:
I call the meeting to order.
This is meeting number 123 of the Standing Committee on International Trade.
Pursuant to Standing Order 108(2) and the motion adopted by the committee on Wednesday, August 21, 2024, the committee is resuming its study on protecting certain Canadian manufacturing sectors, including electric vehicles, aluminum and steel, against related Chinese imports and measures.
We have with us today, from the Inter-Parliamentary Alliance on China, Luke de Pulford, executive director, by video conference.
From The Committee for Freedom in Hong Kong Foundation, we have Samuel Bickett, lawyer, researcher and Hong Kong human rights advocate.
We welcome you all.
We will start with opening remarks and then proceed with a round of questions. Each witness has up to five minutes, and I will keep track of the time for everyone.
Mr. de Pulford, I invite you to make an opening statement of up to five minutes, please.
:
Thank you, Madam Chair. It's very good to see you again.
As you heard, I'm creator and executive director of the Inter-Parliamentary Alliance on China. That's an international cross-party group of parliamentarians working to address challenges associated with the Chinese Communist Party under the leadership of Xi Jinping. I'm proud to say that this includes around 30 Canadian parliamentarians from all parties, some of whom are represented today.
On electric vehicles, since 2020, China has emerged as the largest manufacturer and exporter of EVs in the world, and its capacity continues to grow as a result of policies such as extensive state subsidies and other non-market practices. In 2023, China's annual EV exports totalled $47.2 billion, up from $0.2 billion in 2018. Automobile imports from China to Canada's largest port, in Vancouver, jumped 460% year over year to 44,356 in 2023.
China undermines markets and competition with massive state subsidies that amounted to $57 billion between 2016 and 2022. A further 20% cost advantage is achieved through Chinese control over the supply chain and raw materials. This allows Chinese EVs to undercut the market by between 20% and 30%. This doesn't even include the advantage gained through China's comparative lack of environmental and labour standards, including through the presence of forced or state-imposed labour in Chinese supply chains.
Similarly, and very importantly, Chinese overcapacity in aluminum and steel is structural, persisting and worsening. These are highly strategic industries core to the development and deployment of innovation, especially in the defence and energy transition sectors.
Despite softening global demands, China, the world's largest steelmaker, has increased its steelmaking capacity by 18.6 million metric tons since 2018. This is more than Canada's total production capacity. Similarly, China's primary aluminum capacity has grown from 11% of global production share to 59% over the last two decades, with the government investing up to $70 billion between 2013 and 2017.
China's weakening economy now exposes this excess capacity even further, fuelling unprecedented export surges that are disrupting markets and creating spillover effects in other sectors and across the globe. Failure to address this spillover will leave our companies weakened and lacking the financial capacity to make investments required for the energy transition. Takeovers by Chinese companies, which would further embed Chinese supply chains, may end up being the only option to prevent permanent closures and resultant job losses across the whole of our own supply chain.
It's really important to emphasize that Beijing makes no secret of its intent to undermine the economic security of liberal democracies, as it views our values as an existential threat to the regime's legitimacy, and neither is Beijing averse to weaponizing its advantages in pursuit of its global ambitions.
Very briefly, what is the remedial action? What can we do? Addressing this is much more than simply seeking to protect our markets from Chinese overcapacity, unfair competition and distortionary practices. It's about the principles of free and fair trade, supporting the innovation of our companies and ensuring companies and workers gain from an energy transition that is secure and clean and aligns with our core values.
We have to think beyond bilaterals and tariffs. Low-demand overcapacity is proliferating globally in addition to and beyond China, in particular in the ASEAN, the Middle East and North Africa.
We'd recommend developing a shared strategy to address the issue in emerging economies. I want to emphasize that whatever is done, it has to be done in alignment with allies. The reason for that is that there are ways around tariffs, and the PRC has demonstrated willingness and ability to circumvent them. It's also worth noting here that misalignment with allies on tariffs can have far-reaching consequences for free trade and other bilateral or plurilateral trade agreements.
Canada could, and should, build upon the commitment from G7 leaders in June 2024 to act “together to promote economic resilience, confront non-market policies and practices that undermine the level playing field and our economic security, and strengthen our coordination to address global overcapacity challenges.”
This is an international problem that requires international alignment to address.
Madam Chair, I'm very happy to address questions or recommendations, and I yield the floor.
:
Good morning, Madam Chair.
Thank you for inviting me to appear before the standing committee on behalf of The Committee for Freedom in Hong Kong Foundation to talk about our work into how China uses Hong Kong to evade Canadian sanctions. This is an issue related to the import issues that you're speaking about today, and it really is about how the Chinese government is willing to evade tariffs and sanctions on a broader basis.
CFHK is a non-governmental organization operating in Canada, the U.S., the U.K. and the EU and is focused on human rights and freeing political prisoners in Hong Kong.
I am a human rights lawyer and an international sanctions specialist who is the author of the CFHK report called “Beneath the Harbor: Hong Kong's Leading Role in Sanctions Evasion”. For this report, we extensively reviewed data sources, including Russian customs records, vessel tracking data, Hong Kong companies and registry filings. We came to one inescapable conclusion: Hong Kong has gone rogue.
Previously a key partner in the global economy, the city's government now serves some of the world's most brutal regimes by smuggling military technology, cash and prohibited commodities through the territory to flout Canadian and international sanctions.
Our findings on Hong Kong's supply of military components to Ukraine are particularly alarming. Just after the Ukraine war began, in February 2022, Hong Kong shipments to Russia dropped for two months before beginning to rise rapidly in the spring. By the end of 2022, shipments had almost doubled from pre-war levels. These were not benign shipments. Between August and December 2023, of the $2 billion in goods shipped from Hong Kong to Russia, $750 million, nearly 40%—and this is U.S. dollars—comprised goods on the common high-priority items list. This is a list of items that Canada and its allies consider to be of the highest priority to Russia's war effort.
Statistics aside, our report reveals how the Chinese and Hong Kong governments are allowing unprincipled people to profit off the most dangerous, destabilizing states in the world, in particular the regimes in Russia, North Korea and Iran.
To give a couple of examples from our findings, the Hong Kong company called Piraclinos, which claimed to sell fertilizer and charcoal, shipped millions of dollars in military-grade semiconductors to sanctioned Russian military supplier VMK. We discovered that its true owners are carefully hidden behind a network of front directors and shareholders from Cyprus, Kyrgyzstan and Bulgaria. Neither Piraclinos nor any of their front companies or individuals have been sanctioned.
Li Jianwang was a Hong Kong trader who ran Arttronix International, a company shipping drone and missile components to Iran, which has regularly supplied these weapons to Russia and Middle Eastern proxy militias. When the U.S. sanctioned Arttronix last year, Li simply dissolved the company and started a new one called ETS International, which remains unsanctioned.
Hong Kong company Align Trading reported shipping two cargoes of integrated circuits purportedly produced by French company Vectrawave to AO Trek, a company suspected by Ukraine to be supplying the Russian military. Vectrawave is a military contractor that produces expensive, highly specialized chips for use in military aircraft and communications equipment. None of the companies or individuals involved have been sanctioned.
As this is happening, the Hong Kong government, at the behest of Beijing, has explicitly said that it won't intervene to enforce Canadian or international sanctions, effectively inviting these smugglers to set up shop in the city.
What can Canada do? For starters, Canada should use its new secondary sanctions authority to sanction Hong Kong, Chinese and other third-country evaders. In mid-2023, Canada amended the Special Economic Measures Act to permit secondary sanctions. This was a positive and essential step to addressing the problem, but more than a year later, Canada has yet to exercise this power. The United States and the EU, in contrast, have regularly designated third-country collaborators for sanctions throughout Russia's war in Ukraine.
Simply sanctioning trading companies is not enough, however. It is extraordinarily easy to dissolve a sanctioned Hong Kong company and set up a new one in a matter of days. Canada and its allies must get serious about targeting the infrastructure behind these activities by sanctioning logistics companies, corporate service agencies and, most importantly of all, financial institutions. Also, more focus must be placed on sanctioning the individuals behind these companies and, importantly, this must be done in concert with allies in the U.S., the EU and Australia.
Second, Canada should ramp up enforcement against Canadian participants in these schemes. In September 2023, the U.S. Treasury Department published data on suspicious activity reports related to Russian sanctions evasion. Of western countries discussed in the report, Canada ranked third, after the U.S. and the U.K., for SARs filed against its citizens. The companies and individuals named in these SARs are not public information, but they suggest there is the potential for more expansive investigation of Canadian sanctions evaders.
Finally, Canada and its allies must speed up the sanctions designation process. It typically takes many months to investigate and sanction a person. This pace has allowed evaders to run circles around the west, moving assets and changing corporate identities long before sanctions catch up to them. Bureaucracy and layers of review should be minimized, and investigators should be empowered to move quickly and efficiently, while being provided with all the resources they need. With Russia slowly but surely encroaching further into Ukraine, there is limited time for Canada and its allies to take decisive action. We strongly encourage the committee and the government to prioritize this issue.
Thank you for your time. I'm happy to answer any questions you have.
I want to ask you about the ESG movement. I'll make a statement and invite your comment on it.
Too often, the ESG movement has led to an exclusive focus on the “E”, ignoring the social and governance consequences, as well as the strategic consequences, of certain decisions. The push for a green transition has been accompanied by certain decision-makers turning a blind eye to human implications in the way the sourcing of these materials has led to slave labour and deplorable conditions in, for instance, mines in the DRC. I know you have done a great deal of work on the Uyghur genocide, which is part of this, as well.
Do you agree that this is a problem, and is it critically important that we hold green industries to strong human rights standards and not allow a blind eye to be turned to human rights in the name of an aspired-for green transition?
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It's absolutely crucial, and it's crucial to do that in concert with allies.
We have to find ways of ensuring that the tariffs that are now being imposed by Canada itself—in a very welcome decision around tariffs imposed by Canada itself—but also by the EU do not find themselves circumvented by China through the development of electric vehicles in, say, Slovakia or perhaps other eastern European countries, and that there are no weak links in the chain of resilience.
Without that, it's hard to see how our electric vehicle industries are going to be able to survive when—you heard the numbers that I recited earlier—tens of billions of dollars of state subsidies have been pumped into them and the overcapacity is now so extraordinarily high that all of our domestic industries are on a hiding to nothing.
Absolutely, we need to do more to seed investment into our own electric vehicle manufacturing supply chain, but we need to ensure that we are resistant to the market distortion that China has become extraordinarily adept at meting out to our industries.
:
The European Union itself has just decided to impose tariffs on Chinese-made electric vehicles, and it's done that partly because last year, something in the region of well over 25% of electric vehicles in the European Union were produced in China.
The slight difficulty is that not every country in Europe has a similar relationship with the People's Republic of China. Some that decide not to impose bilateral tariffs or even unilateral tariffs might find themselves exploited as a market for Chinese electric vehicles.
For example, in my own country, the United Kingdom, which has not yet decided whether or not it will impose tariffs on Chinese electric vehicles, what that may mean is very cheap electric vehicles for U.K. consumers, but it's also going to mean an utter defenestration of the U.K. car industry, or what remains of it.
There's a bit of a disparity, just to answer your question, Mr. Sidhu, but I think there is clearly alignment between the European Union and Canada when it comes to tariffs, and that should be expanded to ensure that there is real trans-Atlantic resilience.
:
Thank you, Madam Chair.
I would like to thank the witnesses for their very useful presentations.
My first question is for the representative of the Inter-Parliamentary Alliance on China, or IPAC, of which I am a proud member, by the way, and which has members from several legislatures around the world.
Mr. de Pulford, on May 15, just before the G7 summit, you issued a statement outlining some of the priorities you wanted to see addressed at the summit. One of these recommendations was to coordinate responses to cases of economic coercion by any state actor, including China.
Do you fear that economic coercion measures could be put in place by China in response to the tariffs that have been implemented? What action do you recommend, if any?
:
Thank you very much indeed for that question. I think there are a couple of things to say about economic coercion.
The first, and perhaps the most important, is that we are still lacking a coherence in terms of our response. You might remember that in the case of Lithuania, which, it was argued, had illegally been coerced by Beijing, there was a case brought forward by the European Union at the World Trade Organization, which was recently dropped under slightly mysterious circumstances. We know that the European Union has an anti-coercion tool or mechanism, which we've not seen work. We also know that the G7 has come forward with various proposals to try to combat economic coercion, but we've not really seen it happen. All of that is to say, there's a lot of talk and not much action. Economic coercion is extremely difficult to deal with.
I tend to rather agree with the former secretary-general of NATO, who spoke about an economic article 5, that we need to find a way of ensuring that when one of our democratic number is bullied or singled out for economic coercion, we will all come together and do what we can to support them.
Quite an interesting example of this, without going on too long, was the Australian wine tariffs. After Australia had asked for an investigation into the origins of COVID, China imposed 220% tariffs on Australian wine, which could have caused some economic damage, but the rest of the world seemed to pick up and buy more Australian wine to deal with it. That would be a slightly fatuous example of an economic article 5 that might be something we can look at.
Briefly, we need to find a way of coordinating our response to economic coercion, and we need to make sure that the commitments we've had at the G7 and the European Union amount to something.
:
Thank you very much for the question.
Human rights due diligence is exceptionally important, particularly as we move toward an increasingly interconnected global economy. Unfortunately, in China, any due diligence, let alone human rights due diligence, is very difficult to perform. In fact, the consensus of human rights experts is that human rights due diligence in the Uyghur region is impossible to perform, for the simple reason that it isn't possible to take somebody who is Uyghur out of a factory and interview them freely with them speaking freely. In fact, they would probably suffer reprisals if they were to tell you about the conditions in the factory.
Basic human rights due diligence simply isn't possible in the Uyghur region, yet many big, multinational companies continue to source from that region knowing that human rights due diligence is not possible. I think what this tells us is that our human rights due diligence protocols are not up to scratch. They don't work.
You can see from a number of examples recently of companies withdrawing from Xinjiang that there is an acknowledgement that it's becoming more and more difficult. Here's one very good example, although it doesn't have to do with human rights. Staff from a German due diligence firm were imprisoned just the other day. They were imprisoned because China had accused them of espionage, which is something that happens routinely. The reality is that China didn't like them digging around in the details. Well, that's the job of people doing due diligence. If they're not able to do it in China, we need to ask ourselves some very serious questions about how we can continue to source from that region.
:
Thank very much, Madam Chair.
I want to thank the witnesses for being present with us today. The work you're doing is incredibly important.
I think Canadians, right now in particular, are in a position where they're combatting the reality that we have a severe vulnerability in our supply chain management. We saw that particularly throughout COVID, but now we're seeing it manifested across the globe. We're finding ourselves a stage back—maybe a place behind—particularly when it comes to some of the extreme dependencies mentioned by Mr. de Pulford.
Mr. Bickett, we reviewed your report, and there are some serious and extreme instances here that I think Canadians and our committee would do well to understand more. One of the key findings you discovered, according to your report, relates to this issue. I may be oversimplifying it, but please correct me if I'm wrong. Let's say Russia wants Canadian goods. Let's say they're parts of weapons and important, critical components. Hong Kong is being used as a particular port of entry for these markets, even against sanctions that would prohibit these particular goods that Canadians make from entering these kinds of illicit regimes.
Can you walk us through how something like that could take place, given Canada's existing sanctions regime?
:
There are a number of ways that this can happen. It's important to state that there are different types of goods here. There's been a lot of press around, say, a company like Texas Instruments, which has very cheap calculator parts. They're important for military goods, but they're very difficult to control.
There's a separate category, one that I spoke about in the introduction, like Vectrawave, which makes highly specialized and very expensive chips, or something more in the middle, like Nvidia, which makes relatively expensive chips that are relatively rare. They're very important for these advanced types of machines. Those more specialized categories are the ones that it is best to focus on.
What's happening is that you're not shipping these things directly to Russia from Canada, the United States or Europe. They're being shipped elsewhere, and often not actually to Hong Kong. Hong Kong doesn't release its customs records, and there's no way to access them, so we don't know exactly where they're coming from. They might be in several different places going around the world. What's important here is that certain companies have made it clear that unless governments crack down on them and, essentially, take steps to deter and enforce regulations against them, they're not going to do anything.
Recently, Nvidia's leadership gave an example that if the speed limit is 75 and they're going at 65, they're not breaking the law, and they're going to do it. That was in reference to them sending extremely advanced GPUs to China. China is then using those to advance its AI. That's the attitude you're getting from many businesses in North America and Europe. They are saying, “If you guys don't stop us from doing this, we're going to do it to the extent that we're able to do it.”
Right now, Canadian and American companies can send their goods to different places. They can do a few check marks. There was a great example we talked about in our report of a New York company that asked, through email, a man, a Russian citizen who was based in Hong Kong, to confirm that he didn't plan to send its advanced technology to Russia. He wrote in an email, “I will not send this to Russia.” He was sent a bunch of OLED displays that can be used in scopes for weapons.
There's that kind of example. They're going to do the minimum. Increases are needed on due diligence requirements, and enforcement against those who sort of put their heads in the sand like ostriches and don't do what they're supposed to do when it comes to really making sure their supply chains and distributors are doing what they're supposed to do.
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Part of what we've done, particularly since releasing this report, is meet with investigative agencies. We hear routinely that there's a need to strip away bureaucracy. You need to have approvals and you need to reach a certain level of evidentiary standards, but there's a need to make sure that this stays with people who are able to do this quickly and understand what's going on. That comes down to really letting these agencies do their job without having this get held up in a lot of review and things like that.
There's also just a need, frankly, for more budget and more people to be able to investigate these things. At this point, we've done more work with the U.S. government on this than the Canadian government, with understanding the weeds of that. To give an example here from the U.S. side on Russian sanctions evasions, the organization BIS, which is responsible for investigating these things, only has a very small number of people who are able to investigate this. Having done this ourselves in a private capacity outside of the government, it takes many months to pull together even a few names and pull together the evidence on them.
It shouldn't be two, three or four people who are in the government investigating these things. It should be dozens or more. There are hundreds of companies in Hong Kong alone, much less China or the Middle East and autocracies there, that have filled up these holes, filling the void and reshipping these things.
:
Thank you very much indeed for the question.
I think that what we can do, and what we have yet to do in a really meaningful way, is ensure that plurilateral trade agreements have very meaningful commitments to human rights due diligence.
I'll give you an example. Right now, the CPTPP does contain quite extensive provisions around labour. It has quite high labour standards, but in practice, they don't mean very much because you can more or less join that agreement if the members say you can. The assumption had always been that China would never be able to join the CPTPP. Their labour standards are way too low. The reality is realpolitik. They'll be able to join if the members say they can.
I think that ensuring that there are non-negotiable principles around shared values, human rights and due diligence in supply chains would be a very good start.
There's much more that we can do. I think there should be a coordinated reduction of dependency upon China, not just unilaterally—not just Canada saying that it's too dependent. We need democratic nations to come together and say, we have this common problem, so let's find a common solution. If it requires us to pool our resources in order to seed alternative markets, for example, let's do that. It's going to be much easier dealt with together than on our own.
:
I would say, in two ways. First would be through what people call cellular modules or CIMs, which are susceptible to remote manipulation because they require software updates from the manufacturers. There have been a number of reports, sadly, about remote access and remote manipulation of Chinese-made cellular modules in electric vehicles, including one in the United Kingdom. It was in a ministerial car, which was bugged as a result, so these are really very important national security implications around this.
In addition to that, a key point about data transfer is that we have, in the European Union, the general data protection regulation, GDPR, but the reality of that situation is that it doesn't really save us when it comes to data transfer to China. The reason is that it's still possible for any company to transfer to any partner company in China if they have contracts with each other and there are certain clauses in those contracts. Those clauses say that they will, of course, protect people's data. However, they don't, and they can't. The reason that they can't is that, in China, the intelligence security law of 2017 and a number of other pieces of legislation require every Chinese company to hand over data upon request and to deny that such a request has happened if they are asked. So, from a data protection point of view, that means that your data can be legally transferred to China, that the state may have access to it, that you will never know, and that the company is not permitted to tell you by law.
I'll really emphasize here that you'll hear Chinese companies—and we even see this with companies like TikTok, which are technically based in Singapore—assuring you that they don't want to turn over Canadians' information, that they don't want to violate people's privacy, that they want to work with you on these things. Frankly, a lot of the time they're telling the truth. These are guys who are capitalists, and they want to make money. However, what they won't tell you is that they don't have a choice in the matter. If they are operating out of China, if they are a Chinese company or if they have connections to China even if they're officially based internationally, if they are asked for personal information, they will provide it. If they are told in a dispute, in a war or anything like that to trigger problems with their technology across the world to attack infrastructure, they will have to do it.
All of these things are major national security concerns. I think that Canada and the west have long benefited from free markets, and that has been a very helpful thing to the world. However, we can't do that at the expense of national security. There needs to be a much clearer-eyed view of what's going on here.
:
Thank you, Madam Chair.
Mr. de Pulford, you spoke, in response to my colleague's question, about the differences between the American government's relative success in stopping products made with forced labour coming into the United States, and about Canada's catastrophic failure in preventing products involving forced labour from coming into our country.
You mentioned legislative differences between Canada and the United States, and you also mentioned potential issues of capacity. It has always seemed to me, though, that we can address the capacity challenges by having effective alignment among democracies. You understand that it's difficult to trace origins and that digging into supply chains can be complex, but if we collaborated more effectively with like-minded allies so that we could be sharing information, we would ease any capacity pressures and ensure that we would be succeeding at the level of our allies.
I would like to see a situation where, if a shipment is turned away from Seattle because it has products made with forced labour, it can't simply go and dock in Vancouver, so that we're benefiting from American experience and know-how and, really, the bipartisan work that's been done there. I also wonder if this kind of framework for collaboration could be extended to more allies, and if we could establish some kind of partnership involving our North American economies but also Japan, the U.K., Europe, etc.
What do you think about the possibility of establishing some kind of effective alignment on preventing products made with forced labour from coming into our economies and sharing information in the process?
:
I think the point I was making is that what's so revolutionary about the Uyghur Forced Labor Prevention Act is that it provides that you cannot import anything from there. It's not just a whole phone; it's also the bits. It's the constituent parts, and that makes a big difference.
I was coming to address your point. Complexity is not a reason not to do it, and we do have some interesting new tools. For example, with organic materials, there are companies like Oritain. Oritain isn't the only company. There are companies like Oritain that have isotopic maps of various parts of the world and have technology so sensitive that they can take a hair on your head and tell you where you've been over the past six months. Any organic material they can test, and they can tell you whether or not it comes from Xinjiang.
We don't need to be doing this all-encompassing thing here. We can spot-check companies, and some companies do have contracts with Oritain and other similar organizations. There are ways around this. I don't believe in the capacity argument. It's a question of political will, but we do have to have the legislative tools, and at the moment, I believe that really only the U.S. does when it comes to Uyghur forced labour.
:
I'm not an expert on Canadian law, but we think the biggest thing that Canada has done—which I'm very approving of—that can potentially address some of the shortfalls in the sanctions program is revise the law to permit third-country sanctions. Again, it hasn't been used yet. In particular, if you're going to address something like a rampant effort by multiple countries to evade Canadian sanctions through trade companies, you're not going to be able to end that by just sanctioning the ultimate beneficiaries of that in Russia and Iran. You have to sanction the evaders. Even that, as we were talking about earlier, is not really going to change that much, because they can simply start a new company. They can always find new people to do it.
Ultimately, what we would really like to see—what we've been really emphasizing in Canada, the United States and the EU—are sanctions against some of the infrastructure companies, particularly, and most important of all, financial firms. The new sanctions authority that Canada has given itself allows that to happen where there are regional banks—in Asia, in particular—that we know are financing quite a bit of this illicit trade. You don't have to sanction the Bank of China, but if you sanction a smaller regional bank, every other bank will fall in line.
As I mentioned earlier, when it comes to corporates and financial firms, they will fill the holes and push the limits as far as they can. Really, the only way to get them to revise how they're acting is to issue some sanctions and to set a few examples. They will then revise their due diligence programs. They will very quickly stop doing the things that they do.
In short, I would say that there's been progress in revising the law—and that's great to see—but we would really encourage more use of the new tools that are available.
:
I call the meeting back to order.
My apologies for the delay, but we'll make sure that you get sufficient time to make your points with the committee.
We have, from the Canadian Institute of Steel Construction, Keanin Loomis, president and chief executive officer, and from Kal Tire, we have Corey Parks, president.
Welcome to all. We will start with opening remarks and proceed with a round of questions.
Mr. Loomis, you have up to five minutes for your presentation.
:
Thank you for inviting me to present my brief on behalf of the Canadian Institute of Steel Construction on this very important topic.
Established in 1930, CISC is Canada's voice for the steel construction industry, promoting the use and benefits of steel in construction and supporting the needs of the membership and industry through technical expertise, knowledge transfer, research and development, industry codes and standards, and certification and advocacy.
We represent the steel manufacturers, fabricators, suppliers, constructors, engineers and architects who are building with steel in Canada. Steel is a strong, adaptable material that is sustainable, cost-effective and resilient, among many other benefits, making it a reliable choice for building Canada's vital infrastructure.
I want to begin by commending the federal government for the measures, which were supported by all parties, announced on August 26. The CISC is supportive of the 25% surtax on imports of steel and aluminum products from China under section 53 of the Customs Tariff, which we, in conjunction with the Canadian Steel Producers Association, advocated for the government to introduce.
Our fabricators are generally supportive of creating a strong domestic steel industry. They recognize China as a bad actor in the fabricated steel industry and, most importantly, recognize that it is in our best interests to protect access to and harmonize with our closest trading partner, the United States. However, it must be acknowledged that Canada does not domestically produce all the raw steel that our members need to build in this country. While CISC encourages domestic production, we recognize that at present our members must have access to outside markets to build the high-rises, hospitals, schools and bridges our country needs.
Since much of the steel we buy is from the United States and our fabricators do a significant amount of cross-border work, the Department of Finance and other relevant departments must work closely with their U.S. counterparts to support harmonization in our ongoing response to China's unfair trade practices.
We also appreciate the government's intentions with the recently announced remedies to support stakeholders facing supply chain shock due to the recently announced tariffs. While these remedies are well intentioned, we caution the government to be selective in applying remedies to ensure that the objectives of the tariffs are fulfilled and that Canadian domestic materials continue to be prioritized. The remedy application process should require that the supplier operates under the same rules as our domestic suppliers do for any remedies to be granted. While we commend measures introduced thus far on raw Chinese steel, there is more work to be done to support the domestic steel industry and Canada's larger economy against unfair trade practices.
The current tariff regime is ambiguous as to the steel that has been melted down and poured in another country or as it pertains to downstream steel products, which is steel that has been fabricated or, for example, incorporated into our household appliances. Omitting downstream products from the list enables loopholes for bad actors to continue to exploit. Fabrication is the real value-add in the steel industry, where our members take raw steel and engineer and craft it for our building purposes, all with safety, quality, sustainability and cost-effectiveness of national infrastructure projects top of mind. This is very engineering-intensive and high-tech, and it requires skilled labour.
Failing to protect Canada from imported fabricated steel products will result in losing this vital skill from our domestic manufacturing knowledge base. We need to protect our Canadian manufacturing industry's ability to build well with steel, to support our infrastructure needs and to quickly and safely respond to environmental crises, such as the Fraser Valley flooding in 2021, in which steel bridges were rapidly deployed to restore transportation corridors after several bridges were washed out. Our members were among the very first responders in that natural disaster, and as we face many more, we need to continue to have this important domestic capacity.
The push to extend the tariffs to downstream products has gained support in the United States as well, with the bipartisan congressional steel caucus last month calling on the Department of Commerce to expand section 232 protections for certain downstream products, including fabricated structural steel. In the interest of continuing to achieve harmonization with the United States and protect this cross-border industry, we should be expanding section 53 tariffs on the same.
To further support the steel industry and the highly skilled engineers and tradespeople who fabricate and innovate our country's steel infrastructure, the CISC recommends that the government establish fabricated-in-Canada requirements in the construction of all taxpayer-funded and taxpayer-supported manufacturing projects, including those that support the transition to a low-carbon economy, such as EV and battery plants.
Our communities receive a four-time return on investment when we utilize Canadian fabricators to build our infrastructure. The overall economic success of the steel industry, like other sectors of construction, is shaped by the economic boost in opportunities that arise from big projects, particularly government-funded projects. Canadian taxpayer-funded projects should not be awarded to companies purchasing foreign fabricated steel in countries that lack reciprocal procurement policies.
Once again, thank you to the committee for inviting me to appear on behalf of the Canadian Institute of Steel Construction.
I look forward to your questions.
My name is Corey Parks. I'm the president of Kal Tire, which is a family-owned Canadian company based in British Columbia. We employ over 4,800 people in Canada and are one of the country's largest independent tire dealers. We're the largest remanufacturer of truck and bus radial tires, which are also called TBR tires.
Canadian industry and consumers are threatened by the dumping and subsidizing of low-quality, single-use Chinese truck and bus tires. I'm here today to ask you to include the retreading industry in the protections being considered for electric vehicles, aluminum and steel. I will share some background on our industry, discuss the economic, affordability and environmental implications of these unfair trade practices, and ask you to consider the urgent need for action to protect Canadian interests.
In 2023, the Canadian tire industry contributed approximately $7.1 billion to the economy. It represents a vital part of our national transportation and supply industries, directly supporting tens of thousands of Canadian jobs and indirectly supporting many others.
The truck and bus radial tire market and its associated remanufacturing sector annually contribute $2.3 billion to the economy and are especially important. Remanufacturing of tires, which is often called retreading, adds a new tread to a used tire casing, extending its lifespan. Retreading has been a well-established and integral component of the transportation sector in Canada for over 70 years. Today, roughly 50% of all truck and bus tires on the road are retreaded tires.
Retreaded tires are a popular, sustainable and cost-effective alternative to new tires, which reduces waste and carbon emissions by 70% per tire when compared to new tire production. Further, our experience indicates that one quality tire can be retreaded three or more times and can cover the same distance as 12 low-cost, low-quality, single-use tires.
The retread industry is threatened by waves of low-quality, single-use tires imported from China at prices below the raw material costs of the commodities needed to manufacture them. These tires enter Canada supported by non-market practices, including government subsidies and weaker labour and environmental standards, making it impossible for the domestic industry, tire producers and retread industry to compete. These low-quality, single-use tires are poorly made and do not have the structural integrity to effectively and safely accept retreads. As a result, increased tire waste is being sent to Canadian landfills.
In short, this unfair competition threatens our domestic industries by depressing prices, discouraging local investment, filling our landfills with unnecessary waste and risking elimination of thousands of Canadian jobs.
If unfairly traded imports of truck and bus tires continue, the retread industry will likely disappear and Canada's transportation sector will rely on Chinese imports to maintain operations. Ensuring that the retreading sector can compete on a level playing field will strengthen our supply chain and help Canada keep its economy independent from foreign economic influence.
Our key allies, including the United States, the European Union and the United Kingdom, have already implemented measures to protect their truck and bus tire manufacturing and retreading industries from unfairly priced Chinese imports. In 2019, the U.S. imposed up to 90% duty on truck and bus tires manufactured in China. The duty was renewed just this year. Unfortunately, Canada is now the only major western nation where dumping of these Chinese-manufactured TBR tires still occurs, and it's gaining momentum.
To safeguard the Canadian industry, economy and environment, we urge you to support a 109% surtax on truck and bus tires manufactured in China. This step would promote fair competition, protect thousands of jobs, safeguard our supply chain and support Canada's environmental goals. Countering unfair trade practices is essential to Canada's economic and environmental well-being and the survival of this industry.
I would like to end with three points. First, Chinese tires are being dumped and subsidized in Canada at prices below the raw material costs needed to make those tires. Second, the growing presence of these tires in Canadian markets is threatening the very existence of the remanufacture industry in the short term and the stability of the transportation sector in the medium and long term. Finally, western nations that have implemented duties to stem the dumping and subsidizing of these tires into their countries have returned market stability and fair competition to their domestic tire and transportation industries and have ensured a more level, market-based economy for these products.
Finally, I want to thank you for the invitation to appear before this committee. As a growing independent business in Canada, this is a very intimidating place to find ourselves. However, it's important to me that each of you know how much it means to each of these thousands of Canadians that you are interested in hearing about the very real threat that these dumped tires pose to their jobs, to the tire and transportation industries at large, and to the broader Canadian economy.
I'm happy to answer any questions you may have.
:
Okay. We believe that the harmonization of tariffs is fairly important.
There's very little domestic production of tires here in Canada. There are a couple of Michelin plants in Atlantic Canada that we're familiar with. The majority of their product gets exported back to the United States. Most of our tires here in Canada on the truck and bus side come from the U.S. or from Asian markets.
For 70 years, we've seen a lot of discipline in that market—at least the 70 years we've been around—where pricing goes up and down in terms of where it makes the most sense to make product, but we've never, ever seen something that is sold so far below the raw material costs that we can't even compete. We can't retool our factories. We can't invest. We won't invest in retooling these production lines when we can't even get into the ball game on the raw material costs, so in terms of our work with the U.S., it has been very light here at Kal Tire.
What I can tell you is that the Americans have a tremendous advantage when it comes to putting the tariffs in through the normal World Trade Organization process, and that advantage is the United Steelworkers. The manufacturers of these tires are very unwilling to sit at the table and push for these tariffs when they have manufacturing that is not being subsidized in these markets, in the China market, where they're making other products beyond tires. Michelin and Goodyear make things beyond tires.
In the U.S., the United Steelworkers were the ones who brought the petition and could get into the process. That's an almost impossible task for us in our industry, because it's such a collection of smaller businesses. We see ourselves as a small business. We know we're not small—we're the largest player by a long way in Canada, in this market—and we can't get ourselves in front of that commission without a lot of work to try to find our way there, which is what led us to you here at this hearing.
:
Thank you, Madam Chair.
Thank you to all of the witnesses for their presentations.
On August 26, the Aluminum Association of Canada and the Canadian Steel Producers Association published a joint press release to support the announcement of Canadian tariffs and to state that Canada refuses to be “a point of entry for unfairly traded and high carbon steel and aluminum imports”.
According to these two associations, in Canada, there are 18 active anti‑dumping cases against China for primary forms of steel. Furthermore, 56% of all of Canada's trade cases concern China. However, despite the high number of dumping cases, steel from China is booming. In recent years, it has even doubled on the Canadian market.
Mr. Loomis, what isn't working in the trade remedy system?
:
I think you heard from the Canadian Steel Producers Association, when they gave testimony not too long ago, that the trade remedy system is broken. That is certainly one of the issues that we are finding. Even if you have a clear trade case to bring, you have to think long and hard before doing so because of the length of time and the amount of money required to enforce your WTO rights.
The big thing here is that, just as my colleague is facing.... It is really easy, of course, to go to the bottom line and to talk about price. What we are trying to sound the alarm on is that there's a huge risk there, too, when it comes to quality. The big issue for us is that.... If these tariffs are in place and then the price issue is equalized, we'll be able to make much higher-quality decisions when it comes to the purchasing of steel.
Again, in referring to my colleague, I have had members of mine say that when they bid on a project—we're not even talking about publicly funded projects, but an oil sands project, for example, in northern Alberta—even if they zero out their labour, they're not able to compete on price. The issue here is that it's far too easy, and the bottom line is controlling our decision-making far too much in this industry.
:
Thank you very much, Madam Chair.
Thank you to the witnesses for being present with us.
It's an important study that we're undertaking related to steel, of course, as there are many Canadians who are involved in this. Whether they're employers at a shop level or whether they're executives, this is an issue that's pertinent to industries across the country. Because of the immense issue presented by China and its extreme steel and aluminum dumping here, there are actions that have largely been undertaken. That's why you're here today. The minister came out equalizing some of these tariffs with our American counterparts to ensure that much of the steel industry here is protected.
Mr. Loomis, you mentioned that part of your association's goal is to encourage domestic production of steel, which is, of course, good. We want to see more of that. It would probably solve many of the issues you're explaining today if we had more domestic production. On U.S. partnership and harmonization, I think that's an encouraging path forward, both for Canadians, who have a huge dependency on those markets, and for our contractors, who depend on those stabilizing prices to build.
The supply chain shock issues are also interesting to me. I want to explore with you how the supply chain has been shocked by this. Of course, producers—those who utilize steel—are reeling. Part of my line of questioning is on how those who are either purchasing steel domestically or have a former arrangement with Chinese steel, for example, are impacted. How do we create more resilience for those persons?
More recently, the mentioned that, in light of all this, on October 15, she may consider some tariff relief for some industries. Do you support the exemption for certain industries?
:
I would argue that we can't survive in the long term without strong measures in this industry, and I would point to a couple of reasons for that.
Your comment that we are surviving is probably accurate. We are barely surviving. We are operating many of these retread plants below cost. We are losing money on every tire we sell, because we're trying to make money on the service piece. That is not sustainable in the long term.
To your other questions, about the long- and medium-term impact to the industry, I think it's very significant. We happen to have 290 stores across Canada coast to coast. We are in many small towns and jurisdictions where you would not normally have a tire business. We are able to do it because we're a small passenger and light truck business, and there's a bustling natural resource industry, whether it be forest products, mining, you name it. In the absence of being able to compete, some of those stores risk closure. When you start to close those stores over the long term, that's a material impact to the industry and, I think, to the transportation industry at large.
I would like to add one last thing, if I might. Every bit of the steel that we're talking about in this conversation is being moved from the plant to its final destination on these exact tires.
:
Thank you very much, Madam Chair.
To continue on that frame, you've mentioned several times now that Canada is not the bad guy here; it has to be Mexico. This is something that occurs often in various committees, not particularly this committee, where we see that attempt to maybe obfuscate—I don't want to attribute negative malice—what is our issue here. There are domestic steel production issues, like dumping from foreign enterprise into Canada. We have weaker safeguards than our American counterparts. That's a fact that's true.
You're also mentioning a very important fact, which is that in addition to Canada's vulnerabilities, Mexico is hyper-volatile in the action of disrupting our stability for supply chain security for steel manufacturers here.
Can you explain what you mean when you say “investment in Mexico”? Are you talking about investments into capital projects, or investments into innovation, science and technology, or investments into supply chain resiliency, for example? Where is that investment into Mexico and how is it damaging Canadian steel users, manufacturers and producers?