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Lacey Coalition

January 9th, 2012

CMEC
Tag Line: Lacey Coalition

Dear CMC Colleague,

(This message is being sent to you by Birgit Matthiesen, Special Advisor to the President & CEO – Canadian Manufacturers & Exporters)

Dear Colleague:

As many of you know, the US Department of Agriculture (USDA) issued regulations to prevent international trafficking in illegal logging products and global deforestation. As a result, companies in the United States and abroad who are doing business in the United States must submit an import declaration with each shipment which must contain, among other things, the scientific name of the plant, the country of origin and the quantity and value of the products imported into the United States. In their regulations, USDA expanded the definition of “plants” to include paper, wooden furniture, hammers with wooden handles, musical instruments containing wood and even further manufactured products such as perfume, plastics and plastic components, jewelry and plant based pharmaceutical products. While enforcement concerns are targeted elsewhere around the globe and Canada is well known for its model forest sustainability programs, Canadian companies must still comply with these onerous reporting and declaration requirements. The compliance and cost burden will only increase as 1) Congress moves to expand the product coverage and 2) your customers upstream in your manufacturing supply chain, either in Canada or in the United States, request detailed transactional information from you. The Lacey provisions require the exercise of “due care” and failure to exercise this care can expose your company and your customers to civil penalties of up to (US) $10,000 per violation and even criminal penalties. Currently only imported products under Tariff Chapters 44, 66, 82, 92, 93, 94, 95 & 97 are scheduled for enforcement of the declaration requirement but the underlying law makes it clear that almost all product lines should eventually be covered.

This is not a forestry or lumber issue, but rather an onerous and unnecessary requirement on Canada’s manufacturing sector. CME is therefore taking the business lead to work with the Government of Canada to find a permanent solution for Canadian shippers and suppliers. Your business voice and expertise will be critical in those efforts but we understand the need for business confidentiality and discretion. To that end, we are organizing a Lacey Coalition of companies who are willing to work with CME and provide us with your company’s experience and concerns with the implementation of the Lacey Act.

If you are interested, please reply to this message. We will organize an initial conference call with you and provide an initial draft action plan for your review and approval. On behalf of CME’s leadership team, thank you and we look forward to hearing from you.

Birgit Matthiesen

Special Advisor to the President and CEO

Canadian Manufacturers and Exporters

PH 703-303-8413

birgit.matthiesen@cme-mec.ca

www.cme-mec.ca

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