What’s wrong with being unique?

How Canada’s Chemicals Management Plan needs to better align with our global reading partners policies

Everyone, every now and then, likes to differentiate themselves by standing out from the pack. Clothes, hairstyles, tattoos, body piercings — you name it, are all expressions of individuality and ways for people to claim their own uniqueness.

Like people, countries and sub-national jurisdictions also like to differentiate themselves by taking what some would call leadership stances on various issues, for a variety of reasons. For instance, California was the first jurisdiction to put in place tailpipe emissions standards in 1966 for valid geographical and photochemical smog reasons. In a similar fashion, Canada has pursued a world leading Chemicals Management Plan for the good and valid reasons of looking to reduce and eliminate toxic substances from our environment. 

However, California’s unique role in the regulation of pollution, that subsequently morphed into the mitigation and elimination of greenhouse gas emissions, is significantly different from Canada’s unique leadership role on chemicals management.   

California has a larger population than all of Canada, and there are more vehicles on the road in California than all of Canada, but part of California’s unique waiver from federal emissions regulations is that other states can choose to follow California’s regulations or they can choose to follow federal emissions control regulations. 

Right now, seventeen other states have committed to follow the California standards with different dates for the implementation of some of those provisions out to 2025. There are two sets of California standards, LEV provisions — which cover criteria air contaminants, and GHG emissions and ZEV provisions — which are similar to the ZEV mandate that the Government of Canada is seeking to impose on a national basis. 

If you look at the percentage of motor vehicle sales in the States that copy California’s ZEV provisions, that covers about 36 per cent of all of the vehicles sold in the United States. In this case, California has set itself up in a leadership role on emissions reduction that cannot be ignored by any automaker.   

On the other hand, Canada’s world-leading Chemicals Management Plan (CMP) is problematic because it is not aligned with Canada’s major trading partners — the United States and Europe. 

While I think the CMP is well-regarded on the international stage, the reality is that Canada is a relatively smaller, middle power economy that does not have the same persuasiveness to drive other countries to adopt its unique program as, say, the United States or Europe or even California. 

The end result is that when Canada decides to ban a chemical like DBDPE — a flame retardant for which there is no known alternative — it has significant ramifications for a number of different industries, including the automotive industry where this chemical is used in a variety of automotive parts. 

While this has obvious implications for vehicles that are being built in Canada that have — for instance — performance standards the vehicles must meet regarding the flammability of interior materials,  this ban on DBDPE also would prevent vehicles from  other countries from entering Canada if those vehicles contain the chemical. As no other country has  sought to ban DBDPE, this seems entirely plausible.

Canada’s automotive industry is primarily highly integrated on a North American basis, but also secondarily part of a globalized industry from a sales perspective. In this regard, we are not unlike many other industries. 

As a Canadian I could look objectively and agree that it is great to see Canada taking a leadership/unique role on the international stage on an issue, but given our reliance on other countries and other jurisdictions as a highly trade-exposed economy, any leadership/unique position needs to be pragmatic and thoughtful as well. 

The failure for a country like Canada to be pragmatic in any leadership activity in this regard is not without consequence either. Being unique can often lead to either limited product selection or higher prices — or both, and this does not make for a robust market, especially in the current economic environment.

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