Vol. 141, No. 26 — December 26, 2007

Registration
SOR/2007-307 December 18, 2007

MOTOR VEHICLE SAFETY ACT

Regulations Amending the Motor Vehicle Safety Regulations (Importation of Vehicles — Section 12)

P.C. 2007-2024 December 18, 2007

Whereas, pursuant to subsection 11(3) of the Motor Vehicle Safety Act (see footnote a), a copy of the proposed Regulations Amending the Motor Vehicle Safety Regulations (Importation of Vehicles — Section 12), substantially in the form set out in the annexed Regulations, was published in the Canada Gazette, Part I, on December 1, 2007 and a reasonable opportunity was thereby afforded to interested persons to make representations to the Minister of Transport, Infrastructure and Communities with respect to the proposed Regulations;

Therefore, Her Excellency the Governor General in Council, on the recommendation of the Minister of Transport, Infrastructure and Communities, pursuant to subsections 7(2) and 11(1) of the Motor Vehicle Safety Act (see footnote b), hereby makes the annexed Regulations Amending the Motor Vehicle Safety Regulations (Importation of Vehicles — Section 12).

REGULATIONS AMENDING THE MOTOR VEHICLE SAFETY REGULATIONS (IMPORTATION OF VEHICLES — SECTION 12)

AMENDMENT

1. Section 12 of the Motor Vehicle Safety Regulations (see footnote 1) is amended by adding the following after subsection (4):

(4.1) For the purposes of subsection 7(2) of the Act, a vehicle that has been sold at the retail level in the United States and that has not been certified by the manufacturer as conforming to subsection 114(4) of Schedule IV to these Regulations may be imported into Canada despite not being certified to conform to subsection 114(4) if

(a) the vehicle was fitted at the time of manufacture with an electronic immobilization system; or

(b) the person importing the vehicle states in their declaration that the vehicle

COMING INTO FORCE

2. These Regulations come into force on the day on which they are registered.

REGULATORY IMPACT ANALYSIS STATEMENT

(This statement is not part of the Regulations.)

Description

Starting September 1, 2007, vehicles manufactured for sale in Canada and imported into Canada, have been required to be equipped with an electronic immobilization system. The introduction of this requirement has resulted in the need to clarify the process for importation of motor vehicles sold at the retail level in the United States. This clarification is needed as vehicles which were purchased in the United States by many Canadian consumers, shortly after the introduction of the immobilization requirements, are being denied entry into Canada. This amendment will mitigate the economic hardship to Canadian consumers who have purchased vehicles in the United States and are unable to license them in Canada.

This amendment modifies section 12, Importation of a Vehicle Purchased in the United States, of the Motor Vehicle Safety Regulations (MVSR), to clarify the vehicle theft immobilization requirements for importation of vehicles into Canada that are sold at the retail level in the United States. This amendment clarifies that vehicles sold at the retail level in the United States, that are equipped at the time of manufacture with an electronic immobilization system, may be imported into Canada and that those vehicles that do not have an electronic immobilization system can be imported if the vehicle is fitted with an aftermarket immobilization system.

This amendment will offer more flexibility to vehicle importers while maintaining comparable safety requirements for imported vehicles as are provided by vehicles sold at the retail level in Canada. This amendment will not impose any new requirement on vehicle manufacturers or importers; rather it facilitates consumer choice and clarifies the importation process for vehicles regarding theft immobilization systems, while maintaining safety for Canadians.

Background

The Canada Motor Vehicle Safety Standard (CMVSS) 114, Theft Protection and Rollaway Prevention, hereafter referred to as the Canadian safety standard, governs the design and performance of theft and inadvertent rollaway protection. This Canadian safety standard was modified in 2005 (see footnote 2) to include the requirement that every light duty, non-emergency vehicle, must be equipped with an electronic immobilization system as of September 1, 2007.

The Canadian safety standard includes the following requirements:

•   Starting September 1, 2007, every passenger car, every three-wheeled vehicle and every multi-purpose passenger vehicle and truck with a gross vehicle weight rating (GVWR) of 4 536 kg or less except walk-in vans and emergency vehicles, must be equipped with an immobilization system that, at the option of the manufacturer, meets one of the following standards:
  •   National Standard of Canada CAN/ULC-S338-98, entitled Standard for Automobile Theft Deterrent Equipment and Systems: Electronic Immobilization; (see footnote 3)
  •   Part III of ECE Regulation No. 97, entitled Uniform Provisions Concerning the Approval of Vehicle Alarm Systems (VAS) and of Motor Vehicles with Regard to Their Alarm Systems (AS); (see footnote 4)
  •   Part IV of ECE Regulation No. 116, entitled Uniform Technical Prescriptions Concerning the Protection of Motor Vehicles Against Unauthorized Use. (see footnote 5)

The requirement for vehicles to be equipped with electronic immobilization systems was prompted by research, (see footnote 6) which indicated that the installation of immobilization systems that make it difficult for the car engine to be started would reduce vehicle theft. Immobilizers are noted for significantly reducing theft for convenience, which frequently involves youth offenders. Studies have estimated the direct dollar losses from motor vehicle theft in Canada to be $600 million per year. (see footnote 7) Furthermore, these studies have demonstrated that an average of 244 to 345 serious injuries and 11 lives could be saved each year if immobilization systems were installed on all Canadian vehicles.

During the development of the Canadian safety standard, Canada focused its efforts on improving road safety by reducing theft for convenience, which frequently involves youth offenders. Youth offender theft presents a significant road safety issue as youth have limited driving experience and often engage in risky behaviours when driving stolen vehicles. Thus youth theft significantly increases the risk of injury and death to themselves, the other occupants of the vehicle, other road users and police officers.

While Canada has focused its safety efforts on reducing theft for convenience by making the vehicle difficult to steal, the United States, National Highway Traffic Safety Administration (NHTSA), has focused its efforts on the identification of vehicles that have been stolen for profit, in other words, vehicles that have been stolen with the intention of disassembling them and selling the individual parts. This regulation is specified in Title 49, Part 541 of the Code of Federal Regulations, Federal Motor Vehicle Theft Prevention Standard, requiring that several parts of passenger cars and some trucks be marked for identification purposes.

The NHTSA parts marking regulation includes the alternative of installing theft protection devices as an option in lieu of parts marking, in some specific instances. It also provides, in its Federal Motor Vehicle Safety Standard 114, (see footnote 8) the exclusion of steering locks for vehicles equipped with theft systems. Thus the NHTSA does support in certain instances the installation of theft protection systems. While there is no specific standard or performance requirement for immobilization systems, installed on vehicles sold in the United States, manufacturers must prove to the NHTSA that their theft protection systems are effective. There are currently over 120 vehicle models which have been deemed by the NHTSA as having effective immobilization theft protection systems in lieu of parts marking.

The absence of a technical performance requirement for theft protection systems in the United States has resulted in an issue with regards to the importation into Canada of vehicles sold at the retail level in the United States. Since September 1, 2007, many Canadians have purchased vehicles in the United States and have not been able to import them into Canada. As the Canadian and United States vehicle safety regulatory regimes are highly harmonized, it is common practice for vehicles sold at the retail level in the United States to be imported into Canada, as provided for under the North American Free Trade Agreement. With the advent of the strong Canadian dollar there has been an upward trend in the volume of vehicle importations from the United States into Canada from 28 019 vehicles in the year 2000 to 112 826 in 2006, and to a projected 160 000 vehicles for 2007. (see footnote 9) This upward trend has also been particularly amplified by the surge in the strong Canadian dollar in the second half of 2007.

This amendment clarifies that vehicles sold at the retail level in the United States, that are equipped at the time of manufacture with an electronic immobilization system, may be imported into Canada. In addition those vehicles that do not have an electronic immobilization system may be imported if the importer declares that an aftermarket immobilization system that conforms to the National Standard of Canada CAN/ULC-S338-98, entitled Automobile Theft Deterrent Equipment and Systems: Electronic Immobilization will be fitted and the importer declares in writing that they will install such a system before registering the vehicle under the laws of a province. Importers of vehicles that require the installation of aftermarket immobilization systems will need to obtain certification from the Registrar of Imported Vehicles (RIV) that the vehicle immobilization system is in accordance with the National Standard of Canada CAN/ULC-S338-98.

This amendment will deem electronic immobilization systems as being acceptable on vehicles imported from the United States by Canadians. Electronic immobilization systems are very difficult to defeat as they have typically over 50 000 different code combinations for the electronic signal. In addition, they frequently require the use of software to allow for the replacement of the vehicle key (transponder) or other system component. Even with the requisite knowledge, replacement parts and the computer software, many systems have a built in replacement time lag so that any component cannot be immediately replaced and the vehicle driven; often it must sit for 5 minutes or more. These features, which are built into electronic immobilization systems, greatly restrict the ability of vehicles to be stolen for convenience.

A large number of manufacturers deem their U.S. models to be in compliance with the Canadian immobilizer standard. In other words they have been voluntarily offering the Canadian level of theft protection to their U.S. customers. However, several Canadian vehicle manufacturers have noted that they cannot be certain that the immobilization systems on their vehicles sold in the United States would meet the Canadian Safety Standard. In addition, manufacturers are reluctant to publicly share the technical information on any potential differences between vehicles destined for the United States and Canadian markets. Information on how to defeat anti theft immobilization systems should not be commonly available and thus it is in the best interest for the safety of Canadians to find an alternative means of certification for vehicles sold at the retail level in the United States which will be imported into Canada.

Some manufacturers have also noted concern regarding tampering with the electronic system of the vehicle in the event that an aftermarket electronic immobilization system would be required. Manufacturers have noted that they cannot ensure that such features as air bag activation will not be compromised. Finally, installing two electronic immobilization systems can create technical challenges and in-use problems as each system uses an antenna, which can result in interference issues. Requiring the installation of a second electronic immobilization system would also be unnecessarily expensive.

During the development of the Canadian safety standard clear evidence was brought forward by the insurance industry noting that it is possible to defeat mechanical immobilization systems with limited knowledge and using only simple tools. If the installed system is mechanical there will not be any interference between it and any additional electronic immobilization system. Thus, regardless of the presence of a mechanical immobilization system, this amendment clarifies the requirement for the installation of an aftermarket immobilization system that meets the National Standard of Canada CAN/ULC-S338-98 standard, entitled Automobile Theft Deterrent Equipment and Systems: Electronic Immobilization (May 1998), published by the Underwriters' Laboratories of Canada. The CAN/ULC-S338-98 standard has been chosen because it is recognized by the insurance industry as a reference for aftermarket immobilization systems and electronic immobilization systems meeting this requirement are readily available in Canada for aftermarket installation.

Manufacturers of vehicles sold into the United States have all strongly noted that they do not have the capacity or the interest to develop aftermarket electronic immobilization systems for a vehicle that does not have an electronic immobilizer installed at the time of manufacture. Manufacturers have also clearly noted that they do not support the installation of aftermarket immobilization systems and that the installation of such systems may result in future electrical failures. As a result they have asked the Government of Canada to remove the proposed requirement that manufacturers identify the vehicle models that cannot be fitted with an aftermarket immobilizer. Some manufacturers have noted that they will be informing Canadian consumers that there will not be any warranty on the electrical system of their vehicle if it is modified to add an aftermarket immobilization system.

In addition to the manufacturers' concern regarding the installation of aftermarket immobilization systems, the Government of Canada received over 100 e-mails and telephone calls from Canadians regarding the proposal. Many of the comments included the similar request for the Government of Canada to remove the proposed requirement that manufacturers identify the vehicle models that cannot be fitted with an aftermarket immobilizer. Canadian consumers are concerned that manufacturers would simply indicate that all of their non-electronically immobilized vehicles could not be modified.

Based on the comments received, the Government of Canada has agreed to remove the requirement for the manufacturers to indicate which vehicles cannot be fitted with an aftermarket immobilizer.

While the Canadian safety standard allows for the installation of both European ECE and Canadian ULC approved systems, this amendment will permit the aftermarket installation of systems meeting CAN/ULC-S338-98 on vehicles that don't have an electronic immobilization system. This requirement is not expected to cause any burden on importers as ULC approved aftermarket systems are readily available in Canada and there is a corresponding standard, ULC/ORD-C275.1-00, Installation of Aftermarket Automobile Theft Deterrent Devices, relating to the installation of these devices which the installers can follow.

This amendment will facilitate the importation of vehicles sold at the retail level in the United States to be imported into Canada. All imported vehicles which have an electronic immobilization system will not need further modification and vehicles which do not have an electronic immobilization system at the time of manufacture will be required to be fitted with an aftermarket one which meets the CAN/ULC-S338-98 standard.

Consumers will need to verify the list of vehicles that can be imported by reviewing the list maintained by the Department of Transport or contacting the manufacturer of the vehicle.

Alternatives

Status quo

This alternative would continue to have a negative effect on consumer choice. This would prevent the importation into Canada of many vehicle model which do not represent a safety disadvantage to the Canadian public.

Eliminate the requirement for imported vehicles to have an immobilization system

Allowing the importation of U.S. vehicles without immobilization systems will, in the cases of vehicles sold without immobilization systems, reduce safety and result in vehicles that can easily be stolen. Past research has shown that once young offenders are aware of how to easily steal one vehicle model, the information spreads quickly and that vehicle model becomes a target for youth theft. This option has been rejected because it could potentially negate the tremendous success that has been achieved in Canada due to the continued efforts of the insurance industry and several vehicle manufacturers to move towards the voluntary installation of vehicle immobilizers.

Allow the importation of vehicles from the United States which have an electronic immobilizer without modification and permit the installation of an aftermarket immobilizer on the remaining vehicles

This option will facilitate consumer choice by permitting Canadians the choice to purchase vehicles at the retail level in the United States while maintaining comparable safety requirements for these vehicles. This alternative has two components: accepting vehicles equipped with electronic immobilization systems installed at the time of their manufacture; and, allowing vehicles which have a mechanical immobilizer, or alternatively have no immobilizer, to be fitted with aftermarket immobilization systems that meets the requirements of the CAN/ULC-S338-98 standard.

Requiring a vehicle to be equipped with an electronic immobilization system has been shown to significantly decrease the risk of property loss, injury and death. This option also stipulates the requirements for the installation of aftermarket systems and clarifies when an aftermarket system is needed, thus maintaining the same level of safety for Canadians as would be provided if the vehicle were sold at the retail level in Canada. In addition, it only requires that an aftermarket immobilization system, which is estimated to cost $300 to $600 per vehicle, be installed if needed.

Benefits and costs

These Regulations will benefit Canadian consumers by permitting them the choice to purchase vehicles at the retail level in the United States, while maintaining comparable safety requirements for these vehicles to be equipped with an acceptable immobilizer. This amendment maintains the desire for advanced theft protection systems recognizing that there are no immobilization standards in the United States.

This amendment will not have any significant cost implication. Consumers will not have to bear additional cost for vehicles that are already manufactured with electronic immobilization systems. They may, however, need to assess the cost of installing aftermarket immobilizers for vehicles that are not fitted with one at the time of manufacture. Such cost may range from $300 to $600, depending on the vehicles, and is part of the cost to ensure that their vehicles comply with the Canadian safety standards. Recognizing that ECE approved immobilizers meeting the Canadian safety standard are not available for aftermarket purchase in Canada, importers are therefore not required to install aftermarket immobilizers that meet such standards, and as such the CAN/ ULC-S338-98 standard remains the sole aftermarket performance requirement for immobilizers.

This amendment is not expected to have any significant negative security impact on Canadians.

Consultation

Specific consultations

Prior to the publication of the amendment, the government had experienced a rising volume of telephone calls and letters from the public as a result of the increased number of vehicles which could not be imported from the United States and licensed in Canada. The Government maintains several 1-800 call centres to provide aid to Canadians. The Department of Transport maintains a call centre for issues pertaining to vehicle safety and importation. These operators have been receiving up to 500 telephone calls per day from Canadians interested in additional information on the importation of vehicles.

The RIV (www.riv.ca) operates the national program of vehicle inspection, certification and registration on behalf of Transport Canada. Coincident with the rise in the Canadian dollar and with the introduction of the Canadian safety standard for theft protection the RIV has been receiving between 5 000 and 7 000 calls daily regarding the importation into Canada of vehicles sold at the retail level in the United States.

In November 2007, prior to the publication of the proposed amendment on December 1, 2007, the Department of Transport completed two teleconference consultations to help develop the best alternative to move forward. Over 175 stakeholders were invited to each of the sessions. There were several options put forward to facilitate the discussions. These consultations did not bring to light any new unforeseen issues or options.

Following the pre-publication, Department of Transport officials completed three additional teleconferences, which invited almost 200 stakeholders to provide their comments on the proposed amendments. Consumers, consumer advocates, insurance associations, provinces and territorial representatives, vehicle manufacturers and representative associations and aftermarket immobilizer installer groups were all represented at these consultations.

In summary, there was broad support from the consumers and their representatives for the requirement to have effective vehicle theft protection systems in Canada. There was unanimous support by consumers to move forward with the proposed amendment to provide relief for Canadians who have purchased vehicles in the United States which do not meet the Canadian immobilization requirements. Many consumers noted their concern that a means of maintaining the list of admissible vehicles current and stable has to be developed. This is needed to allow consumers sufficient time to complete the process for importing their vehicle prior to the list being amended to deem their vehicle inadmissible. This issue will be reviewed to establish a means of providing notice that a revision to the list is forthcoming. Finally, virtually all consumers requested the removal of the proposed requirement that manufacturers identify the vehicle models that cannot be fitted with an aftermarket immobilizer. These consumers requested that any consumer should be allowed to modify a vehicle which does not have an electronic immobilization system. The Government of Canada has agreed with this position and has modified the amendment. Consumers who install aftermarket immobilization systems will be warned that they will be accepting the risk of modifying their vehicle and that they will be at risk of having their vehicle manufacturer warranties voided (e.g. for the electrical system of the vehicle).

During the teleconference consultations, the aftermarket immobilizer installers noted several concerns with the details of the proposal, including the proposed cost and the need to require the ULC installation standard as part of the regulation. They also noted concern with the requirement that manufacturers could block the importation of vehicles without immobilization systems by noting that the vehicle could not be fitted with an aftermarket immobilizer. In light of their comments the cost of installing immobilization systems has been modified to reflect the range of anticipated costs across the country of $300 to $600. They noted that the cost of specialized systems might be more expensive. Given the range of additional cost for aftermarket installations, consumers are advised that they will need to assess the total cost to bring their vehicles into compliance with the Canadian requirements before they purchase their vehicles in the United States. The government did not modify the requirement to introduce the installation requirement of ULC/ORD-C275.1 as it does not meet the criteria for an incorporated document in a federal regulation. Finally, the request to allow modifications to vehicles that do not have electronic immobilization systems was the same request as was made by the consumers and the manufacturers and this change has been made in the amendment.

More than 100 emails were received from Canadians who expressed their support for the proposed amendment. Many of these Canadians echoed the request that the proposed amendment allow modifications to all vehicles that do not have electronic immobilization systems. Many also noted concern for the cost of importation and for the need to obtain from manufacturers such information as the status of vehicle recalls. The Motor Vehicle Safety Regulations specify that this information must be obtained and thus the Department of Transport has no choice but to request that it be provided for each individual vehicle.

In addition to the teleconferences, meetings were held with the interested provinces/territories through the Canadian Council of Motor Transport Administrators. There were no significant concerns or requested changes brought forward during these meetings. The public insurers, including Manitoba Public Insurance (MPI), which has underway an extensive provincially funded immobilization program, also did not note any concern with the amendment as it continues to ensure that all new Canadian vehicles are equipped with an electronic immobilization system. MPI noted that even though over 90 000 vehicles have been retrofitted, it is not aware of any adverse impact on road safety.

Department officials also met with the Canadian vehicle manufacturers and their respective Canadian associations. They noted that they do not have the capacity or the interest to develop aftermarket electronic immobilization systems to be installed in the case where the vehicle sold at the retail level in the United States has no factory installed electronic immobilizer. As a result, they have asked the Government of Canada to remove the proposed requirement that manufacturers identify the vehicle models that cannot be fitted with an aftermarket immobilizer. Most manufacturers have noted that they will be informing Canadian consumers that there will not be any warranty on the electrical system of their vehicle if it is modified to add an aftermarket immobilization system.

Some Canadian manufacturers also indicated that the amendment represents unequal treatment, as they are required to spend additional resources above the cost of equivalent U.S. specification models to meet the Canadian immobilization requirements. They also noted that several models that are in the middle of their design life have been brought into compliance with the Canadian standard by the installation of shields to meet the 5-minute attack test. These shields have been installed to make the task of tampering with the control units difficult and time consuming. In most cases these shields are installed only on the Canadian models due to the added cost. These shields cannot easily be retrofitted on many U.S. specification models. As the Government of Canada intends to maintain a comparable level of theft protection for all Canadians and continues to move towards greater harmonization with the United States, it proposes to work with the United States government officials with the intention of developing a compatible future requirement or process for vehicle theft immobilization protection.

Some manufacturers suggested that the proposed regulatory amendment have an expiration date to allow short-term processing of the inadmissible vehicles already in Canada, or to encourage a timely review of CMVSS 114's immobilization requirements. The Department has considered this suggestion but did not incorporate an expiration date on the basis that it is not possible to predict that the importation problems faced by Canadians will cease to exist following that date. On the other hand, CMVSS 114 has been in force for only a few months and it would be premature to propose an amendment to it. The Department proposes rather to closely observe market trends including the fitment rate of CMVSS 114 compliant immobilization systems in U.S. vehicles, and work with NHTSA to achieve regulatory convergence. This would help guide departmental plans with regard to the need for maintaining the proposed amendment to the importation regulation or to amending CMVSS 114.

Following the public consultation sessions, the Canadian Vehicle Manufacturers' Association, which represents Canada's leading motor vehicle manufacturers, (see footnote 10) wrote the Department of Transport specifically requesting that their comments be posted as part of the public record. In their letter they expressed their concern for the unharmonized regulations that exist between Canada and the United States noting that the consultations should be assessing actions to address all of the unique Canadian safety regulations. The Department of Transport's current consultation did not cover the issue of other non-harmonized regulations. This amendment to section 12 is needed to introduce requirements for the aftermarket installation of immobilization devices. The Canadian safety standard for immobilization systems references only the original equipment manufacturers section of the ULC-338 standard and thus it does not allow for the aftermarket installation of immobilization devices.

In their letter, the CVMA also noted concern with the reference that auto companies changed the eligibility information with little notice. They noted that all of their member companies had provided their eligibility information in a timely fashion and that the issue with updating the eligibility list for their companies was due to the Department of Transport. The Department acknowledges that the CVMA members companies did provide their information in a timely manner and that any reference to late information should not have included their association or any of their individual members.

General communication process

The Department of Transport has instituted a systematic and extensive information process that is intended to keep the automotive industry, public safety organizations, and the general public informed of projected and recent changes to the regulatory requirements governing motor vehicle safety in Canada. This process includes information sessions with the provinces and territories, as well as with the authorities of other countries, and it provides a mechanism for interested parties to comment on the Department's planned initiatives.

In particular, meetings are held three times a year with the CVMA. Departmental representatives meet three times a year with the Association of International Automobile Manufacturers of Canada (AIAMC), which represents international motor vehicle manufacturers and importers. (see footnote 11) There are semi-annual meetings with the Motorcycle and Moped Industry Council and the Rubber Association of Canada. As well, semi-annual meetings are held with the U.S. Department of Transportation.

Mainly through the Department's membership in the Canadian Council of Motor Transport Administrators, discussions that deal with a broad range of issues take place on a regular basis with the provinces and territories. There are also semi-annual meetings with national public safety organizations in order to discuss future regulatory changes and emerging safety problems.

Compliance and enforcement

Motor vehicle manufacturers and importers are responsible for ensuring that their products comply with the requirements of the Motor Vehicle Safety Regulations. The Department of Transport monitors the self-certification programs of manufacturers and importers by reviewing their test documentation, inspecting vehicles, and testing vehicles obtained in the open market. When a defect is found, the manufacturer or importer must issue a notice of defect to owners and to the Minister of Transport, Infrastructure and Communities. If a vehicle does not comply with a safety standard, the manufacturer or importer may be subject to prosecution and, if found guilty, may be fined as prescribed in the Motor Vehicle Safety Act.

Transport Canada has contracted with Livingston International to establish and operate the national program of vehicle inspection, certification and registration, known as the Registrar of Imported Vehicles (RIV). The RIV program was set in place to ensure that vehicles imported for use in Canada meet Canadian safety standards. The RIV maintains a network across Canada of over 500 facilities authorized to perform federal inspections. The safety compliance status of inspected vehicles is shared with all provincial and territorial licensing jurisdictions in Canada and a vehicle cannot be licensed before successfully passing the RIV inspection program.

Contact

Daniel B. T. Davis
Chief, Regulations and Standards
Road Safety and Motor Vehicle Regulation Directorate
Transport Canada
330 Sparks Street, Tower C, 8th Floor
Ottawa, Ontario
K1A 0N5
Telephone: 613-998-1956
Fax: 613-990-2913
Email: Davisda@tc.gc.ca

Footnote a

S.C. 1993, c. 16

Footnote b

S.C. 1993, c. 16

Footnote 1

C.R.C., c. 1038

Footnote 2

SOR/2005-45

Footnote 3

Dated May 1998, published by the Underwriters' Laboratories of Canada (ULC)

Footnote 4

Dated October 14, 2002

Footnote 5

Dated March 6, 2006

Footnote 6

The Motor Vehicle Theft Problem: An Exploration And Development Of Future Options, Michael Parkes, October 15, 1999; Fatalities and Injuries as a Result of Stolen Motor Vehicles (1999-2001), prepared for Project 6116 by Matthew J. Miceli, December 2002

Footnote 7

The Auto Theft Industry – The Cost to Canadians, prepared for the Insurance Bureau of Canada by Standard & Poor's DRI, Toronto, Ontario, April 2000

Footnote 8

Title 49, Part 571, of the Code of Federal Regulations, Docket No. NHTSA-2005-22093 published on April 7, 2006

Footnote 9

Registrar of Imported Vehicles, November 19, 2007

Footnote 10

The CVMA represents Chrysler Canada Inc.; Ford Motor Company of Canada, Limited; General Motors of Canada Limited; and International Truck and Engine Corporation Canada.

Footnote 11

The AIAMC represents the following automotive manufacturers and importers as voting members: BMW Canada Inc.; Honda Canada Inc.; Hyundai Auto Can-ada; Kia Canada Inc.; Mazda Canada Inc.; Mercedes-Benz Canada Inc.; Mitsubi-shi Motor Sales of Canada, Inc.; Nissan Canada Inc.; Porsche Cars Canada Ltd.; Subaru Canada Inc.; Suzuki Canada, Inc.; Toyota Canada Inc.; and Volkswagen Canada Inc.

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