ITAC SMSE017 Comment

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ITAC Comments on:Gazette Notice SMSE-017-01- Public Discussion on a Proposed ImportationMonitoring Scheme for Radio and Telecommunications EquipmentMay 2001About ITACITAC is the voice of the Canadian information technology industry. Together with its partnerorganizations across the country, the association represents 1,300 companies in the computingand telecommunications hardware, software, services, and electronic content sectors. Thisnetwork of companies accounts for more than 70% of the 512,000 jobs, $116.4 billion in revenue,$4.4 billion in R&D expenditure and $30.8 billion in exports that IT contributes annually to theCanadian economy.ITAC's mission is to identify and lead on issues that affect our industry and to advocateinitiatives, which will enable its continued growth and development.Browse our website for a comprehensive overview of our association's efforts to promote andfoster the development of Canada's information technology (IT) industry.Information Technology Association of CanadaSuite 402, 2800 Skymark AvenueMississauga, Ontario L4W 5A6telephone: [phone]fax: [phone]email: [e-mail]: http://www.itac.ca© ITAC, 2001This brief may be freely reproduced with appropriate attribution.ITAC Comments on: Gazette Notice SMSE-017-01The Information Technology Association of Canada (ITAC) is pleased to comment onthe proposal for Simplifications to the Conformity Assessment Process forTelecommunications Terminal Equipment, ...

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• Publié par: Ermey
• Nombre de lectures: 22
• Langue: English

Extrait

ITAC Comments on:

Gazette Notice SMSE-017-01- Public Discussion on a Proposed Importation

Monitoring Scheme for Radio and Telecommunications Equipment

May 2001

About ITAC

ITAC is the voice of the Canadian information technology industry. Together with its partner

organizations across the country, the association represents 1,300 companies in the computing

and telecommunications hardware, software, services, and electronic content sectors. This

network of companies accounts for more than 70% of the 512,000 jobs, $116.4 billion in revenue,

$4.4 billion in R&D expenditure and $30.8 billion in exports that IT contributes annually to the

Canadian economy.

ITAC's mission

is to identify and lead on issues that affect our industry and to advocate

initiatives, which will enable its continued growth and development.

Browse our website for a comprehensive overview of our association's efforts to promote and

foster the development of Canada's information technology (IT) industry.

Information Technology Association of Canada

Suite 402, 2800 Skymark Avenue

Mississauga, Ontario L4W 5A6

telephone: [phone]

fax: [phone]

email: [e-mail]

www: http://www.itac.ca

© ITAC, 2001

This brief may be freely reproduced with appropriate attribution.

ITAC Comments on: Gazette Notice SMSE-017-01

_____________________________________________________________________

Information Technology Association of Canada

1

The Information Technology Association of Canada (ITAC) is pleased to comment on

the proposal for Simplifications to the Conformity Assessment Process for

Telecommunications Terminal Equipment, and on the Proposed Importation Monitoring

Scheme For Radio and Telecommunications Equipment.

Gazette Notice SMSE-017-01- Public Discussion on a Proposed Importation

Monitoring Scheme for Radio and Telecommunications Equipment

In a global marketplace, Canada’s competitive advantage will be based largely on our

ability to exploit newer, better and faster processes than our competitors. ITAC wishes

to see this potential enhanced by the application of forward-looking policies.

ITAC commends Industry Canada for proposing a new importation monitoring scheme

that would allow Industry Canada to focus its attention on high risk importers and will

overcome many of the problems this industry faced.

Background:

With Phase II of the MRAs (acceptance of certificates produced by foreign bodies) and

potentially a Supplier’s Declaration of Conformity scheme for terminal equipment,

Industry Canada will have to be much more active in market surveillance activities.

One tool for market surveillance is the proposed new importation-monitoring scheme,

combined with a Global Market Surveillance scheme, such as DECLARENET.

Industry issues:

“Just in time” inventory processes means business sensitivity to delays and other

requirements such as requesting additional information to be provided at time of

importation. The industry has raised the point that it is difficult to obtain detailed

information in a very short period before the shipment arrives at the border

Physical examination at the border is expensive and labour intensive

It is expensive for brokers and importers to adapt their processes and information

management systems to provide new data at time of importation

A proposed new business environment:

Importation and accounting streamlining that put into practice processes that are

founded on the principles of voluntary compliance and self-assessment, and which

transfer control from customs systems to that of business operations. Accounting

information can be consolidated and provided on a monthly basis. Non-targeted

importation monitoring schemes are very expensive to implement and maintain

Proposal:

Two “managed risk” based approaches are proposed:

First Approach; containing two processes:

Industry Canada to obtain importation data from CCRA and analyze this date to

identify high-risk areas.

Industry Canada to receive notification from CCRA when shipments identified as

high risk enter into Canada.

ITAC Comments on: Gazette Notice SMSE-017-01

_____________________________________________________________________

Information Technology Association of Canada

2

This approach can readily be implemented using existing systems, processes and

procedures. No additional data, invoice or form have to be provided by brokers or

importers.

Second Approach; containing two additional processes:

A. For pre-approved, low risk importers - Importers who show that they have a system

in place that ensures that only compliant products are imported and that imports can

be traced if a problem occurs.

Will be able to use the normal importation processes with no changes.

Would not have to provide specific information at time of importation.

Information would be provided to Industry Canada on demand only.

This option would allow importers to participate in the CCRA Customs Self-Assessment

(CSA) program.

B. Other, unknown risk, importers - These importers will be required to provide extra

data elements at time of importation (ACROSS). Preferably, this information could

be provided electronically through the existing CCRA ACROSS system.

Industry Canada recognizes that the implementation of this second approach would

require development and/or modifications to importers and brokers systems and would

consider this in its implementation plan.

Move to the second approach will be considered only if the number, type and impact of

non-compliances detected in products imported using the first approach persist and

justify closer monitoring.

Discussion:

Recent Industry forecasts estimate that:

By 2005 there will be around 100 Million wireless Internet users in North America,

with some 10 Million in Canada. This equipment has an average lifespan of 2 years

due to advances in technology.

That could mean the importation of nearly 10 Million wireless terminals during the

next 4 years, and more substantial numbers thereafter..

Comment:

Prohibitive import procedures that prevent early entry of advanced technology devices

into Canada, while being available in the United States and Europe, will deter the growth

of Canada’s “Connectedness Program” and deprive Canadian Consumers from using

state of the art equipment and technologies.

The second approach appears is very costly, time consuming and would tend to punish

compliant importers, which does not necessarily deter non-compliant importers.

We recognize that it is in the best interest of government and consumers that devices

imported into Canada, meet Canadian requirements. We also recognize that by and

large, the technical requirements for Canada and the USA are pretty much the same.

ITAC Comments on: Gazette Notice SMSE-017-01

_____________________________________________________________________

Information Technology Association of Canada

3

We therefore urge Industry Canada to consult with industry before considering the

implementation of the 2

nd

approach so that if needed, the 2

nd

approach will be

implemented in a cost-effective manner that will address the real problems and cause

minimal impact on Canada’s Connectedness Program.

Concluding Remark:

ITAC commends and encourages Industry Canada to use the "First approach" to import

monitoring whenever possible.

ITAC encourages Industry Canada to join with other governments in the development of

a global Market Surveillance system that will in combination with the existing CCRA

ACROSS system provide the government with the assurances it seeks.

ITAC urges the Canadian government to work with the governments of our trading

partners, and international industry, to develop and implement such approaches.

ITAC urges Industry Canada to consult with industry on any implementation of the 2

nd

approach.