ITAC SMSE017 Comment
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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: (905) 602-8345fax: (905) 602-8346email: info@itac.cawww: 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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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: (905) 602-8345
fax: (905) 602-8346
email: info@itac.ca
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.