February 6, 2024 | Circular No. 11628

Dear Member,

We recently submitted comments to the Treasury Board of Canada on its Supply Chain Regulatory Review, which is aimed at gathering stakeholder input regarding federal regulations and regulatory practices that have an impact on the operation of Canada’s supply chain, particularly as relates to the movement of goods and commodities in Canada and internationally.  The review is structured around three key themes, two of which are transportation and border operations (the third being critical minerals).

Our comments to the Treasury Board focus primarily on supply chain challenges from a CBSA perspective and the way in which CBSA processes, requirements and resource constraints act as impediments to efficient supply chain operations. We made a number of recommendations in this respect, including the need to streamline CBSA’s reporting requirements for Canada’s waterborne imports and exports; the need to establish a “maritime single window” reporting platform for submitting vessel arrival and departure information to regulatory authorities;  and the need to modernize CBSA’s policies and regulatory requirements regarding the examination of containerized cargo (particularly as relates to its enforcement of radiation screening requirements for import containers, the construction of new container exam facilities, and the acquisition of much-needed technology and equipment).

In addition to the above, we also took the opportunity to highlight a number of concerns regarding Transport Canada’s regulatory processes, including the department’s increasing reliance on the use of Interim Orders and other instruments that exist outside the normal regulatory process, and the need to ensure that TC moves more swiftly in making the legislative and regulatory changes that are needed to implement international conventions in Canada, as per the IMO’s implementation timelines.

The full text of our submission can be found HERE.

The government will use the input provided through this review to develop a regulatory roadmap that outlines initiatives to improve the regulatory system from a supply chain perspective. This could include initiatives such as changes to federal regulations or enabling legislation, as well as updated policies, practices, guidance or tools.  This roadmap will also align with the work being undertaken by the newly created Supply Chain Office and its effort to develop a national supply chain strategy for Canada.


Karen Kancens
Vice President