Canadian Automotive Partnership Council: Working Groups: Regulatory Harmonization

Regulatory harmonization was identified as one of the key pillars of a new strategic automotive policy for Canada.
The CAPC Working Group on Regulatory Harmonization developed a Vision for Regulatory Harmonization and identified immediate harmonization priorities.

Vision for Regulatory Harmonization

For Products: A product environment that respects self-certification to one set of regulatory requirements across North America and in the longer term, globally, and satisfies societal needs efficiently.

Within Canada: One set of globally competitive manufacturing and vehicle in-use requirements across all jurisdictions in Canada.

Recommendation: Develop a formal harmonization policy with clear statements that is recognized across government departments with responsibility for the automotive sector.

Immediate Harmonization Priorities & Recommendations

Harmonize Canadian Motor Vehicle Safety Standard 208 (CMVSS 208) for occupant protection with the belted requirements of US Federal Motor Vehicle Safety Standard 208 (FMVSS 208).
Maintain fuel economy targets that are fully consistent between Canada and the US.
Fully accept self-certification.
From a manufacturing and facilities perspective, harmonize emission inventories and reporting regulations for Ontario ONAir Regulation 127 and the federal National Pollutants Release Inventory (NPRI).

Status Report on Subcommittee Actions to Date

Overview

As of the May 30th CAPC meeting, the Regulatory Harmonization Subcommittee had identified:

A vision for regulatory harmonization;
An overall recommendation regarding the need to develop a formal harmonization policy;
Three critical harmonization issues relating to vehicle standards set by the federal government; and,
One recommendation with respect to emission inventories established primarily by Ontario.

Issues papers for all four harmonization priorities have been completed.
At the May 30th CAPC meeting, the decision was made to circulate the group recommendations for review and comment. All comments received support the Regulatory Harmonization Working Group recommendations.
Early in the CAPC process, the Regulatory Harmonization Working Group had selected and prioritized its recommendations from a long potential list of regulatory harmonization issues.
These issues were identified as having the most critical impact on the competitiveness of the Canadian automotive industry. The dynamic is such that priorities can shift rapidly in the product standards area based on changes by government in policy, timing, departmental positions, etc. All four initial recommendations remain issues that are of critical importance to the automotive sector, and are issues that pose considerable competitive risk for the industry.
Since May 30th, two meetings of the CAPC Regulatory Harmonization Working Group have been held.
At the May 30th meeting, the potential benefits of the federal Smart Regulation Initiative were raised. The Subcommittee investigated the potential of the Smart Regulation Initiative and has found that while the Initiative shows promise in the long run, the Smart Regulation Initiative is not specifically targeted at the automotive sector, and will likely not deal with the automotive industry's existing areas of regulatory concern. The Regulatory Harmonization Working Group has therefore concluded that the federal Smart Regulation Initiative is not a substitute for the CAPC process.
Discussions related to the issues identified by the Regulatory Harmonization Working Group have been ongoing with 4 government departments.

CMVSS 208

Industry provided Industry Canada with a detailed overview of the issue of CMVSS 208 harmonization.
The Regulatory Harmonization Subcommittee formally requested data from Transport Canada that supports the need for a different standard for chest deflection in Canada than in the US.
Since May 30th, Transport Canada conducted a workshop and subsequent meeting with the automotive industry to discuss the Benefits and Costs report.
To date, Transport Canada has not provided any Canadian field data related to chest deflection injuries to support the need for a unique-to-Canada standard.
Transport Canada acknowledges that no Canadian field data is available that would specifically support the intended unique Canadian chest protection requirements - i.e. there is no demonstrable need for different Canadian chest protection requirements. In the absence of unique Canadian data, there is no technological reason for a different chest deflection in Canada.
The auto industry has serious concerns with the Transport Canada Benefits and Cost analysis, and these concerns continue to be raised with Transport Canada. To date, industry concerns have not been adequately addressed.

Fuel Economy

An issue paper has been developed that outlines the need to maintain common fuel economy targets between Canada and the US.
Harmonization of fuel economy targets between Canada and the US remain a high priority in order to ensure that Canadian consumers have access to a broad range of vehicles.
Advanced vehicle emission control technologies require appropriate fuel quality in order to function properly and to deliver the emissions benefits. With the introduction of Tier 2 emissions standards, the need for appropriate fuel quality in Canada becomes even more critical.
Manganese-based fuel additives have the impact of clogging high-density close-coupled catalytic converters that are required to meet Canadian Tier 2 emissions standards.
Environment Canada is in the process of establishing and undertaking a Third Party Review of a recently completed automotive industry study into the impacts of manganese-based additives on vehicle emissions. The Canadian automotive industry supports the government decision to proceed with a Third Party Review.
A national clean fuel standard designed to support the needs of advanced vehicle emission control technologies would ensure that Canadians have access to consistent fuel quality across the country.

Vehicle Safety Self-Certification

Discussions between industry and Transport Canada are ongoing. Progress towards a resolution continues to be slow.

Harmonization of Ontario Emissions Reporting with Federal NPRI

A smaller working group has been established with MEDT to better understand industry issues.
Harmonization of both substance thresholds and reporting requirements will be addressed.
38 differences have been identified between ONAir 127 and NPRI.

Next Steps

Process Required to Act on Recommendations

A clear and efficient process needs to be established to deal with recommendations that are developed by the Regulatory Harmonization Subcommittee, particularly for recommendations that impact a number of departments.

Commitment to Develop a Vision for Regulatory Harmonization

Progress towards resolution of immediate priorities would benefit from a vision on regulatory harmonization that spans across all departments that deal with automotive issues.
Governments within Canada should adopt a policy of harmonization of standards and regulations, unless compelling Canadian evidence exists that a different standard in Canada is necessary.

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