The eect of this legislation is to silence the energy industry, and those that support it, in an eort to clear the field of debate and promote the voices of those most opposed to Canada’s energy industry. [...] We recognize and respect the Competition Bureau’s role in this consultation process is to develop guidance and that the Competition Bureau is not in a position to truly fix the fundamentally flawed amendments hastily made to the Competition Act. [...] As already stated, the best solution to this issue is to repeal the recent amendments to the Competition Act and take the time to have a fulsome discussion on the issue of greenwashing, something that did not happen in this instance and we believe is a missed opportunity. [...] Businesses need the flexibility to use the newest and most accurate methods to identify, quantify and communicate their performance to stakeholders and should not be penalized for changing and evolving best practices. [...] If the barrier to bring a claim to the Bureau is low, and the guidance is not clear and pragmatic so that companies can comply and other parties have the means to understand that claims are likely to be properly substantiated, the new provisions could create significant administrative burden for both the Bureau and companies.
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Table of Contents
- Competition Bureau Re Consultation on Competition Acts New Greenwashing Provisions 1
- Via email Competition Act Competition Act 1
- Competition Act Competition Act Competition Act 2
- A. The new rules should apply equally across all industries and sectors. 2
- Competition Act Competition Act any 2
- B. Internationally recognized methodology is undefined. 3
- Competition Act 3
- C. Canadian federal regulatory and provincial reporting frameworks and standards already exist 3
- Competition Act Competition Act 4
- D. Safe harbours are required. 4
- Competition Act Competition Act Competition Act Competition Act 4
- Competition Act 5
- E. Dierent methodologies exist for gathering data. 5
- F. The new rules discourage the use of scenario analysis and aspirational target-setting 5
- Competition Act Competition Act 6
- Conclusion CANADIAN ASSOCIATION OF PETROLEUM PRODUCERS 6
- Appendix 1 CAPP Detailed Response to Competition Bureau Consultation Questions 8
- 1. What kinds of claims about environmental benefits are commonly made in the marketplace 8
- 2. Are there certain types of claims about the environmental benefits of businesses or business 8
- 3. What internationally recognized methodologies should the Bureau consider when evaluating 9
- In Canada a business should be able to publicise what it reports to government 9
- 4. What other factors should the Bureau take into consideration when it evaluates whether 10
- 5. What challenges may businesses and advertisers face when complying with this new 10
- 6. What other information should the Bureau be aware of when thinking about how and when to 11
