draw your attention to one such legislative effort.
After many years of consultation and work, we were delighted that Bill C-63 received royal assent in December 2017. The bill included amendments to the Energy Efficiency Act aimed at improving the process for updating efficiency standards and product test procedures to help Canada keep pace. These included a ministerial authority to make technical and administrative changes to regulations designed to maintain harmonization with another jurisdiction, as well as the authority to incorporate by reference technical standards documents to harmonize with another jurisdiction.
Both government and industry knew that these authorities were needed to keep abreast of advancements in energy efficiency, an important matter for all Canadians. However, the benefits of these critical process improvements cannot be realized until the cabinet enables the Minister of Natural Resources to utilize these new authorities. Using a football analogy, we are at the one-yard line and need only one more concerted effort to get these new authorities over the goal line and into practice. Natural Resources Canada's office of energy efficiency has developed an ambitious and busy forward regulatory plan for 2018 to 2020. Bringing these new ministerial authorities to bear upon the plan will be key to its success.
Why did the government decide we need these modern regulatory authorities? The changes to Canada's energy efficiency regulations contained in the recently enacted amendment 13 took 10 years to get published. The current process to amend Canadian energy efficiency regulations is overly lengthy and lacks nimbleness. This has created a significant regulatory burden for manufacturers who have to comply with different Canadian and U.S. energy efficiency requirements. Strangely enough, as some of you may not know, it's actually the U.S. requirements that are more stringent than Canada's.
Additionally, the long delay prompted provinces to introduce and publish their own regulatory energy efficiency requirements. This resulted in a chaotic mosaic of regulatory requirements that extended right to the Canadian consumer. The Canadian and U.S. energy labels that must accompany home appliances had different annual energy consumption values, leading to substantial consumer confusion as to why the same product consumed more or less electricity in one country versus the other. The reality is, the appliance consumes the same amount of electricity. It was the misaligned regulations that required appliance manufacturers to report results from two different non-harmonized test procedures.
In August 2014, the Canada-U.S. regulatory co-operation council joint forward plan included the goal of aligning new and updated energy efficiency standards and test methods for energy-using equipment. AHAM proposed and strongly supported this initiative. In June 2018, Canada and the U.S. signed a memorandum of understanding reaffirming their commitment to the regulatory co-operation council, as it is a practical and proven form devoted to reducing, eliminating and preventing unnecessary regulatory differences between the two countries.
With the publication of Canada's energy efficiency regulatory amendment 13 in December 2016, and the recent publication of amendment 14 on October 31, the energy efficiency standards and product test procedures are now largely aligned and harmonized with those previously published by the U.S. Department of Energy.
For Canada to be able to maintain a regulatory posture to ensure the energy efficiency regulations can be updated, improved and remain in alignment with jurisdictions of our important trading partners, the new ministerial authorities in the act need to be up and running. It would be terribly unfortunate if the bill was enacted to improve energy efficiency and the new authorities were never realized.
The goal of aligning and harmonizing energy efficiency standards, test procedures and labelling provides the best outcome for consumers, manufacturers, retailers and regulators themselves.
A regulatory environment that is responsive to the introduction of new technologies, and is better positioned to harmonize with our largest trading partner will not only achieve public policy goals of reducing greenhouse gases and electricity consumption but also contribute to maintaining the production and availability of affordable appliances for Canadian consumers.
The harmonization and alignment of home appliance energy conservation standards and test procedures between Canada and the U.S. is a top priority for my association and its members. We continue to strongly support this goal and urge this work to continue under the auspices of the regulatory co-operation council.
We would welcome this committee's support of our ask of the government that we get these ministerial authorities across the goal line so we can put them to use.
I want to briefly show you some of that confusion here. I have provided copies of the diagrams to the clerk.
You can see here on my right, this is what the old label used to look like. You can see that in the United States and Canada the energy consumption values per annum are different. That is what was causing the confusion. This tag typically hangs in every refrigerator, clothes dryer and washer.
I have here with me an aligned and harmonized energy tag. You can see that the annual consumption of this particular refrigerator is now aligned and harmonized and there's no longer confusion for the consumer as to why this appliance consumes more or less electricity in one country than the other. As I indicated earlier, the answer is that it doesn't. The analogy would be if I'm testing a motor vehicle at 50 kilometres an hour. If I test it at 100 kilometres an hour, I will get different results. That's what we were getting as well.
Thank you very much.