Canada Country Report

Case Report:	ADVERTISING - PROSECUTIONS
Topic:	False or Misleading Advertising - Prosecution
Who:	3181731 Canada Inc., doing business as Direct Health Organization, Columbus Health Centre, New Opportunities Publications & Canadian Shipment Centre
When:	August 2000
What happened:	Company urged consumers, through mail samples, to purchase various weight-loss products & get involved in a "get-rich-quick" scheme. Subsequent investigation determined that these representations had not been based on adequate or proper tests. Company was charged for misleading advertising under s.52 of the Competition Act and pleaded guilty.
Decision:	Company was fined $500,000.
Comments:	Fines in these matters are not insignificant
Case Report:	ADVERTISING - PROSECUTIONS
Topic:	False or Misleading Advertising - Prosecution
Who:	Dial America Teleservice Corporation and its Director
When:	December 2000
What happened:	Charge of misleading advertising against Company and its Director in connection with the sale to US consumers of credit card protection. Charge alleges that consumers were mistakenly led to believe that the company was calling on behalf of, or was affiliated with, their credit card issuer. Also alleged that the product did not actually offer any additional credit card protection.
Decision:	No resolution at this time.
Comments:	It was interesting that the victims here were U.S. consumers, not Canadians.
Case Report:	ALTERNATIVE CASE RESOLUTIONS [An enforcement option which may be considered by the Competition Bureau as an alternative to litigation]
Topic:	False or Misleading Advertising
Who:	A Canadian beverage Company
When:	2000/2001
What happened:	Beverage was being promoted as "the top-selling product in its class" based on the past year's statistics, which were no longer valid, contrary to the false or misleading representation provisions of the Competition Act.
Decision:	On receipt of communication from the Competition Bureau, target company voluntarily submitted an acceptable plan of action whereby products already on shelf would be re-labelled, and new product packaging was designed.
Case Report:	ALTERNATIVE CASE RESOLUTIONS [An enforcement option which may be considered by the Competition Bureau as an alternative to litigation]
Topic:	False or Misleading Advertising
Who:	A Canadian importer/distributor of agricultural irrigation systems
When:	2000/2001
What happened:	Product was promoted as having "the best" warranty coverage in the industry and was "superior in performance" to its competitors. These representations were found to be inaccurate.
Decision:	On receipt of communication from the Bureau, target company voluntarily discontinued the advertisements, agreed to refrain from similar activity in the future, and arranged for the discontinuance of all advertising materials where claims could not be verified. The US Manufacturer also advised all North American distributors to discontinue use of the representations.
Case Report:	ADVERTISING: SELF-REGULATORY CASES
Topic:	Use of Sex in Advertising - Advertising Standards Canada
Who:	The Shoe Company Limited
When:	mid 2000
What happened:	Transit ads for women's boots showed only the lower half of a woman covering herself with a fig leaf and wearing only red snakeskin boots. 8 Complaints were received that the ads were sexually exploitive.
Decision:	Advertising Standards Canada upheld the complaints, stating that the ads focused on the woman's sexuality more than on fashion trends in boots. Ad was removed.
Case Report:	ADVERTISING: SELF-REGULATORY CASES
Topic:	Use of Sex in Advertising - Advertising Standards Canada (Quebec)
Who:	Quebec advertiser
When:	2000/2001
What happened:	7 Complaints received about the unmistakable sexual activity implied by the impersonation of well-known public figures in a consumer product commercial, combined with the use of double-entendre further suggesting sexual aspects of the couple's relationship.
Decision:	Clause 14 of the Canadian Code of Advertising Standards was contravened, so ad was removed.
Comments:	As noted by Advertising Standards Canada, "Neither an intention to be humorous nor humorous treatments [of attitudes that offend the prevailing standards of public decency] render commercials acceptable"
Case Report:	ADVERTISING: SELF-REGULATORY CASES
Topic:	Use of Sex in Advertising - Advertising Standards Canada (Quebec)
Who:	La Brasserie Stroh (Quebec) Ltèe
When:	2000
What happened:	42 Complaints were received that women's sexuality was being used to advertise a product with no relationship to sexuality - specifically: Newspaper advertisements showed adult females wearing sheer negligees and surrounded by baby chicks in an Easter-themed ad for a beer product
Decision:	As reported in ASC's 2000 Ad Complaints Report: "Council found that the advertisement was demeaning and disparaging to women, contrary to Clause 14(c) of the Advertising Standards Code."
Case Report:	ADVERTISING: SELF-REGULATORY CASES
Topic:	Safety - Depiction of Unsafe Practices - Advertising Standards Canada
Who:	In-store Bakery
When:	2000/2001
What happened:	One (1) complaint by a member of the public to an ad showing individuals looking up from inside a grain silo as grain began to pour into the silo from the top.
Decision:	Ad was found to contravene S.10 of the Canadian Code of Advertising Standards. Advertiser given option of removing ad altogether, or amending it to include a super to warn of the dangers of entering a silo AND having it broadcast after 9:00 pm to minimize chance of children being part of the audience.
Case Report:	ADVERTISING: SELF-REGULATORY CASES
Topic:	Unnecessary Violence - Advertising Standards Canada (Quebec)
Who:	Informatique Mercier in Quebec
When:	2000
What happened:	1 Complaint was received that an advertisement exhibited unwarranted and gratuitous violence - specifically: a television advertisement showed an enraged office worker smashing his computer.
Decision:	As reported in ASC's 2000 Ad Complaints Report: "Council concluded the advertisement appeared to exploit, condone and incite violence and exhibited indifference to reprehensible behaviour, contrary to Clause 14(b) of the Canadian Code of Advertising Standards."
Case Report:	ACTIONS BY COMPETITION BUREAU UNDER CIVIL PROVISIONS OF THE COMPETITION ACT
Topic:	Deceptive Marketing - Civil Provisions of Competition Act
Who:	Gestion Professionnelle Inc. ("GPI")
When:	September 2000
What happened:	GPI marketed an electronic anti-corrosion device called "ML-10" using several unsubstantiated claims and representations.
Decision:	GPI agreed to stop selling the device and to refrain from marketing it or any similar device until "appropriate" tests took place.
Case Report:	SELF-REGULATORY TRADE DISPUTE PROCEDURE
Topic:	Advertising - Self-Regulatory - Revised Trade Dispute Procedure
Who:	Advertising Standards Canada
When:	February 2000
What happened:	Implementation by Advertising Standards Canada of Revised Trade Dispute Procedure for disputes between advertisers. The Procedure now provides, among other things, for mandatory resolution meetings prior to scheduling a hearing date.
Decision:	Only 17 of 50 trade dispute issues brought before Advertising Standards Canada between 1995 and 2000 were actually heard by a Trade Dispute Panel - all others were resolved by agreement between the disputing parties. Advertising Standards Canada has always encouraged resolution without the need of a hearing.
Case Report:	CLASS ACTION LAW SUIT
Topic:	Class Action Law Suit
Who:	American Express Canada ("Amex Canada")
When:	Late 2000/early 2001
What happened:	To help promote membership applications, Amex Canada offered two-for-one "companion certificates" with Canadian Airlines International Limited ("Canadian") to consumers purchasing a ticket on Canadian with their Platinum Amex Canada Credit Card. Before consumers could convert their certificates to tickets, Canadian terminated its contract with Amex Canada, resulting in Amex Canada being unable to fulfill its promotional promise.
Decision:	Amex Canada settled the class action by negotiating an agreement with Air Canada (of which Canadian is now a wholly-owned subsidiary) whereby the companion certificates were honoured by Air Canada until the end of May 2001.
Case Report:	ADVERTISING TO CHILDREN
Topic:	Advertising to Children
Who:	Pizza Hut
When:	June 2001
What happened:	Pizza Hut attempted to promote its product in Quebec's schools by offering a reading kit and coupons to children who achieved reading objectives set by their teachers.
Decision:	Pizza Hut was found to be in contravention of Quebec's Education, with respect to promotional activities in schools. The promotion was, therefore, terminated.
Comments:	This follows two similar charges just last year against Kellogg Canada Inc. and the Campbell Soup Company Ltd. Both of the latter companies were forced to terminate their promotions mid-stream due to their contravention of the relevant provisions. Quebec marketing laws are in a number of ways stricter and broader than other Provinces in Canada.
Case Report:	PROMOTIONAL DISASTERS
Topic:	Promotion Disasters
Who:	Ultramar Limited
When:	June 2001
What happened:	A printer's error resulted in 100,000 potential winners of $1,500 rather than the originally planned 3 - translating to a potential liability of $150,000,000 (CAN)
Decision:	When the error was discovered, Ultramar Ltd. issued a public notice advising that the coupons bearing the incorrect printing code would not be honoured, although they would be submitted for a draw at the end of the promotion period, in which the original three (3) prizes would be awarded. Ultramar included certain errors provisions in its Rules on which it purported to rely in the action taken.
Comments:	It is not clear yet whether the errors provisions - and the resulting action taken by Ultramar - will be tested in court.
Case Report:	PROMOTIONAL DISASTERS
Topic:	On-line Gaming
Who:	Various - please see below
When:	2001
What happened:	(a) Prince Edward Island ("PEI")- PEI government wishes to license a charity for hosting an Internet gaming site. It has submitted a reference to PEI Court of Appeal to determine the legality of the proposed license. (b) The Federal Department of Justice ("Justice") successfully prosecuted a Canadian on-line gambling firm that had located its host computers outside Canada.
Decision:	PEI - A ruling from PEI's Court of Appeal is being awaited. (b) Justice - Firm was fined $100,000 plus $15,000 victim's surcharge, and one-half of their profit - totalling US$3.9-million - under the federal Proceeds of Crime legislation. Total hit: Over $6,000,000 (CAN)
Case Report:	PROPOSED GUIDELINES
Topic:	Internet Advertising - Proposed Guidelines
Who:	Competition Bureau
When:	May 2001
What happened:	Draft recommendations made by the Competition Bureau with respect to on-line advertising to help protect consumers and to minimize the risk of challenge for misleading advertising or deceptive telemarketing.Among the key issues addressed in the detailed draft guidelines is how to achieve "clear and conspicuous" disclosure of material information for consumers. If a designer plays an active role in initiating, conceiving, drafting or shaping a representation that raises issues under the Act, it could be held liable for such issues.
Case Report:	PROPOSED GUIDELINES
Topic:	Environmental Labelling & Advertising - Proposed Guidelines
Who:	Competition Bureau of Canada (which administers the Consumer Packaging & Labelling Act and the Competition Act)
When:	Summer 2001
What happened:	Competition Bureau proposes replacement of the existing Principles and Guidelines for Environmental Labelling and Advertising with the CAN/CSA-ISO 14021-00 Standard, as the latter document provides internationally harmonized and more comprehensive guidance.
Decision:	Public consultation has been requested and may result in changes being made prior to implementation.
Comments:	Once implemented, the Guidelines will affect all labelling and advertising with respect to environmental claims.
Case Report:	LABELLING & ADVERTISING CHANGES
Topic:	Labelling and Advertising of Pet Foods - New Guidelines
Who:	Competition Bureau and Pet Food Industry
When:	September 21, 2001 - Hot off the Press!
What happened:	Following consultations with both government and non-government organizations, Competition Bureau has now finalized and published up-to-date Guidelines for the labelling and advertising of pet foods.
Decision:	Will be used by the Competition Bureau as a reference point for the application of the misleading advertising and packaging and labelling laws the Bureau administers with respect to pet foods sold in Canada. Guide also sets out industry standards.
Comments:	The guidelines were apparently originally initiated by a US executive who came to head a Canadian company and wanted to clarify standards as to claims, ingredients and other issues, and level the playing field.
Case Report:	LABELLING & ADVERTISING CHANGES
Topic:	Labelling and Advertising of Genetically Modified Foods - New Guidelines Coming
Who:	Canadian General Standards Board together with members of the Council of Grocery Distributors, the Food & Consumer Products Manufacturers of Canada, and the Canadian Biotechnology Advisory Committee
When:	Anticipated for publication in early 2002
What happened:	National labelling standards for genetically modified foods are being developed. Until standards are in place, members of the Council of Grocery Distributors and the Food & Consumer Products Manufacturers of Canada have agreed to not use "GM" or "GM-Free" in their advertising or package labelling.
Decision:	Current draft suggests implementation on a voluntary basis and that services be centralized to channel information on all novel foods for consumers.
Case Report:	TELEMARKETING - PROSECUTIONS
Topic:	Telemarketing - Prosecution
Who:	The Director of S. S. Viking Industries, S. C. Canadian Clearing Centre Inc., and Exclusive Premium Distribution Centre S. C. Corporation
When:	December 2000
What happened:	Company promised consumers they would receive valuable awards if they bought promotional products the company was selling. Subsequent investigation showed that the products were being sold at inflated prices.
Decision:	Director was found guilty of 3 criminal charges, and sentenced to pay $300,000;
Comments:	The Competition Bureau cites this as the highest fine imposed against an individual for this type of case.
Case Report:	TELEMARKETING - PROSECUTIONS
Topic:	Telemarketing - Prosecution
Who:	C.S.R.H. Heritage Group Inc.
When:	December 2000
What happened:	Company promised consumers valuable awards if they bought promotional products such as pens and coins at what were later shown to be inflated prices. In addition, extra conditions and restrictions that were required to collect the awards were either not mentioned or only partially disclosed.
Decision:	Company was fined $700,000
Comments:	Another significant fine.
Case Report:	TELEMARKETING - PROPOSED GUIDELINES
Topic:	Telemarketing - Proposed New Guidelines
Who:	Canadian Radio-television & Telecommunications Canada ("CRTC")
When:	Late 2001 or early 2002
What happened:	Certain telemarketing rules that govern how and when telemarketing may occur have been in effect only within certain areas of and for certain service providers in Canada. The CRTC has proposed an extension of existing Rules to ALL telecommunications service providers across Canada, in an effort to harmonize activity. This will extend, across Canada: prohibition of automatic dialling and announcing devices for solicitations; time restrictions for unsolicited facsimile calls; no sequential dialling (by live voice or fax); maintenance of a "Do Not Call" listing; and removal of names and numbers on request within specific periods of time.
Decision:	Public comment has been requested to be submitted prior to October 6th, 2001.
Case Report:	PACKAGING & LABELLING
Topic:	Consumer Packaging & Labelling Act - Non-compliance: "Net Quantity"
Who:	Gaston Charbonneau Ltèe
When:	December 2000
What happened:	Product labelling did not contain the net quantity declared on the label.
Decision:	Company was fined $3,000 and product was seized and removed from sale.
Case Report:	PACKAGING & LABELLING
Topic:	Consumer Packaging & Labelling Act - Non-compliance: "Made in Canada"
Who:	Importer/distributor of cat litter
When:	2000/2001
What happened:	Packaging was marked as being a product of Canada, though it did not meet the Bureau of Competition's Made in Canada Guidelines.
Decision:	Company agreed to immediately replace the "Product of Canada" claim with "Packaged in Canada" on all packaging.
Case Report:	NEW PACKAGING REGULATIONS
Topic:	Hazardous Products Act - Re-vamping of new Consumer Chemicals & Containers Regulations ("CCCR 2001")
Who:	Health Canada
When:	October 1, 2001
What happened:	New regulations come into effect, fully replacing existing regulations Consequential amendments will be made to Schedule I of the Hazardous Products Act, the Food & Drugs Regulations and the Cosmetics Regulations
Decision:	Up-dated Regulations provide for a criteria-based regulatory scheme in which products and substances will be regulated on the basis of the scientifically assessed hazards posed to the user, rather than the existing list-based criteria. A broader range of products will be captured, and new products will be immediately covered by the Regulations. The Government hopes the warnings will be better read and understood. KEY ELEMENTS: Only 4 hazard categories - toxic, corrosive, flammable and quick skin-bonding adhesives; with the first 3 further divided into sub-categories reflecting varying degrees of hazard Higher number of products to be packaged in child-resistant containers, with a new record-keeping requirement for tests conducted. Current symbols will all use the same octagon frame rather than differently-shaped frames for each category New requirements for borders around certain warnings and for label information as to print type, legibility, durability, location and order ALL consumer chemical products and their containers will be regulated Designed to harmonize with existing systems and classifications worldwide Changes to be implemented over a 2-year period, to permit manufacturers and distributors time to change their labelling
Comments:	This is a wholesale re-vamping of the Regulations that has been some time in coming.
Case Report:	FOOD DRUGS & COSMETICS
Topic:	Re-organization of Health Canada's Therapeutic Products Program
Who:	THE THERAPEUTIC PRODUCTS PROGRAM WILL NOW BE SPLIT INTO 3 FUNCTIONS: THERAPEUTIC PRODUCTS DIRECTORATE (TPD): responsible for the regulation of pharmaceutical drugs, medical devices and other therapeutic products available to Canadians. HEALTH PRODUCTS AND FOOD BRANCH (HPFB) INSPECTORATE: responsible for the delivery of a national compliance and enforcement program for all products under the mandate of the Branch, with the exception of food products that are the responsibility of the Canadian Food Inspection Agency. BIOLOGICS AND GENETIC THERAPIES DIRECTORATE (BGTD): responsible for the regulation of biological and radiopharmaceutical drugs.
When:	April 2001
What happened:	There are now 3 organizations managing submission and approval processes for food & drugs under the Food & Drugs Act, the Controlled Drugs and Substances Act and associated Regulations. As reported by Health Canada: "TPD will act as the national regulatory authority for drug advertisements, and may intervene when an advertisement poses a significant safety concern when an unauthorized drug product is promoted or if resolution of another issue is not achieved through the independent agencies' complaints mechanism."
Decision:	Health Products & Food Branch Inspectorate is now responsible for national compliance and enforcement programs for all products excepting those that are the responsibility of the Canadian Food Inspection Agency; while the Therapeutic Products Directorate is responsible for the regulation of pharmaceutical drugs and medical devices.
Case Report:	FOOD DRUGS & COSMETICS
Topic:	Environmental Assessment of New Products under Food & Drugs Act
Who:	Health Canada and Environment Canada
When:	Announced September 1, 2001; in effect September 14, 2001
What happened:	As part of the government's intention to proceed with development of environmental assessment regulations for substances in products regulated under the Food and Drugs Act ("F&DA"), it has been announced that all companies seeking approval to import and manufacture new products and substances regulated under the F&DA will need to notify the Minister of the Environment under the New Substances Notification ("NSN") Regulations of the new Canadian Environmental Protection Act (CEPA).
Decision:	This process will remain in place until the new environmental assessment regulations are in place.
Comments:	Though it will take at least two years to fully develop and implement the proposed Regulations, Health Canada and Environment Canada have already implemented review procedures for new food substances being imported to or manufactured in Canada.
Case Report:	FOOD DRUGS & COSMETICS
Topic:	New Product Introduction under Food & Drugs Act (F&DA)
Who:	Health Canada / Unilever Canada Limited ("Unilever")
When:	October 2001 - Hot Off the Press!
What happened:	On October 3, 2001, Health Canada issued a public notice indicating that Unilever did not obtain required approvals from Health Canada prior to introducing BecelTM Pro-activTM fat spread in Canada. Health Canada indicated that it has not been able to properly assess the effect of exposure to this product, which has added phytosterols. While acknowledged for lowering cholesterol, phytosterols may pose health risks for certain groups (eg: pregnant women, children, people predisposed to hemorrhagic strokes and people on cholesterol-lowering medication). In Europe and Australia, where this product has passed through the necessary pre-market review process, it is required to carry a label advising that certain consumers may be placed at risk by consuming the product.
Decision:	Health Canada indicated that it continues to monitor the situation closely and will take appropriate action to bring this product into compliance with Canadian regulations. They have further stated that anyone who has been using the product and has concerns is to consult their physician.
Case Report:	HEALTH PRODUCTS & CLAIMS
Topic:	Advertising & Labelling of Natural Health Products
Who:	Health Canada, Advertising Standards Canada andThe Non-Prescription Drug Manufacturers Association of Canada (NDMAC)
When:	2001
What happened:	Proposed regulatory framework for natural health products is still in the works. For example, at one time it was going to require that licenses were to be applied for and received before items could be placed on shelf for sale to consumers. That has now been softened such that any license application not actually refused within 60 days will be deemed granted, once new monographs and labelling standards are finalized and put into place.
Decision:	Stay tuned.
Case Report:	HEALTH PRODUCTS & CLAIMS
Topic:	Nutrition and Health Claims - Proposed Regulations
Who:	Health Canada
When:	Anticipated for final publication in early 2002, following a request for public comments issued in mid-June 2001.
What happened:	A final draft of proposals by Health Canada has entered the final consultative phase, with improved nutrition information for labelling of pre-packaged foods, including regulations on nutrient content and health claims.
Decision:	All stakeholders - including consumers - have already been involved in reviewing prior proposals.
Comments:	Among other things, this begins to open up the types of health claims that will be permitted in connection with foods in Canada. New health claims are under study. While certain nutrition labelling has been voluntary up to now, implementation of the new regulatory framework will become mandatory with a few exemptions. Further, the format and the content of the nutrition labelling will bring us much closer to the U.S. position and format.
Case Report:	DIRECT SELLING
Topic:	Direct Selling Legislation
Who:	(a) Province of British Columbia ("BC") - under the Consumer Protection Act (b) Province of Ontario - under the Consumer Protection Act
When:	(a) For British Columbia ("BC") - New bill introduced in late August. (b) For Ontario - Bill passed early in 2001; In effect in early August 2001.
What happened:	BC - Proposal for repeal of current requirements for direct sellers to be licensed, which will ease the administrative burden on direct sellers. Ontario - New Part II.I added respecting Direct Sales Contracts in the Consumer Protection Act, and Regulation 175/01 with respect to Direct Sales.
Decision:	(a) In BC - Anticipated to be enacted in early 2002. (b) In Ontario - Key changes include: buyers having a 10-day "cooling off period" to cancel a contract after purchase, or up to a year if goods/services purchased are not delivered within 30 days of the due date, or the contract lacks prescribed information - provided contract is negotiated/concluded in person (face-to-face) - in which case the seller has 15 days to refund money. Standard cancellation language is now required in the contracts.
Comments:	On enactment of this bill, BC would join Ontario in not requiring licensing of direct sellers. Deletion of this requirement would significantly alleviate the administrative burden on direct sellers in these provinces.
Case Report:	PRIVACY & E-COMMERCE
Topic:	Personal Information Protection & Electronic Documents Act ("PIPEDA")
Who:	(Federal Government
When:	Phase 1 in effect as of January 1, 2001 (for federal works, undertakings or businesses, and organizations that disclose personal information for consideration on an inter-provincial or international basis) Phase 2 in effect as of January 1, 2002 (for personal health information) Phase 3 in effect as of January 1, 2004 (for all other organizations)
What happened:	PIPEDA sets out rules governing the collection, use and disclosure of personal information in the private sector. Organizations must amend their privacy practices and policies by the relevant date to ensure that personal information is not, among other things, collected, disclosed or used in any manner other than as consented to by the consumer.
Decision:	Privacy notices plus internal policies and procedures will need to be developed and prominently disclosed to consumers. This legislation will affect all consumer communications (including marketing and promotional activities), require certain corporate infrastructure changes so as to ensure that personal information is managed properly, and may necessitate review of corporate and human resource documentation (including contracts, policies and procedures).
Comments:	The full impact of this federal legislation is just beginning to be felt, by marketers and advertisers alike. The Privacy Commissioner of Canada is investigating several complaints about companies. Quebec has had its own statute relating to protection of personal information for some time, and many provinces are developing their own provincial privacy legislation.
Case Report:	PRIVACY & E-COMMERCE
Topic:	Personal Information Protection & Electronic Documents Act ("PIPEDA")
Who:	Air Canada
When:	July 18, 2001
What happened:	The Privacy Commissioner of Canada received complaints regarding a brochure distributed by Air Canada which described the airline's privacy policy governing personal information collected from members of its Aeroplan mileage reward program. The Commissioner issued a press release stating that it questioned whether it was appropriate for Air Canada to use an "opt-out" form of consent for the use and disclosure of certain personal financial information of Aeroplan members. The Commissioner also expressed concern about the four month time-lag from the time a member refused to give consent before Air Canada could implement the member's request to opt-out.
Decision:	The Commissioner requested, and Air Canada agreed, to suspend its activities with respect to such personal information pending the completion of the Commissioner's investigation of the matter.
Case Report:	PRIVACY & E-COMMERCE
Topic:	Internet Sales Contract Harmonization Template (the "Template")
Who:	Canadian federal-provincial-territorial governmental working group responsible for Consumer Affairs
When:	May 25, 2001
What happened:	The Template sets out a policy framework for new consumer protection legislation in the online context. The Template requires suppliers to disclose prescribed information to consumers, provides a procedure for cancellation of Internet sales contracts, and enables consumers in certain circumstances to request credit card issuers to cancel or reverse credit card charges incurred in connection with a cancelled Internet sales contract.
Comments:	The Template anticipates a new national standard of obligations and requirements for businesses engaged in on-line sales activities. While each jurisdiction will ultimately determine the specific scope of its legislation based on the Template, the provinces and territories have not yet committed to a timetable for any legislation.