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OTTAWA, June 6, 2007

4214-14
AD/1363

STATEMENT OF REASONS

Concerning the making of a final determination of dumping of

CERTAIN ADULT INCONTINENCE BRIEFS ORIGINATING IN OR EXPORTED FROM FRANCE

DECISION

On May 22, 2007, pursuant to paragraph 41(1)(a) of the Special Import Measures Act, the President of the Canada Border Services Agency made a final determination of dumping with respect to all-in-one (one piece) disposable adult incontinence briefs, which provide absorbent protection against urinary and fecal incontinence and are held in place during use by means of a fastening system, originating in or exported from France.

TABLE OF CONTENTS


SUMMARY OF EVENTS

  1. The investigation was initiated in response to a complaint filed with the Canada Border Services Agency (CBSA) by SCA North America-Canada Inc. (“SCA”) of Oakville, Ontario on October 3, 2006. The complainant provided evidence to support its claim that adult briefs from France had been dumped and that the dumping had caused injury to SCA. On October 23, 2006, the CBSA informed SCA that the complaint was properly documented and notified the Government of France that a properly documented complaint had been filed.

  2. On November 22, 2006, the President of the CBSA (President) initiated an investigation into the alleged dumping of certain adult incontinence briefs from France.

  3. Upon receiving notice of the initiation of the investigation, the Canadian International Trade Tribunal (Tribunal) started its preliminary injury inquiry. On January 22, 2007, the Tribunal made a preliminary determination of injury, determining that there is evidence that discloses a reasonable indication that the dumping of certain adult incontinence briefs from France has caused injury to the Canadian industry.

  4. On February 20, 2007, pursuant to subsection 38(1) of the Special Import Measures Act (SIMA), the President made a preliminary determination of dumping with respect to certain adult incontinence briefs originating in or exported from France. For details regarding the basis of the preliminary determination, consult the Statement of Reasons issued on March 7, 2007, which is available on the CBSA website at http://www.cbsa-asfc.gc.ca/sima-lmsi/i-e/menu-eng.html.

  5. The CBSA continued its investigation and, on the basis of the results, the President is satisfied that certain adult incontinence briefs originating in or exported from France have been dumped and that the margin of dumping is not insignificant. Consequently, on May 22, 2007, the President made a final determination of dumping pursuant to paragraph 41(1)(a) of SIMA.

  6. On February 21, 2007, the Tribunal initiated an inquiry into the question of injury to the Canadian industry. The Tribunal will issue its finding by June 20, 2007.

PERIOD OF INVESTIGATION

  1. The investigation covers all subject goods released into Canada during the Period of Investigation (POI), that is, from October 1, 2005 to September 30, 2006.

INTERESTED PARTIES

Complainant

  1. The complainant, SCA, is the only known producer of like goods in Canada. Its Canadian headquarters are located at 1275 North Service Road West, Suite 612 in Oakville, Ontario. The manufacturing facility is located at 999 Farrell Street in Drummondville, Quebec.

Exporters

  1. At the time of the initiation of the investigation, the CBSA had identified two potential exporters of the subject goods from customs import documentation and from the complaint submitted by SCA.

  2. During the preliminary stage of the investigation, the CBSA confirmed that there was only one exporter of subject goods from France. A parent company to subsidiaries that produce subject and like goods in France, sell like goods in France and sell subject goods to Canada, designated itself as the exporter. The CBSA considers the vendor of the subject goods to Canada to be the exporter for purposes of the investigation.

Importers

  1. At the time of initiation of the investigation, the CBSA had identified two potential importers of the subject goods from customs import documentation and from the complaint submitted by SCA. During the investigation, the CBSA confirmed that the subject goods were sold to only one importer in Canada.

PRODUCT INFORMATION

Definition

  1. For the purpose of this investigation, the subject goods are defined as:

    “All-in-one (one piece) disposable adult incontinence briefs, which provide absorbent protection against urinary and fecal incontinence and are held in place during use by means of a fastening system, originating in or exported from France.”

Additional Product Information

  1. The adult briefs covered by this investigation are disposable, i.e. are normally thrown away after use, as opposed to cloth diapers that are normally re-used after cleaning and washing. The imported adult briefs are directly substitutable for domestically produced like goods. They come in a range of different absorbency levels and sizes to fit a range of different body shapes from Small (waist size of 22”-36”) to Extra Large (waist size of 60”-64”). They incorporate a fastening system such as a glue type tape that connects the front portion of the brief to the back and helps to keep the brief in place. Although the glue type tape is a common form of fastening systems, other forms are also used including the hook and loop type of fastening system (such as “Velcro”).

  2. The product definition excludes incontinence products described as “step-in” underwear or protective underwear, a product into which a person must step-in and pull up to the waist. It also excludes goods described commonly as “Belted Briefs”, a two-piece system that consists of a belt that is fastened around the waist of an individual and used with a diaper folded through the crotch. Incontinence products commonly described in the industry as “pads” or any other self standing absorbent core product that must be worn with a separate garment such as a mesh or cotton undergarment are not covered under this product definition.

  3. The individual adult briefs are packed in inner packs of varying quantity, usually 10 to 12 per pack and 6 to 8 packs per outer case. Sales are made either on a case quantity or pallet quantity basis.

Production Process

  1. All producers generally manufacture adult briefs in the same manner. Raw material cellulose pulp sheet is fiberised, and then combined with super-absorbent powder to produce a mix of fibres and powder that is formed into a shaped (typically hourglass or similar) absorbent core. This process is conducted on a pocket-forming drum. The core is then combined with an impervious backsheet made of a plastic polyethylene sheet (which helps prevent leakage) in combination with a nonwoven and a liquid pervious top sheet. The liquid pervious top sheet, which allows for the absorption of fluids, is a nonwoven material produced from polypropylene fibres. The absorbent core is glued in place onto the impervious backsheet and then the pervious topsheet is glued in place over both the core and backsheet to form a continuous web that has the individual absorbent cores separated by the top sheet and backsheet layers. Before the core is applied to the backsheet, the leg elastics are stretched and then glued in place on the backsheet.

  2. Other manufacturing operations follow such as the application of an adhesive tape fastening system, the shaping of the product into a body fitting form by cutting out a leg area, the folding of the outer edges of the product into a narrower shape to facilitate cutting of the product, the cutting of the product into individual units, the trifolding or bifolding of the product to facilitate packaging.

Classification of Imports

  1. The subject adult incontinence briefs are properly classified in section X of the Customs Tariff under the following ten-digit classification numbers of the Harmonized System:

    4818.40.20.00 Napkins (diapers), napkin (diaper) liners and similar sanitary articles for incontinence, designed to be worn by persons, excluding those of a kind for babies. (Unit of measure for reporting: kilogram)

CANADIAN INDUSTRY

  1. SCA is the only known producer in Canada. The company is a wholly owned subsidiary of SCA Hygiene Products AB (Sweden), which in turn is wholly owned by SCA Hygiene Holding Company AB (Sweden). In 1996, it acquired some Canadian incontinence product manufacturing capabilities from Cascades PSH Inc. in Drummondville, Quebec. SCA installed two new state of the art adult brief manufacturing machines between 2000 and 2003, and a third one between 2003 and 2005.

  2. The company currently employs close to 200 employees. SCA has sales and marketing offices at its location in Drummondville, Quebec and in Oakville, Ontario.

  3. Prior to the initiation of this investigation, the CBSA was satisfied that the standing requirements of subsection 31(2) of SIMA had been met. There has been no change in the structure of the Canadian industry since then.

IMPORTS INTO CANADA

  1. During the final phase of the investigation, the CBSA did not modify its estimates of the volume of imports from countries other than France. The CBSA did further review information received during the investigation from the importer and the exporter.

  2. The CBSA has revised the volume of subject goods imported from France. Import values and volumes were obtained from confidential information received during the investigation and may not be divulged. The following table presents the CBSA’s revised percentage import share of certain adult incontinence briefs into Canada:

    Imports of Certain Adult Incontinence Briefs (October 1, 2005 to September 30, 2006)

    Imports into Canada % of Total Imports
    France 4.7%
    Other Countries 95.3%
    Total Imports 100%


DUMPING INVESTIGATION

  1. At the time of the initiation of the investigation, information was requested from known and possible exporters, vendors and importers of subject goods concerning imports into Canada of subject goods during the POI. The purpose of this information was to determine normal values and export prices and ultimately to determine whether the subject goods were dumped.

  2. Normal values are generally based on the domestic selling price of the goods in the country of export, or on the full cost of the goods including administrative, selling and all other costs plus a reasonable amount for profits. The export price of goods sold to an importer in Canada is generally an amount equal to the lesser of the adjusted exporter’s sale price and the adjusted importer’s purchase price for the goods. These prices are adjusted where necessary by deducting the costs, charges, expenses, duties and taxes resulting from the exportation of the goods as provided for in subparagraph 24(a)(i) to 24(a)(iii) of SIMA. When the export price is less than the normal value, the difference is the margin of dumping.

  3. The CBSA received three responses to the Request for Information (RFI) for exporters, one from the manufacturer of like and subject goods (Tyco Healthcare Manufacturing France SAS), one from the seller of like goods in France (Tyco Healthcare France SAS) and one from the vendor of the subject goods to Canada (Tyco Healthcare Group AG). The three companies are associated to Tyco Group S.a.r.l., which is located in Luxembourg. While the three responses were received separately, they were submitted with the purpose of being considered as one response on behalf of Tyco Group S.a.r.l., a parent company of the three companies. Tyco Group S.a.r.l. had designated itself as the exporter of subject goods to Canada. The CBSA received a response to the RFI for importers from one importer in Canada, Tyco Healthcare Group Canada Inc. (Tyco Canada).

  4. The three submissions received by the CBSA that were made on behalf of Tyco Group S.a.r.l., were considered to be one complete response to the RFI for exporters. While Tyco Group S.a.r.l. had designated itself as the exporter of subject goods, the CBSA did not consider this company as the exporter for SIMA purposes since it is not located in France. For the investigation, the CBSA considered Tyco Healthcare Group AG (THAG) to be the exporter of subject goods to Canada for SIMA purposes. THAG conducts business activities at a location in France from which subject goods are exported to Canada and was a principal in all transactions with the importer.

  5. Tyco Canada’s submission was also complete and included information with respect to the purchase of subject goods from THAG as well as information on the resale of the goods to customers in Canada.

  6. For the purpose of making a preliminary determination, normal values and export prices were estimated based on information contained in responses to CBSA RFIs from the Tyco entities.

  7. Following the preliminary determination made on February 20, 2007, the CBSA conducted verification visits at the premises of Tyco Healthcare France SAS, Tyco Healthcare Manufacturing France SAS and Tyco Healthcare Group Canada Inc. Information from THAG was verified at the premises of Tyco Healthcare France SAS.

RESULTS OF THE DUMPING INVESTIGATION

  1. All subject goods were exported by THAG to an associated importer in Canada, Tyco Canada.

a) Normal Values

  1. THAG did not have domestic market sales to purchasers in France with whom it was not associated. THAG sells to Tyco Healthcare France SAS (Tyco France) who resells adult incontinence briefs at arm’s length in France. The transactions between THAG and Tyco France could not be used to determine normal values due to the relationship between the two companies. Accordingly, the CBSA applied subparagraph 16(1)(c)(ii) of SIMA, and deemed Tyco France to be the exporter of the goods for purposes of determining normal values of the goods sold to the importer in Canada.

  2. The CBSA conducted a profitability analysis of domestic sales of like goods by Tyco France to customers that were at the nearest subsequent trade level to the importer in Canada. Tyco France did not have a sufficient number of sales of like goods that were made at a profit to allow the determination of normal values pursuant to section 15 of SIMA. Normal values for all subject goods imported into Canada during the POI were determined pursuant to paragraph 19(b) of SIMA based on the aggregate of the full cost of production of the goods, plus a reasonable amount for administrative, selling and all other costs, plus a reasonable amount for profits. The reasonable amount for administrative, selling and all other costs represents an amount equal to all administrative selling and other costs that are reasonably attributable to the domestic sales of like goods made by Tyco France in accordance with subparagraph 11(1)(c)(i) of the Special Import Measures Regulations (SIMR). The amount for profits was based on the profit earned by Tyco France on sales of like goods sold in the domestic market at subsequent trade levels in accordance with subparagraph 11(1)(b)(i) of the SIMR.

  3. In the determination of normal values, several adjustments were also made in accordance with the SIMR. A qualitative adjustment was made pursuant to paragraph 5(d) to take into account differences in the conditions of sale between the subject goods sold to Canada and like goods sold domestically. A delivery cost adjustment was made pursuant to section 7 of the SIMR for freight expenses incurred on sales of like goods that are sold on a delivered basis in France. An adjustment was also made pursuant to section 9 of the SIMR for expenses incurred in selling like goods to purchasers in France who were at the nearest and subsequent trade level to the importer in Canada.

b) Export Prices

  1. As previously stated, the export price of goods sold to an importer in Canada is generally an amount equal to the lesser of the adjusted exporter’s sale price and the adjusted importer’s purchase price for the goods. These prices are adjusted where necessary by deducting the costs, charges, expenses, duties and taxes resulting from the exportation of the goods as provided for in subparagraphs 24(a)(i) to 24(a)(iii) of SIMA. When sales are made between an associated exporter and importer, such as THAG and Tyco Canada, the President must consider the reliability of the section 24 export price from the exporter to the related importer. This price is tested to determine if the importer sold the product in Canada at a price that allowed for the recovery of all costs incurred by the importer, including the cost of the goods, the costs incurred in preparing, shipping and exporting the goods to Canada, all costs incurred in reselling the goods (including duties and taxes), and an amount representative of the amount for profits earned by vendors in Canada.

  2. Export prices calculated pursuant to section 24 of SIMA were not found to be reliable for the purposes of SIMA. Export prices were therefore determined in accordance with paragraph 25(1)(c) of SIMA for the final determination based on Tyco Canada’s resale prices in Canada, less the costs incurred by Tyco Canada on the importation of the subject goods, the costs incurred in Canada for the resale to customers in Canada, and an amount representing the average industry profit in Canada, determined pursuant to section 22 of the SIMR.

c) Margin of Dumping

  1. The total normal value was compared with the total export price for all subject goods imported into Canada during the POI. It was determined that the subject goods were dumped. The weighted average margin of dumping was 65.3%, expressed as a percentage of export price. When the normal value of subject goods sold to Canada exceeded the export price, the margins of dumping for those transactions ranged from 30.4% to 92.0%.

    Summary of Final Results of Dumping Investigation

    Country Margin of Dumping as Percentage of Export Price Dumped Goods as Percentage of Country Imports Dumped Goods as Percentage of Total Imports
    France 65.3% 100% 4.7%


  2. In making a final determination of dumping in relation to goods imported from a country in the investigation, the President must be satisfied that the subject goods have been dumped and that the margin of dumping is not insignificant. Subsection 2(1) of SIMA defines ‘insignificant’ as being less than 2% of the export price of the goods. The table above indicates that the margin of dumping is not insignificant.

  3. For purposes of a preliminary determination of dumping, the President has responsibility for determining whether the actual and potential volume of dumped goods is negligible. After a preliminary determination of dumping, the Tribunal assumes this responsibility. In accordance with subsection 42(4.1) of SIMA, the Tribunal is required to terminate its injury inquiry in respect of any goods if the Tribunal determines that the volume of dumped goods from a country is negligible.

REPRESENTATIONS CONCERNING THE DUMPING INVESTIGATION

  1. Following the preliminary determination of dumping, the CBSA received written representations from legal counsel representing all the Tyco companies (Tyco) involved in this investigation. The representations and case arguments related to the selection of domestic sales for the determination of normal values, to adjustments to be considered in the determination of normal values, to the alternate method of determining normal values based on the costs of goods and to the amount for profits for vendors in Canada to be used in the calculation of export prices under section 25 of SIMA.

  2. Representations from legal counsel for the complainant (SCA) were also received by the CBSA. Arguments were submitted regarding a request by Tyco to have certain expenses excluded in the calculation of normal values and the amount for profits to be used in the calculation of export prices pursuant to section 25.

  3. Some of the representations made to the CBSA contained information that was designated as confidential by the party who provided the information. In order to protect the confidentiality of this information, the following summaries of the representations, and the CBSA’s responses, are limited to information that is not confidential.

Selection of Domestic Sales

  1. Tyco noted that the CBSA should use the domestic sales that were selected by Tyco for purposes of establishing normal values. Tyco had submitted selected sales to domestic customers in France that were at the next and nearest trade level to the importer in Canada and that were made in certain quantities. For purposes of the preliminary determination, the CBSA had selected sales without distinction between trade levels.

CBSA’s Response

  1. Following verification and after obtaining further information, the CBSA accepted Tyco’s selection of domestic sales for purposes of the application of section 15 of SIMA and taking into account subsection 16(1) of SIMA for the final determination. The CBSA examined the sales to domestic customers in France that were at the next and nearest trade level to the importer in Canada in order to determine if there were a sufficient number of sales that were made at a profit to allow the determination of normal values in accordance with section 15 of SIMA.

Adjustments for Normal Values

  1. Tyco requested that the CBSA consider three adjustments under the SIMR in the determination of normal values. Tyco requested the following adjustments: a qualitative adjustment pursuant to paragraph 5(d), a delivery cost adjustment pursuant to section 7 for freight expenses and a trade level adjustment pursuant to section 9.

CBSA’s Response

  1. Following verification and after obtaining further information, the CBSA found that the three requested adjustments were warranted and were made in the determination of normal values pursuant to section 19 of SIMA for the final determination to account for differences in the conditions of sales, delivery costs and trade levels.

Alternate Method for Calculating Normal Values

  1. Tyco requested, in the event that normal values were determined pursuant to section 19 of SIMA, that the CBSA exclude general and administrative expenses incurred by Tyco France on domestic sales of like goods in the total costs of goods. These expenses were in addition to the expenses that Tyco requested that the CBSA consider when making adjustments pursuant to sections 5, 7 and 9 of the SIMR in the determination of normal values.

  2. The complainant submitted that Tyco France’s general and administrative expenses must be included because these costs are reasonably attributable to Tyco France’s sales of like goods. It was also submitted that the objective of the provisions of the SIMR is to ensure that the administrative, selling and all other costs reflect the costs of arm’s length sales of like goods.

  3. Tyco also made a representation on the amount for profits to be included in the determination of normal values in accordance with subparagraph 11(1)(b) of the SIMR. Tyco pointed to subparagraph 11(1)(b)(i) indicating that the primary basis upon which profits are to be determined for this purpose is profits earned on sales of like goods in the country of export. Tyco suggested that a certain amount for profits, that it claimed was being earned by Tyco France on its sales to unrelated customers, and that it considered to be reasonable, be used in the determination of normal values.

CBSA’s Response

  1. Regarding the request to exclude Tyco France’s general and administrative expenses, subparagraph 11(1)(c)(i) of the SIMR stipulates that such expenses that are attributable to the domestic sales of like goods by the exporter are to be included in the determination of normal values under section 19 of SIMA. In this case, Tyco France has been deemed to be the exporter for purposes of determining normal values in accordance with paragraph 16(1)(c) of SIMA. Tyco France’s general and administrative expenses must therefore be considered to be attributable to the like goods. There are no provisions in the SIMR to remove these general and administrative expenses in the determination of normal values under section 19 of SIMA.

  2. With respect to the amount for profits, other than claiming that it was a reasonable amount pursuant to subparagraph 11(1)(b)(i) of the SIMR, Tyco did not provide any evidence to support the amount that it was proposing that the CBSA use as a reasonable amount for profits. The amount for profits that was calculated by the CBSA in accordance with subparagraph 11(1)(b)(i) the SIMR was based on actual domestic sales of like goods made at arm’s length by Tyco France that satisfied the greatest number of conditions set out in section 15 and subsection 16(1) of SIMA.

Amount for Profits for Vendors in Canada for Section 25 Export Price

  1. Tyco submitted that the amount for profits estimated for the preliminary determination of dumping was calculated erroneously by the CBSA. Tyco maintained that the paragraphs of section 22 of the SIMR are to be applied consecutively and that subsequent paragraphs should not be applied when the previous paragraph is applicable. Tyco submitted that for the preliminary determination, the President had at his disposal all the necessary information to estimate an amount for profits based on sales of like goods in Canada and that the CBSA exceeded its jurisdiction and erred in going beyond Tyco Canada’s and SCA’s sales and profits.

  2. Tyco requested that the CBSA not use the same methodology for purposes of the final determination. It submitted that the amount for profits that should be used for the final determination be based on profits earned by vendors in Canada on goods of the same general category following the hierarchy set out in section 22 of the SIMR.

  3. SCA agreed with Tyco concerning the application of section 22 of the SIMR. It also maintained that the paragraphs of this section must be applied in sequence. SCA then stated that paragraph 22(a) deals with “sales of like goods” and that Tyco Canada doesn’t make like good sales in Canada and that it makes subject good sales. CBSA therefore cannot use Tyco Canada data under paragraph 22(a) and must then consider the application of paragraphs 22(b) and (c) to determine an amount for profits. SCA also claimed that the CBSA could use data of additional vendors, whether including SCA data or not, and disregard Tyco Canada data. In addition, SCA provided updated financial results for its most current fiscal period for consideration by the CBSA.

CBSA’s Response

  1. The representations from both parties were fully considered by the CBSA in determining an amount for profits for vendors in Canada pursuant to section 22 of the SIMR. In order to protect the confidentiality of the data used in making this determination, the CBSA cannot provide more details, other than to state that an amount for profits representing the average industry profit in Canada was determined pursuant to section 22 of the SIMR.

DECISION

  1. On the basis of the results of the investigation, the President is satisfied that certain adult incontinence briefs originating in or exported from France have been dumped and that the margin of dumping is not insignificant. Consequently, on May 22, 2007, the President made a final determination of dumping pursuant to paragraph 41(1)(a) of SIMA.

FUTURE ACTION

  1. The provisional period began on February 20, 2007, and will end on the date the Tribunal issues its finding. The Tribunal is expected to issue its decision by June 20, 2007. Subject goods imported during the provisional period will continue to be assessed provisional duty as determined at the time of the preliminary determination. For further details on the application of provisional duty, refer to the Statement of Reasons issued for the preliminary determination, which is available on the CBSA Web site at http://www.cbsa-asfc.gc.ca/sima-lmsi/i-e/menu-eng.html.

  2. If the Tribunal finds that the dumped goods have not caused injury and do not threaten to cause injury, all proceedings relating to this investigation will be terminated. In this situation, all provisional duty paid or security posted by importers will be returned. If the Tribunal makes an affirmative decision, anti-dumping duty will be imposed on imports of the subject goods.

  3. If the Tribunal finds that the dumped goods have caused injury, the anti dumping duty payable on subject goods released into Canada during the provisional period will be finalized, pursuant to section 55 of SIMA. Imports released into Canada after the date of the Tribunal’s finding will be subject to anti-dumping duty equal to the margin of dumping. In that event, the importer in Canada shall pay all such duty. If the importers of such goods do not indicate the required SIMA code or do not correctly describe the goods in the customs documents, an administrative monetary penalty (AMP) could be imposed. The provisions of the Customs Act apply with respect to the payment, collection or refund of any duty collected under SIMA. As a result, failure to pay duty within the prescribed time will result in the application of interest.

  4. Specific normal values for the subject goods have been provided to the co-operating exporter. Should the Tribunal make an injury finding, these normal values will come into effect the day after the date of the injury finding. Anti-dumping duty will apply based on the amount by which the normal value exceeds the export price of the subject goods.

  5. Subject goods for which there are no specific normal values and which are imported into Canada following an injury finding, will have normal values established by advancing the export price by the highest margin of dumping found for the co-operating exporter, in this case, 92%, based on a ministerial specification pursuant to section 29 of SIMA.

RETROACTIVE DUTY ON MASSIVE IMPORTATIONS

  1. Under certain circumstances, anti-dumping duty can be imposed retroactively on subject goods imported into Canada. When the Tribunal conducts its inquiry on material injury to the Canadian industry, it may consider if dumped goods that were imported close to or after the initiation of the investigation constitute massive importations over a relatively short period of time and have caused injury to the Canadian industry. Should the Tribunal issue a finding that there were recent massive importations of dumped goods that caused injury, imports of subject goods released by the CBSA in the 90 days preceding the day of the preliminary determination could be subject to anti-dumping duty.

PUBLICATION

  1. A notice of this final determination of dumping will be published in the Canada Gazette pursuant to paragraph 41(3)(a) of SIMA.

INFORMATION

  1. This Statement of Reasons has been provided to persons directly interested in these proceedings. It is also posted on the CBSA website at the address below. For further information, please contact Michel Leclair, Edith Trottier or Véronique Pouliot as follows:

    Mail
    SIMA Registry
    Anti-dumping and Countervailing Program
    Trade Programs Directorate
    Canada Border Services Agency
    100 Metcalfe Street, 11th Floor
    Ottawa, Ontario K1A 0L8
    CANADA

    Telephone
    Michel Leclair    613-954-7232
    Edith Trottier    613-954-7182
    Véronique Pouliot    613-954-1641

    Fax
    SIMA Registry    613-948 4844

    E-mail
    simaregistry-depotlmsi@cbsa-asfc.gc.ca

    Website
    www.cbsa-asfc.gc.ca/sima

Darwin Satherstrom
Acting Director General
Trade Programs Directorate

Date Modified: 2007-06-06

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