Comments and Reply: Movement Document

A number of comments were received by both industry and association stakeholders with respect to the movement document provisions set out in the proposed Regulations.

Response: Environment Canada agrees with this recommendation, and is proposing a fully harmonized movement document that will meet both provincial and international requirements. The prescribed form will also meet the requirements for shipping documents under the Clear Language TDGR.

Response: Environment Canada will allow regulatees to submit movement documents and notices electronically, as PDFs.

Environment Canada is also working toward the electronic transmission of both notices and movement documents, and on developing an electronic interface.

The wording of the proposed Regulations has been modified to require that the movement document be sent to the authorities of the province of export or import, if required.

The same units of measure indicated on the notice must also be used on the movement document. Environment Canada's international agreements prescribe these units as kilograms or litres

Response: Environment Canada agrees with the recommendation of working with the provinces and territories to address documentation concerns. Environment Canada is proposing a tracking form that will meet the needs of the Department, provinces, including the Ontario Ministry of Environment, and a shipping document under the TDGR. The form includes the quantities shipped and received (as found in the current manifest), and has been modified to incorporate the additional codes required for transboundary movements. A number of codes found in the notice must also be outlined in the tracking form in order to meet international obligations under both the Basel Convention and the OECD Decision.

Environment Canada agrees with the recommendation to re-name the manifest tracking document the movement document. The revised document, which will be bilingual, will be incorporated into the proposed Regulations.

Response: The term "immediately" has been dropped from the contract requirements. It will be the responsibility of the exporter or importer to ensure proper procedures are in place to obtain a copy of the movement document from their foreign counterpart and provide it to the Minister within the time set out by the proposed Regulations.

Response: The length of time the movement document must be kept has been changed from two to three years. This is necessary to comply with Canada's international obligations under the OECD Decision, which requires that these documents be kept for three years.

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