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Final Report
November 2008

Evaluation Division
Strategy and Coordination Branch

Executive Summary
1.0 Introduction
2.0 Key Findings
3.0 Conclusions, Recommendations and Management Response
Appendix A: List of key acts governing export reporting
Appendix B: Export-related monetary penalties (Administrative Monetary Penalty System)

Executive Summary

Facilitating the exportation of goods from Canada is essential to the country's prosperity. In 2007, Canada's exports added up to 35.1% of the country's $1.3 trillion gross domestic product, placing Canada as the eighth-largest economy in the world. The total value of goods exported from Canada in 2007 exceeded $463 billion; 77% of those goods were destined for the United States ($356 billion).

The Canada Border Services Agency (CBSA) manages the movement of exports as legislated by a number of federal laws, acts and regulations. Goods being exported from Canada are required by law under Part V, sections 95 to 97.2 of the Customs Act to be reported to the Government of Canada. The CBSA receives those reports and is responsible for verifying that the goods are compliant with export laws and regulations. If non-compliant, the goods may be detained and/or seized or subject to ascertained forfeiture, or exporters or service providers are issued a monetary penalty.

Functional guidance for the CBSA's export-related activities is provided by the Admissibility and Enforcement branches. The mandate of the Admissibility Branch's Export Process (EP) Unit is to provide integrated export policies and program activities that support national security and public safety priorities, and facilitate the free flow of exported goods that meet all legislated requirements. The Strategic Export Control (SEC) Section in the Enforcement Branch develops and maintains export policies that meet the Government of Canada's international agreements related to the non-proliferation of nuclear and other weapons and administers, enforces and monitors the legislation related to the export of strategic or controlled goods to countries that pose a threat to Canada and its allies.

This report presents the findings of the program evaluation conducted on the CBSA's export-related activities. This evaluation was identified as a priority for over the 2007-2008/2008-2009 fiscal years in the CBSA Risk-Based Multi-year Evaluation Plan 2008-2011, which was approved by the Executive Evaluation Committee in November 2007. The evaluation assessed the continued relevance of the CBSA's export-related activities and their progress in achieving expected results. In addition, the evaluation explored the effectiveness and efficiency of the export programs' design, delivery and management.

Research Methodology

The CBSA's Evaluation Division in the Strategy and Coordination Branch planned and conducted this evaluation. The evaluation research was conducted between January and July 2008, and the following research methodologies were used:

A review and analysis of CBSA and other government department (OGD) documents and data;
A review and analysis of export-related domestic and international literature;
One-on-one and group interviews with internal and external stakeholders; and
Site visits to ports in Toronto, Calgary, Vancouver and Montréal.

Conclusions and Recommendations

Overall, the evaluation found that the CBSA's involvement in export processes and related activities is entrenched in legal frameworks and is relevant. Since 2001, there has been a greater international push for countries to secure their exports, i.e. abandoning the idea that one country's exports is another country's imports and that it is the importing country's responsibility to determine the admissibility of the goods. Canada is a signatory to several international agreements on secure trade and the non-proliferation of nuclear and other weapons, and, for some of these agreements, Canada must report on its activities. The Government of Canada has recognized the importance of export security and through its investment in the Air Cargo Security Initiative. Between fiscal years 2006-2007 and 2008-2009, the CBSA received $12.1 million to support Transport Canada in designing and developing secure processes for outbound air cargo.

Canadian exports have increased substantially over the last four years. They were valued at $399 billion in 2003 compared to more than $463 billion in 2007. The CBSA's overall budget for export-related activities at headquarters (HQ) and in the regions is around $4.7 million for both policy and enforcement. This includes $0.6 million for operations and maintenance for tools, facilities, systems (including Canadian Automated Export Declaration [CAED]), system support and training.

The CBSA has export policy capacity and there are some export verification activities in the field. There is also an intelligence and targeting capacity for strategic and controlled goods at HQ and in some regions, and there are trade statistics. Information for the trade community is available on the Internet and some outreach activities are being conducted. The D-memoranda for exports were updated recently and some were reduced in length, making them more accessible to both staff and industry.

Export programs have been operating at a minimal level. Limited examination facilities and tools constrict program effectiveness and efficiency. However, the CBSA's export-related activities have contributed to improved export reporting and have benefited from the leadership and commitment of dedicated staff.

The CBSA's export-related activities are delivered across several CBSA branches and in most regions. There is no one export program in the Agency, rather there are pockets of activity and most modes of transportation are covered. Some efforts have been made to clarify roles and responsibilities between the EP Unit and the SEC Section at HQ; however, there has not been a similar exercise between these groups and the Operations Branch and between these groups and the regions. The focus on exports and resources allocated to export-related activities varies from region to region; consequently, there are delivery inconsistencies.

While communications between the EP Unit and the SEC Section have improved over the last few years, the evaluation found that there was some duplication of activities in the areas of outreach and consultation (e.g. the EP Unit, the SEC Section and some regions conduct separate outreach activities with exporters). The evaluation also found that the SEC Section and the EP Unit communicate directly with border services officers and vice versa, but rarely with one another. There are virtually no communications with the Operations Branch at HQ.

Based on feedback from interviews and site visits, it is clear that a roles and responsibilities document would be helpful not only to regional staff and management but also to those working at HQ. Border services officers have access to up-to-date standard operating procedures (SOPs) for their work pertaining to strategic export control and examinations, but there are no SOPs for compliance verification of non-strategic goods.

There is little training available to border services officers who deliver the export programs in the regions. Above and beyond the initial, brief in-service training, officers are assigned to shadow an experienced officer for several shifts, and then they are on their own. While job shadowing is a cost-effective method to train officers, it is only as effective as the officer being shadowed. There are no lists of what needs to be covered for the shadowee to use when training an officer.

Controlled and dual-use goods are very technical in nature, and, without proper training or tools, it becomes very hard for a border services officer to identify such goods. A number of the officers interviewed described the work in exports as challenging.

There is no performance measurement strategy to gauge the success of the export programs. Export declarations provide data on the number of lines (but not the number of declarations) and the dollar value of exports by port, mode, region and time. The CBSA collects data on enforcement actions against exporters, carriers and service providers and also on Administrative Monetary Penalty System penalties levied.

Recommendation 1: Consider solidifying and enhancing the management structure to support a defined CBSA exports program by undertaking the following:

Outline and define the roles and responsibilities of the EP Unit (Admissibility Branch), the SEC Section (Enforcement Branch), the Goods Processing Section (Operations Branch) and the regions, and distribute these to all program partners.
Improve communications between the export units at HQ.
Design and deliver training (in coordination with key OGDs), create checklists for shadowees to use when training new staff on export-related activities, and develop SOPs for compliance verification of non-strategic goods.
Develop and implement a performance measurement strategy.

The evaluation also found a number of gaps and vulnerabilities in the CBSA's approach to the security of facilitative programs, i.e. Summary Reporting and carrier memoranda of understanding (MOUs).

Recommendation 2: Consider developing options to enhance the security of existing facilitative programs by undertaking the following:

Enhance the risk-assessment process to ensure that companies participating in Summary Reporting and MOU signatories are subject to the same standard of security assessment as is undertaken for the Partners in Protection, Customs Self Assessment and Free and Secure Trade (FAST) programs.
Enhance understanding of the relative risks associated with exports and non-compliant export reporting.

Some current export reporting methods are not conducive to proper scrutiny. Despite the availability of electronic reporting methods, exporters continue to have a choice of submitting their export declaration in paper format. Paper B13A forms are reported at a CBSA-designated export office where exporters use a self-serve stamp machine and reports are left unsecured after-hours at certain offices.

From 2005-2006 to 2007-2008, 38.9% of all lines reported for exports fell under chapters 84 and 85 of the Harmonized Commodity Description and Coding System (HS).[ 1 ] From 2005-2006 to 2007-2008, a total of 7,229,023 lines of exported commodities were reported to the CBSA, of which 900,920 (or 12.46%) were reported using B13A forms. However, of these, 651,506 lines (or 72.3%) were used to declare goods classified under HS chapters 84 and 85.[ 2 ] These items include various kinds of machinery, appliances and sonar and electrical equipment, many of which are strategic and dual-use goods as per the Export Control List and fall under the Nuclear Non-Proliferation List or the Nuclear-Related Dual-Use List. The 2008 compliance stints indicated that about half of the B13A forms examined were for the export of machinery, appliances and electrical equipment and about half of the goods reported this way were non-compliant. B13A forms therefore represent a higher degree of risk.

CAED -- the most popular export reporting method -- is due to sunset in a couple of years, after which time it will no longer be supported. Statistics Canada hopes that the CBSA will host the CAED replacement. The EP Unit, the SEC Section and the Innovation, Science and Technology Branch are considering options.

In the air mode of transportation, there is only a two-hour window for officers to review the export reports, to risk assess them, to get to the warehouses that are distributed over several kilometres and to conduct examinations. While there is a two-hour time frame in place for the rail mode, officers have more time to conduct their review because the Rail Export Verification Unit has access to rail companies' billing information.

Recommendation 3: Continue to design and develop a single electronic reporting system in which all export-related information is stored. In addition, consider the following steps:

Eliminate the paper B13A reporting option and implement mandatory electronic reporting.
Ensure that the new system can accommodate compliance verification and targeting, and that it has report and historical functions to support performance measurement and trend analysis.
Expand the export reporting time frame for air and rail shipments.

One gap in the legislative frameworks concerns the definition of an exporter.

Recommendation 4: Review the possibility of legislative and regulatory amendments to clarify the definition of an exporter to ensure that an entity or person without a business number is still accountable for export-related infractions.

1.0 Introduction

1.1 Background

Facilitating the exportation of goods from Canada is essential to the country's prosperity. In 2007, Canada's exports added up to 35.1% of the country's $1.3 trillion economy (gross domestic product), placing Canada as the eighth-largest economy in the world. The total value of goods exported from Canada in 2007 exceeded $463 billion; 77% of those goods were destined for the United States ($356 billion).[ 3 ] Proportionally, the top three products imported by the United States from Canada were mineral fuel (e.g. oil and gas) at 25.2%, vehicles and parts (19.3%), and machinery (e.g. nuclear reactors, boilers and parts) at 7.0%.[ 4 ] Canada's other top two export partners are Japan and the United Kingdom.[ 5 ] The four principal commodity groups exported in 2007 were industrial goods and materials ($104 billion), machinery and equipment ($93 billion), energy products ($91 billion) and automotive parts ($77 billion).[ 6 ]

Canadian commodities are exported from Canada by road, rail, water and air. Table 1 shows the proportionate value shipped per mode of transportation over the last three years.

Table 1: Domestic exports by fiscal year and mode of transportation

Mode of Transport	2005-2006 Value	2006-2007 Value	2007-2008 Value
Highway	$172,163,577,664	$169,027,486,309	$156,564,904,864
Marine	$60,320,981,295	$69,823,010,577	$79,154,480,435
Other[ 7 ]	$75,541,013,519	$70,156,827,895	$78,668,537,045
Rail	$76,848,038,581	$74,314,903,323	$70,962,097,436
Air	$31,091,901,355	$32,835,229,513	$33,001,129,691
Total	$415,965,512,414	$416,157,457,617	$418,351,149,471

Source: Statistics Canada

The Canada Border Services Agency (CBSA) manages the movement of exports as legislated by a number of federal laws, acts and regulations, including the Export and Import Permits Act (EIPA), the Cultural Property Import and Export Act and the Reporting of Exported Goods Regulations. In all, there are 96 federal statutes containing provisions with respect to exports, and this does not include provincial laws.[ 8 ] Goods being exported from Canada are required by law under Part V, sections 95 to 97.2 of the Customs Act to be reported to the Government of Canada, with several exceptions. [ 9 ] The CBSA receives those reports and verifies that the goods are compliant with export laws and regulations. If non-compliant, the goods may be detained and/or seized or subject to ascertained forfeiture, or exporters or service providers are issued a monetary penalty or are subject to prosecution.

Functional guidance for the CBSA's export-related activities is provided by the Admissibility and Enforcement branches. The Export Process (EP) Unit is in the Licensing, Export and Accounting Division of the Border and Compliance Programs Directorate in the Admissibility Branch. The mandate of the EP Unit is to provide integrated export policies and program activities that support national security and public safety priorities, and facilitate the free flow of exported goods[ 10 ] that meet all legislated requirements.[ 11 ]

The Strategic Export Control (SEC) Section in the National Security Division of the Intelligence Directorate in the Enforcement Branch enforces and is consulted on export policies that meet the Government of Canada's international agreements related to the non-proliferation of nuclear and other weapons. The SEC Section administers, enforces and monitors the legislation related to the export of strategic or controlled goods to countries that pose a threat to Canada and its allies, that are involved in or under imminent threat of hostilities, that fall under United Nations Security Council sanctions, and that have a record of serious human rights violations.

The Operations Branch is the Headquarters (HQ) link to the regions. At the time of the evaluation there were no staff dedicated to export-related issues in the Branch. Front-line staff in the regions are responsible for reviewing export documents to ensure nothing is missing or incomplete and for conducting examinations as necessary based on the presence of risk indicators. Border services officers may detain goods to verify technical details or seize goods that are being exported contrary to an act of Parliament. Officers and other regional staff may also issue penalties for non-compliance under the Administrative Monetary Penalty System (AMPS).

The CBSA's National Rail Export Targeting Unit (NRETU), which is based in Winnipeg, was created in response to the International Traffic in Arms Regulations (ITAR).[ 12 ] The ITAR were developed to address concerns of the U.S. government regarding the licensed use and movement of American munitions and equipment in and to foreign countries. Under this regime, the CBSA has a heightened level of responsibility for control of specific categories of goods.[ 13 ] The NRETU is responsible for identifying, tracking and tracing export containers moved by rail to a Canadian marine port of exit that are suspected to be in violation of Canadian export laws and regulations. The Unit forwards the information regarding the targeted containers to the CBSA export examination teams in Canada and to the appropriate officials in the United States. Marine port examination teams are responsible for intercepting and inspecting the containers before they are exported.

The Rail Export Verification Unit (REVU) pilot project was developed in partnership with the Canadian National Railway Company (CN). Its objective is to ensure that the A5 reports[ 14 ] and the necessary export documents, including permits and certificates, have been filed. The REVU's focus is on rail cars and containers destined for the United States or transiting through the United States to another foreign destination. As of April 2008, Canadian Pacific Railway Limited is participating in the pilot project.

Export Reporting

Export reporting refers to presenting applicable licences, certificates and permits (all of which are considered export “reports”), as well as the export declaration[ 15 ] when applicable (also called the export “report in writing”), within prescribed time frames, depending on the method of transport (see Table 2). The goods are required to be available for examination at the time of report. Border services officers are the final checkpoints

Mode	Reporting Time Frame
Marine	Not less than 48 hours before cargo is loaded on the vessel
Air	Not less than 2 hours before cargo is loaded on the aircraft
Rail	Not less than 2 hours before the railcar containing the goods is assembled to form part of the train
Highway	Immediately prior to export

Source: CBSA, A Handy Guide for Exporters, http://www.cbsa-asfc.gc.ca/publications/pub/rc4116-eng.htm

Data obtained through export reports serves multiple purposes. The CBSA uses export reports to monitor compliance and enforce export security. Statistics Canada and other entities (e.g. importers, exporters, manufacturers, governments) use the trade information to assess the volume of exports, changes in the demand and market share, transportation requirements and infrastructure needs. Law enforcement and intelligence organizations use the information to ensure national security.

Export Declarations

Export declarations must be submitted with the export permits, licences or certificates when the goods are valued at $2,000 or more and the final destination is a country other than the United States, Puerto Rico or the U.S. Virgin Islands. The export of goods controlled, regulated or prohibited by other government departments (OGDs) and organizations -- such as the Canadian Nuclear Safety Commission, Environment Canada, Health Canada or Transport Canada -- must also be reported in writing to the CBSA.[ 16 ] Although in theory all four reporting methods are formatted to collect the same data, they are not all updated at the same time. In addition, not all the information from the four methods is entered into a singular database or sent to a singular organization.

1. Canadian Automated Export Declaration (CAED)

CAED is the most common method of declaring exports and is available from Statistics Canada to companies with a valid business number. Once a report has been submitted, the CAED form is electronically “date-stamped” as a “proof of report.” Information transmitted via CAED is also stored in the CBSA's Accelerated Commercial Release Operating Support System (ACROSS). As of April 2008, there were 71,000 CAED participants.

2. G7 Electronic Data Interchange (G7-EDI)

The G7-EDI option allows Canadian exporters to file export declarations for each shipment electronically using an electronic message format that is standard within the G7 countries. G7 reporting was implemented to facilitate the sharing of export/import information electronically with other G7 countries, and affords exporters the ability to provide an electronic copy of the G7 export declaration to the importer/agent in the importing country. G7 reports are sent simultaneously to both the CBSA and Statistics Canada. The G7-EDI system is not used as much as the other methods.

3. B13A

The B13A is a paper-based form and the second-most-used method. The exporter (or delegate) goes to the CBSA office nearest the port of exit within the time frame prescribed for the mode, finds the self-serve stamp machine, and stamps and distributes three copies of the form with the identical CBSA “proof of report” number. One copy goes to the CBSA with the other required documents, licences and permits; one copy goes to the carrier as a “proof of report”; and one copy is retained by the exporter.[ 17 ] The “proof of report” stamp has the date, time, export reporting office port code and a reference number specific to that declaration. CBSA ports are required to send the B13A forms to Statistics Canada by the third week of the following month for manual data entry and paper archiving.

4. Summary Reporting

The Summary Reporting option was implemented for exporters of bulk, low-risk goods that meet specific CBSA requirements and who export on a regular basis.[ 18 ] Participating exporters must submit export reports, by e-mail or fax, directly to Statistics Canada within five business days after the end of the month in which the goods are exported -- even if there were no exports during that month.

Tables 3 and 4 show the total commodities and value of exports from Canada reported during the last three fiscal years both by number of lines (commodities) reported and by the value of the goods. These tables demonstrate the change in relative reporting proportions by method and by year.

Table 3: Number of declarations (lines)[ 19 ] by reporting type over three years[ 20 ]

Count (No. of lines)	Fiscal Year
Count (No. of lines)	2005-2006	%	2006-2007	%	2007-2008	%	Total	%
CAED	1,740,764	80.4%	1,904,022	82.5%	2,125,020	77.2%	5,769,806	80.0%
B13A	240,052	11.2%	228,187	9.9%	432,681	15.5%	900,920	12.2%
Summary Reporting	88,005	4.1%	98,332	4.3%	103,269	3.8%	289,606	4.0%
G7-EDI	11,554	0.5%	11,273	0.5%	10,145	0.4%	32,972	0.5%
Total	2,162,695	100%	2,307,305	100%	2,759,073	100%	7,229,073	100%

Table 4: Number of declarations (value) by reporting type over three years

Value ($ millions)	Fiscal Year
Value ($ millions)	2005-2006	%	2006-2007	%	2007-2008	%	Total	%
CAED	$38,517	52.2%	$48,090	55.5%	$58,314	57.8%	$144,921	55.1%
B13A	$13,851	18.8%	$14,046	16.2%	$16,126	15.9%	$44,023	17.0%
Summary Reporting	$20,903	28.4%	$24,052	27.8%	$26,043	25.8%	$70,998	27.3%
G7-EDI	$134	0.2%	$187	0.2%	$217	0.2%	$538	0.2%
Total	$73,768	100%	$86,673	100%	$100,982	100%	$261,423	100%

“Proof of Report” -- “No Report, No Load”
There are 308 carriers and service providers who have signed a memorandum of understanding (MOU) with the CBSA indicating that they will only transport goods that are accompanied by an export report bearing the proper declaration code format.

Permits,[ 21 ] Licences and Certificates Required for Exports
Exports may require permits.[ 22 ] The Export Control List (ECL), a regulation under the EIPA, includes items controlled for their potential military and strategic uses, as well as items controlled for economic policy reasons and pursuant to international agreements or commitments. Exports of such items must be authorized in advance by an export permit issued by the Export and Import Controls Bureau of the Export Controls Division (TIE) at Foreign Affairs and International Trade Canada (DFAIT). Exports requiring a permit can be covered by a General Export Permit (GEP)[ 23 ] or by individual export permits (also issued by the TIE). The TIE is responsible for administering export permits for controlled goods or goods destined for controlled areas, in accordance with the EIPA.[ 24 ] Exports that do not fall under the ECL may require a licence, permit or certificate from another government organization. Permits must be presented to the CBSA with the corresponding export declaration. DFAIT issued 4,237 permits in 2006-2007 and 5,083 permits in 2007-2008 for military and strategic goods or technology.[ 25 ]

In addition, export permits are required for any and all exports to countries on the Area Control List.[ 26 ] Listed items that are only transiting the United States for export to other destinations also may require a Canadian export permit, depending on the country of final destination. Exporters or their agents may file for an individual permit electronically through Export Controls On-Line (EXCOL)[ 27 ] or submit a paper application to DFAIT.

1.2 Evaluation Purpose

The evaluation of the CBSA's export-related activities was identified as a priority over the 2007-2008/2008-2009 fiscal years in the CBSA Risk-Based Multi-year Evaluation Plan 2008-2011, which was approved by the Executive Evaluation Committee in November 2007. The purpose of this evaluation was to examine the design and delivery of the CBSA's export-related activities in various modes of transportation (i.e. air, highway, marine and rail) and assess related results, relevance and program effectiveness and efficiency.

1.3 Evaluation Issues and Questions

The evaluation was conducted in accordance with the Treasury Board's Evaluation Policy. In preparation for this evaluation, a logic model and evaluation framework for the CBSA's export function was developed, which defined outcomes and evaluation issues. Table 5 provides a summary of key evaluation issues and research questions for this evaluation.

Table 5: Key evaluation issues and research questions

Evaluation Issue	Evaluation Question
Relevance	To what extent are the export programs aligned with CBSA and government-wide priorities?
Relevance	To what extent is the export programs' rationale valid and addressing an actual need?

Design and Delivery	How effective are the management and delivery of the CBSA's export programs?
	To what extent are the design and delivery of export-related activities effective?
	How effective are the channels of communication for managing and delivering the export programs?
	How effective is the training for the delivery of export-related activities?
	How effective is the performance measurement of the export-related activities?

Results	To what extent have the export programs increased the compliance of exports?
	To what extent has the CBSA enhanced the control of strategic exports?
	To what extent have the export programs contributed to increased exporters' knowledge of reporting regulations and policies?

Effectiveness and Efficiency	Are the most appropriate means being used to achieve the objectives of the export programs?

1.4 Evaluation Methodology

The evaluation used the following qualitative and quantitative lines of evidence to investigate export-related activities:

Review and Analysis of CBSA and OGD Documents and Data

Internal CBSA documents, such as planning documents, management reports, standard operating procedures (SOPs), forms from different export programs, MOUs, training materials, outreach materials, security assessments, intelligence products, and budget and expenditure information.
Internal and open source OGD documents.
Statistics Canada and CBSA statistics and performance data related to the management of export activities, export process compliance verification and stints.

Literature Review

The evaluation team reviewed export-related legislation and examined international accords and agreements related to exports, including the Smart Border Declarationand 32-point Action Plan, the Security and Prosperity Partnership of North America, andWorld Customs Organization (WCO) guidelines. A review was conducted of documents relating to the design, delivery and performance of export programs operating in other countries such as the United States, the United Kingdom, New Zealand and Australia for comparison purposes and to identify alternative forms of delivery that may be relevant to the CBSA.

Key Interviews

Interviews were conducted with key stakeholders to learn about the design and management of different aspects of the export programs, and to solicit views and explanations of data and results obtained from other methodologies:

CBSA HQ staff, including senior management and program management in the Enforcement, Admissibility and Operations branches;
CBSA regional staff involved in export-related activities (e.g. regional directors general, directors, chiefs, superintendents, border services officers, export targeters, SEC officers, regional export coordinators);
Representatives of relevant OGDs; and
Representatives from select business- and export-related associations.

Table 6: Interviews conducted

Interview Category	Number of Interviewees
CBSA HQ staff	15
CBSA regional staff	42
OGD representatives	5
Industry representatives	9
Total	71

Site Visits

Four site visits were conducted: Toronto Calgary Vancouver and Montréal The visits involved observation of export compliance verification and examination processes to understand how export-related activities are managed and performed. The site visits also served to collect reports and statistics produced and compiled by the export teams.

Study Limitations

This evaluation excludes exit controls of travellers and the examination of the personal effects accompanying travellers leaving Canada. It also excludes exports in courier and postal modes.
While there is data available on a number of export-related activities, it was often not collected in a consistent, standardized manner. The unavailability of some performance data restricted the evaluators' ability to assess the impact or results of the programs. For example, it was not possible to determine the total number of declarations submitted per year or the total number of examinations conducted by border services officers; therefore, the evaluation could not determine the magnitude of exit controls on goods.
Access to highly classified documents was limited by the evaluators' security clearance. Therefore, only materials that were classified up to “secret” were used for this evaluation.
Finally, the scope of the study is restricted to CBSA programs and thus did not evaluate the activities or the programs pertaining to exports delivered by other organizations.

2.0 Key Findings

2.1 Relevance

To what extent are the export programs aligned with CBSA and government-wide priorities?

The CBSA has legal obligations with respect to exports as laid out in sections 95, 96 and 97 of the Customs Act specifically and in section 12 of the Canada Border Services Act generally.[ 28 ]

The CBSA's legislated mandate is to provide integrated border services that support national security and public safety priorities and facilitate the free flow of persons and goods, including animals and plants, that meet all requirements under the program legislation. Border management involves facilitation of exports but also exit controls.

The CBSA receives export declarations and is responsible for verifying that the related goods are compliant with export laws and regulations, and for detaining or seizing those goods that are non-compliant. These activities align well with the mandates of the EP Unit and the SEC Section (see the Introduction section). Their mandates and activities also align with the CBSA's strategic outcomes, which are that “Canada's population is safe and secure from border-related risks,” and that “legitimate travellers and goods move freely and lawfully across our borders.”[ 29 ]

Between fiscal years 2006-2007 and 2008-2009, the CBSA received $12.1 million under the Air Cargo Security Initiative to develop secure processes for outbound air cargo.

The CBSA is supporting Transport Canada in the development of secure supply chain programs, a secure supply chain management system, and air cargo screening and inspection protocols. This shows that the CBSA's export-related activities are aligned with the Government of Canada's priorities. It further shows the relevance of the CBSA's role in ensuring a secure trade chain.

Export control is a government-wide responsibility and is not restricted to the CBSA.

A multitude of government organizations have enforcement and administrative responsibilities in support of export laws, policies and regulations. DFAIT, Environment Canada, Health Canada, etc., issue permits for the exportation of controlled and/or regulated goods. Where greater concern exists for security of trade, there are additional checks and balances. For example, the objective of the Controlled Goods Directorate of Public Works and Government Services Canada is to safeguard controlled goods and/or controlled technology within Canada and to prevent controlled goods and/or controlled technology from being accessed by unauthorized persons.[ 30 ]

The CBSA's role in facilitating outbound trade is essential for Canada's economic health as it depends heavily on solid export performance.

Natural resources continue to dominate Canada's export economy. Mining, energy, agriculture and forest products represented 61% of total exports in 2006. The automotive industry also represents a significant contribution to the export sector, accounting for 11% of total exports in 2006.

The United States is by far Canada's largest trading partner. Canada's international trade with other countries is growing and the Government of Canada recognizes the importance of trade diversification. At a gathering of the Canada India Foundation on April 18, 2008, Prime Minister Stephen Harper said:

Canada has been too dependent on our customer to the south for too long. Regardless of the outcome of the next round of American elections, diversifying our trade is in the long-term interests of this country. In fact, that is starting to happen. Since 2000, [of] the US share of Canada's total trade, total exports has fallen nearly ten percent, and last year exports to other countries grew by close to 20 percent. But if there is one part of the world where we can and should be doing better it is India.[ 31 ]

Changes to the flow of trade put pressure on the CBSA to respond to the realities and evolving risks of the global market. Having solid export processes and policies helps the relationship with the United States and also prevents potential terrorist threats from entering the United States from Canada. In addition, exports to new and emerging markets also require solid export processes and policies to prevent Canadian goods from supporting enemy regimes. The potential negative economic and reputational impact for Canada failing to secure its contributions to the global supply chain is considerable in light of the country's international commitments.

To what extent is the export programs' rationale valid and addressing an actual need?

Security threats including terrorism and war amplify the issues of global trade security and counter-proliferation measures.

The United Nations Security Council resolutions 1540 (2004) and 1673 (2006) set out new obligations regarding domestic export control, law enforcement efforts regarding exportation, enhanced border controls and tighter trans-shipment controls, as well as promotion of these issues to trade stakeholders.[ 32 ] The resolutions maintain that states should prevent the proliferation of weapons of mass destruction (WMD) by establishing and enforcing effective domestic controls over exports, transits, trans-shipments and re-exports, as well as controls on funds and services related to such exports and trans-shipments. Signatories are expected to submit statements describing the ways in which they fulfill the resolutions. Canada submitted its third report on domestic implementation of Resolution 1540 in January 2008.[ 33 ]

At the 15th Asia-Pacific Economic Cooperation (APEC) summit in Sydney in September 2007, APEC members agreed to “emphasiz[e] total supply chain security as a priority for 2007.”[ 34 ] Members pledged new counter-terrorism initiatives, better aviation and transport security, and improved protection of legitimate financial and commercial systems from abuse.

The WCO Framework of Standards to Secure and Facilitate Global Trade (SAFE)[ 35 ] has set forth a minimum threshold of what must be done to facilitate a safe and secure international trade chain without creating duplication or over-burdening customs organizations and trade entities. Trade chains are vulnerable in terms of being used to transport weapons of mass effect and thus there is a need to detect illegal cross-border movements of such cargo. The SAFE Framework of Standards refers to both inbound and outbound trade, and includes standards pertaining to risk assessment, advance electronic information and outbound security inspections. The CBSA has made considerable progress on implementing the Framework for imports.

Canada supports a number of non-proliferation regimes, disarmament conventions and export control bodies. Currently, there are two CBSA participants in the Proliferation Security Initiative.

OGDs participate in other groups, such as the Wassenaar Arrangement,[ 36 ] the Australia Group,[ 37 ] the Zangger Committee and Nuclear Suppliers Group, the Chemical Weapons Convention, and the Missile Technology Control Regime. Until 2005, the CBSA's SEC Section participated in the Australia Group and the Missile Technology Control Regime; it now continues to interact with these groups informally.

2.2 Program Design and Delivery

How effective are the management and delivery of the CBSA's export programs?

The CBSA's export-related activities are delivered across several CBSA branches and in most regions. There is not a single program architecture for the CBSA's export-related activities.

The CBSA's 2008 budget for export-related activities at HQ and in the regions is around $4.7 million for both policy and enforcement. Resources have been distributed according to priority activities: the SEC Section and the EP Unit operate with close to half of the budget and the other half of the budget is shared among six regions. With the volume of exports, limited staff dedicated to exports and $0.6 million allocated to operations and maintenance to cover detection tools, information technology (IT) systems, system support and training, the program areas are limited in what they can do to build the export-related activities up to a full program.

Some efforts have been made to clarify roles and responsibilities between the EP Unit and the SEC Section; however, there has not been a similar exercise between these groups and the Operations Branch and between these groups and the regions.

While roles and responsibilities of the EP Unit and the SEC Section are fairly well understood at HQ, they are less clear for regional staff. Communications between the EP Unit and the SEC Section have improved over the last few years, yet the evaluation found that there was some duplication of activities in the areas of outreach and consultation (e.g. EP and SEC staff, regional SEC teams and other regional staff separately conduct outreach activities with exporters). Regional export staff with any questions will call either the EP Unit or the SEC Section -- this is not based on the nature of their question but rather according to whom they have dealt with in the past.

The Operations Branch is rarely consulted on export matters and does not have staff dedicated to the export file. Its Goods Processing Section is responsible for ensuring that the processing of goods entering and exiting Canada is effective, efficient and consistent. In at least one instance, the Operations Branch was unable to provide an answer to an export-related question from a front-line employee because it had not been included in any previous discussion on the issue. The lack of the Operations Branch's presence on export-related matters is another indication that there is no export program per se at the CBSA. Based on feedback from interviews and site visits, it is clear that a roles and responsibilities document would be helpful not only to regional staff and management but also to those working at HQ.

There is currently no SOP for border services officers engaged in export-related activities above and beyond strategic export control. Also, officers are expected by both HQ divisions to focus their time and effort on the activities that come under their mandate (e.g. compliance verification of export declarations and permits versus enforcement activities pertaining to strategic export goods). In addition, each region, and to some extent each port, has its own priorities and areas of risk. Expectations of roles and responsibilities are not always met. Staff interviewed for this evaluation also acknowledged the challenges associated with an under-funded program and that they are all “doing the best they can with what they have.”

To what extent are the design and delivery of export-related activities effective?

The focus on exports and resources allocated to export-related activities varies from region to region. Consequently, there are delivery inconsistencies.

CBSA management interviewed for this evaluation indicated that CBSA obligations vis-à-vis exports are important. Delivery inconsistencies are associated with varying numbers of dedicated officers at ports of exit. The number of officers varies from one to seven. Most regions have a regional intelligence officer that dedicates some, if not all, of his or her time to exports. Border services officers often concentrate on the regulations with which they are more familiar.

According to border services officers, companies have photocopied B13A forms and drivers have presented the same declaration for different export shipments. Drivers simply use the self-serve stamp machine to enter the proper date -- if at all -- raising suspicions that the export reports in the highway mode are not accurate.

The lack of resources is manifested in many ways. Dedicated teams are found in some regions for the air mode. Most ports only have one or two border services officers on duty at a time, and air cargo export reporting timelines are short (two hours). Some ports have clerks assigned to issue AMPS penalties and to verify report transaction numbers for MOU carriers, yet most do not. In terms of resource levels affecting policy, for example, updates are made to some systems and not others. Since 2005, there have been three updates made to the CAED system that affect the nature of information submitted on the report (e.g. stipulating the value be reported in Canadian currency). The same updates have never been made to the G7-EDI report format.

In 2007, the NRETU targeted 133 containers shipped by rail to marine ports where they would exit Canada by ship. A key factor that has a direct bearing on CBSA export targeting numbers is the location and number of marine/rail export examination facilities and officers in the three main marine ports (Montréal, Vancouver and Halifax). A targeted container destined for export competes for priority with incoming containers.

The NRETU has made a considerable effort to reduce the number of “missed targets.” A missed target is a container that has been identified for examination but is loaded without an examination. According to the NRETU 2007 activity report, eight targets were missed, representing 6% of all targets issued. While this amount is slightly higher than the 5.5% missed in 2006, it is significantly lower than 2002 and 2003 missed target rates, which were 11.8% and 15.7% respectively.

Current export reporting methods are not conducive to proper scrutiny and have some heightened risks in some areas.

Pre-arrival electronic reporting has been required since 2004 on imported goods. Exporters, on the other hand, continue to have a choice of submitting their export declaration in a paper format at a CBSA-designated export office. An exporter has to stamp the copies of the B13A form, leave one copy at the designated office, ensure one copy goes to the carrier and keep one copy for his or her records.[ 38 ] At the port of exit, CBSA officers go to the warehouses where the shipments are being staged for export. Time is of the essence, especially for air cargo. There is theoretically a two-hour window for officers to manually review the stack of B13A forms, risk assess and prioritize them, travel to the multiple warehouses spread over several kilometres and conduct examinations. If a declaration was submitted outside the CBSA's hours of operation, there will have been no verification.

From 2005-2006 to 2007-2008, a total of 7,229,023 lines[ 39 ] of exported commodities were reported to the CBSA, of which 900,920 (or 12.46%) were reported using B13A forms. However, of these, 651,506 lines (or 72.3%) were used to declare goods classified under chapters 84 and 85 of the Harmonized Commodity Coding and Description System (HS). Overall, items under chapters 84 and 85 represent only 38.9% of exports reported.[ 40 ] These items include various kinds of machinery, appliances and sonar and electrical equipment, many of which are strategic and dual-use goods as per the ECL and fall under the Nuclear Non-Proliferation List or the Nuclear-Related Dual-Use List. Thus, a disproportionately high number (72.3%) of goods declared on B13A forms are coded as commodities that could be strategic or dual-use goods. Recent compliance stints from 2008 indicated that about half of the B13A forms examined were for the export of machinery, appliances and electrical equipment and about half of the goods reported this way were non-compliant. B13A forms therefore represent a higher degree of risk.

There are some very large companies that are still reporting exports by paper despite the availability of free software and support. According to Statistics Canada, two companies account for 50% of the B13A forms submitted, while four companies account for over 75%. These companies are generally not eligible for Summary Reporting due to the type of goods that they export. However, Statistics Canada had at one time struck an agreement with one company to allow it to submit a summarized monthly statement directly to Statistics Canada to reduce the data entry burden.[ 41 ] Statistics Canada estimates that while it requires 10 full-time equivalents (FTEs) to capture all B13A forms, 5 FTEs are needed to input the largest single company's export data.

For fiscal year 2007-2008, approximately 77% of export information was available electronically (CAED and G7-EDI data) in Accelerated Commercial Release Operational Support System (ACROSS).[ 42 ] However, ACROSS only displays the declaration in a text format. Furthermore, the exporter does not receive an acknowledgement receipt following the submission of the export declaration. Consequently, simple data entry mistakes that could have been fixed by the exporter enter the systems to the detriment of data quality. Data shows that 61,312 CAED export declarations were rejected from July 2007 to July 2008. With some exceptions,[ 43 ] goods exported to the United States are not required to be reported to the CBSA. The billing information for goods moved by rail is reviewed by CBSA officers. However, for exports leaving Canada by highway, there is no review of manifest information, nor any examination conducted. While such exports become U.S. imports and thus are potentially reviewed by U.S. Customs and Border Protection (CBP), there is no process in place for the CBSA to verify reporting compliance.

The REVU pilot project has demonstrated the benefits of having access to pre-departure manifest information.

A previous evaluation study of the REVU pilot project showed that for CN shipments, the pilot led to more consistent and uniform application of regulations under the D-3 (transportation), D-19 (other government departments) and D-20 (export reporting) series of customs D-memoranda. Furthermore, the evaluation found that export reporting compliance had increased significantly since the pilot's inception, and that in July 2006, the rate of compliance had reached 98 percent.

Mandatory electronic reporting of exports is being introduced in the United States and by the European Union (EU) but not yet in Canada.

The United States is implementing mandatory pre-departure electronic reporting of exports for all modes (air, rail, marine and highway)[ 44 ] to monitor and enforce export controls. New regulations regarding commodity description and authorized exporter lists have been developed and come into effect on September 20, 2008.[ 45 ]

In 2005, the EU began a staged approach to its enhanced export control. The European Commission adopted a regulation aimed at increasing security for shipments (outbound and inbound) and facilitating greater compliance of operators.[ 46 ] Phase 2 takes effect in July 2009, which introduces mandatory electronic reporting of goods both entering and exiting the EU. The mandatory electronic export reporting facilitates the exchange of information between customs administrations to tighten security and safety requirements.

The CBSA has yet to develop a plan for implementing mandatory pre-departure electronic reporting of exports. U.S. CBP is working on an initiative that would require pre-arrival information on goods originating from Canada in the marine mode. The fact that Canadian exporters and carriers would have to provide the United States with electronic manifest information represents an opportunity for the CBSA to receive the same pre-departure information.

CAED is due to sunset in the next couple of years. Statistics Canada wants the CBSA to manage the next generation electronic export reporting system.

CAED is currently owned, operated and maintained by Statistics Canada. The CBSA pays Statistics Canada $350,000 a year for its shared use and upkeep of CAED. The system has been updated many times since its introduction on January 1, 1998, and each time there has been a good degree of cooperation between both agencies in meeting their respective needs. However, Statistics Canada has indicated that it can continue to support the current version of CAED for only a short period of time -- two years at most -- due to sun-setting software.

In light of this, the EP Unit, the SEC Section and the Innovation, Science and Technology Branch at the CBSA are collaborating to strengthen the CAED and identify electronic export reporting system requirements. It is envisioned that this new system would build on the fundamentals of CAED, adding provisions for more flexible communication with exporters and replacing all other reporting formats.

Summary Reporting and carrier MOUs facilitate outbound trade; however, they represent unmitigated risks as minimal security assessments are conducted on the companies.

Summary Reporting has been an efficient way for Statistics Canada to track certain kinds of bulk, frequently shipped goods. There are currently 336 exporters approved by the CBSA for Summary Reporting. Exporters simply fax or mail their report or e-mail an electronic spreadsheet once a month to Statistics Canada; staff then enter the summarized export data into Statistics Canada systems for trade purposes. Once a company is approved, it is difficult to have it disqualified.

Although Summary Reporting in its current form was created in the 1990s to improve export reporting and is valued by participating exporters, its current program design is problematic. Contrary to other trade facilitation programs delivered by the CBSA, such as the Partners in Protection (PIP), Customs Self Assessment (CSA) and Free and Secure Trade (FAST) programs, there are minimal security assessments conducted on the companies that apply for Summary Reporting.

In contrast, the modernization of PIP in June 2008 has led to an enhanced security screening program that allows members to enter other facilitative programs, such as CSA and FAST. The process involves a lengthy security application, an in-depth analysis and verification of the information provided, an on-site security visit by a regional security officer, a report on the security findings that is sent to the applicant with suggestions or recognition as applicable, and a CBSA-approved certificate and MOU once the applicant is approved. Membership has to be renewed every two years. At the time of the evaluation, the CBSA was working to align other facilitative programs with the same security procedures as PIP so that admission to one of these programs automatically qualifies members for other programs as well.

Further, by its very nature, Summary Reporting prevents pre-shipping compliance verification and interception of high-risk goods. Export reporting takes place after the goods are exported, thus requiring that the right people are admitted to the program by virtue of a front-end screening process. There are similar risks associated with the carrier MOU arrangements. However, the CBSA reserves the right to cancel the MOU if the carrier gets “too many” AMPS penalties. This has not happened yet.

How effective are the channels of communication for managing and delivering the export programs?

Internal communication on export programs is informal, and while it works in some contexts, it does also result in inefficient and sometimes conflicting information.

Middle management reported that inter-divisional communications have improved over the years. Communication channels between branch personnel are informal, based on personal connections rather than on formally defined avenues. There are no regular meetings between the EP Unit and the SEC Section, nor are there any meetings between these groups and the Operations Branch. A consequence of ad hoc interactions was, for example, the EP Unit's lack of awareness of the SEC Section's participation in an interdepartmental working group concerning both export policy and strategic and dual-use goods. It could have been useful for the EP Unit to be aware of and to contribute to this working group, given the EP Unit's mandate in export policy development and horizontal liaison. In addition, the groups were simultaneously developing proposals for a new information management system without consulting with one another.

Border services officers requiring information or assistance on a specific export-related issue will often call the person they know regardless of this being the right person for the question. Rarely will regional staff communicate with the Operations Branch on export-related matters. Communications between the EP Unit and the regions is facilitated by export coordinators, conference calls and quarterly newsletters. The export coordinators distribute e-mails from HQ to the regions and liaise as required; however, exports is only one of several files for these program coordinators. The coordinators have no responsibilities vis-à-vis the SEC Section.

Communications between adjudicators in the Recourse Directorate (Admissibility Branch) and in the EP Unit could be strengthened as well. While the Adjudications Division maintained 70% of the export-related AMPS penalties appealed during 2007-2008 -- a rate that has remained virtually the same over the last five years -- some border services officers did not support the decision to overturn some of the AMPS penalties. The Adjudications Division indicated that many penalties were overturned because of technical errors (e.g. officers both issuing an AMPS penalty and seizing the goods for the same contravention, rather than doing one or the other[ 47 ]). In the meantime, export-related AMPS penalties given increased between 2005-2006 and 2007-2008 by 15% in quantity and by 31% in dollar value, yet the number of appeals rose by only 4.1%, or to 11.1% from 6.8%.

The CBSA has generally maintained solid relationships with OGDs and private sector stakeholders.

Both the EP Unit and Statistics Canada agree that they share a good working relationship. They meet at least once every two months and sometimes more often. The groups reported effective negotiation and compromise when adjusting CAED and related D-memoranda to meet the needs of both Statistics Canada and the CBSA.

Overall, the CBSA has a good relationship with many of the OGDs involved in working groups led by the Non-Proliferation and Disarmament (Nuclear) Division of DFAIT. The SEC Section also interacts daily with the TIE (DFAIT) to enforce the EIPA at the border. However, the TIE stated its relationship with the CBSA could be improved by having regular communication with the CBSA beyond responding to officer queries. Interviews indicated that the SEC Section and the TIE do not understand one another's role, and each group has different opinions as to what the other should do to support them (e.g. the TIE felt that CBSA officers are placing too much emphasis on U.S.-origin goods in their targeting and should concentrate more on potential dual-use goods; the SEC Section noted difficulties with the TIE not accepting its input regarding the granting of permits).

The evaluators also heard from private sector stakeholders that the CBSA's consultations on the amendments to export-related regulations were comprehensive and meaningful, and were considered a best practice by one key stakeholder organization.

How effective is the training for the delivery of export-related activities?

There is little training available to border services officers who deliver the export programs in the regions.

Although some training used to be available on export reporting documents, processes and legislation at Rigaud, Quebec, prior to the expansion of the CBSA Learning Centre there, export-related training is now taught during the in-service portion of the Port of Entry Recruit Training. The in-service portion allows officers to complete their recruit training in the port where they are assigned, and it incl
udes both classroom and experiential learning. Two modules in the in-service classroom portion cover exports in the highway and marine modes, but not air.

Border services officers assigned to exports shadow an experienced officer for several shifts, and then they are on their own. While job shadowing is a cost-effective method to train officers, it is only as effective as the officer being shadowed. There are no lists of what needs to be covered for the shadowee to use when training an officer.

Controlled and dual-use goods are very technical in nature, and, without proper training or tools, it becomes very hard for a border services officer to identify such goods. The ECL is 130 pages long.[ 48 ] DFAIT employs engineers and specialists with doctorates in science to make legally binding determinations as to whether the goods or technology presented in applications are subject to the ECL. A number of the border services officers interviewed described the work in exports as challenging. More advanced training is offered occasionally by the SEC Section on identifying proliferation materials. The WMD Commodity Identification Training was produced for the U.S. Department of Energy's International Nonproliferation Export Control Program and certified SEC officers to deliver this training; however, it is delivered irregularly due to resource and time issues.

OGDs interviewed for this evaluation argued that more knowledgeable officers may lead to better risk decisions and outcomes. DFAIT has offered at least twice -- once in 1998 and again in 2008 - to advise the CBSA on developing and delivering training on how to identify strategic goods.

How effective is the performance measurement of the export-related activities?

While performance data is collected, it is not sufficient to measure whether the CBSA is achieving program outcomes.

Export declarations provide data on the number of lines (but not the number of declarations) and the dollar value of exports by port, mode, region and time. The CBSA collects data on enforcement actions against exporters, carriers and service providers and also on AMPS penalties levied.

Totals are available on targets (from the NRETU) and lookouts (from the SEC Section) issued, investigations conducted and recourse activities (import- and export-related recourse case totals are separable by contravention code; however, some are combined), but not in one place. Officers are only obligated by the SEC SOPs to report on intercepted lookouts, alerts and targets to the issuer. As such, a limited feedback loop prevents the CBSA from fully analyzing trends and enhancing systems and processes, and this hinders the export control teams from learning.

2.3 Results

To what extent have the export programs increased the compliance of exports?

77.3% of outbound air cargo examined during recent compliance verification stints was compliant. B13A forms were the most often inaccurate reports.

From January to July 2008, air cargo stints were undertaken in Toronto, Vancouver, Montréal, Winnipeg and Halifax.[ 49 ] The stints included a total of 573 examinations and 443 of the shipments were found to be compliant.[ 50 ]

Table 7: Number of compliant and non-compliant examinations by reporting method

Reporting Method	No. of Exams	Non-compliant	Compliant
CAED	264	38 (6.6% of 573)	216
B13A	145	65 (11.3% of 573)	80
Summary Reporting	15	2 (0.3% of 573)	13
G7-EDI	2	0	2
No declaration required	132	14 (2.4% of 573	132
Total	573	119 (21% of 573)	443 (77.3% of 573)

A recent compliance verification showed that stolen vehicles are being exported from Canada.

The CBSA does not have sufficient legal authority to target and seize stolen goods at the border, including stolen vehicles. However, it has the authority to examine goods to ensure they are compliant with section 95 of the Customs Act and the Reporting of Exported Goods Regulations. If a suspected stolen vehicle is encountered during an export examination, the border services officer may take action if he or she suspects that a Criminal Code offence has been committed. The officer may either issue a penalty for the misdescription of the goods (if there are errors in the declaration) or contact the police of local jurisdiction to investigate. As an indication of how serious this matter is, during a six-month period in 2008, while officers were verifying the compliance of goods with export requirements, they identified stolen vehicles in 40.9% of the containers they had selected for compliance verification that were being exported from Canada's marine ports.

As mentioned earlier in this report, the compliance of rail shipments increased dramatically with the introduction of the REVU pilot project.

The 2007 evaluation found spill-over effects on non-CN rail exports as a result of the REVU team's verbal warnings and conversations with exporters. While there is no overall data on the extent of the problem of non-compliance, the results of the REVU pilot project, the stints conducted in the air mode and the recent probe in the marine mode all show that compliance is an issue.

To what extent has the CBSA enhanced the control of strategic exports?

Since its inception, the SEC Section has contributed directly to Canada's success in counter-proliferation efforts.

In 2007-2008, the SEC Section referred a total of 81 cases for investigation (40 of which were referred internally) and issued 154 internal lookouts.

Table 8: Strategic export control enforcement actions[ 51 ]

Fiscal Year	2005-2006	2006-2007	2007-2008	Totals
Export detentions	300	326	351	977
Export seizures after detention	4	9	61	74
Export seizures	n/a[ 52 ]	n/a	5	5
Export detentions - warning letters	29	15	13	57
Warning letters (ascertained)	128	176	115	419
Ascertained forfeitures[ 53 ]	n/a	n/a	2	2
Total actions	461	526	547	1534
Value of goods	$27,520,256	$62,594,388	$65,305,638	$155,420,282

To date, the SEC Section has contributed to 44 convictions involving 12 exporters/organizations (according to program files). In 2007, the NRETU targeted 133 containers: 83 were released after inspection, the inspection of 42 containers resulted in enforcement actions (10 were detained for reporting and export violations), and no action was undertaken on the remaining 8 containers. DFAIT and the SEC Section are currently reviewing the files on the detentions to determine possible seizure action.

To what extent have the export programs contributed to increased exporters' knowledge of reporting regulations and policies?

Export programs have contributed to improved export reporting.

In 2003-2004, Statistics Canada's International Trade Division conducted a review to estimate the level of export undercoverage in the marine mode. It found that 30% of the value of the goods leaving Canada had not been reported. In 2005, the estimated marine export undercoverage rate had fallen to a low of just 1.24%, which the Division attributed to initiatives implemented by the CBSA.

The CBSA consulted with external stakeholders in 2004-2005 and made revisions to export regulations, such as stipulating time frames for export reporting and other changes, and it introduced new contraventions specific to exports. The CBSA established MOUs with carriers to implement a no-report, no-load policy between carriers and service providers in 2004-2005. At the time of the evaluation, the CBSA had 308 MOUs with 191 carriers and 118 service providers (e.g. brokers, freight forwarders).

At the time of the evaluation, Statistics Canada had yet to complete a similar study on air cargo reporting.

Monetary penalties appear to have helped improve accurate and timely export reporting. The reasons for issuing an AMPS penalty have shifted from failure to produce an export report to failing to provide something with the report.

AMPS contravention C005, which is directed at exporters who have failed to provide accurate export reporting, was issued 15% fewer times in 2007-2008 than in 2005-2006 (see Table 9). Exporters interviewed for this evaluation noted that they were not fully cognizant of their reporting obligations. Most learned about their obligations after they received a monetary penalty or after their goods were detained.

At the same time, there has been a marked increase in the number of C315 contraventions (failing to obtain the necessary permit for controlled, regulated or prohibited goods): from 89 penalties in 2005-2006 to 824 in 2007-2008. This increase can be attributed to one export control team in the air mode that made a concerted effort to ensure shipments needing a permit in fact had one.

Freight forwarders interviewed for this evaluation said that when permits are late in being issued, exporters frequently ask them to ship the goods without the necessary permits because time is money - especially before the end of the fiscal quarter.

Table 9: Export AMPS penalties[ 54 ] issued over the last three fiscal years

MEASURES as values	FY 2005-2006		FY 2006-2007		FY 2007-2008
MEASURES as values	Number of Contraventions Total	$ Value - Total	Number of Contraventions Total	$ Value - Total	Number of Contraventions Total	$ Value - Total
C005	1,618	$196,100	1,644	$194,000	1,361	$171,400
C170	125	$4,000	165	$93,000	110	$121,000
C189	1	$1,000	0	$0	1	$1,000
C190	0	$0	0	$0	0	$0
C192	1	$1,000	1	$1,000	0	$0
C193	0	$0	0	$0	0	$0
C194	0	$0	0	$0	0	$0
C195	0	$0	0	$0	0	$0
C315	89	$128,000	140	$187,000	824	$2,217,000
C316	0	$0	0	$0	0	$0
C317	0	$0	0	$0	0	$0
C318	0	$0	0	$0	0	$0
C319	0	$0	0	$0	0	$0
C341	0	$0	0	$0	0	$0
C343	195	$195,000	219	$219,000	202	$202,000
C345	6	$69,415	23	$58,000	3	$10,575
C346	2	$27,229	6	$29,970	0	$0
C348	213	$2,022,935	3,172	$3,469,476	169	$722,260
C362	291	$33,300	371	$41,300	348	$39,700
C368	0	$0	2	$2,000	4	$7,000
Total Export Contraventions	2,346	$2,482,980	5,524	$4,076,746	2,820	$3,289,935

The following table illustrates the recourse activities for export contraventions in 2007-2008. It shows that of 1,492 AMPS penalties issued during this period, 22% were appealed and, of the 144 decisions rendered during this period, 70% of the penalties were maintained.

Table 10: 2007-2008 Export AMPS penalties appealed to the Recourse Directorate

Fiscal year 2007-2008
Contravention	Issued	Appealed	Maintained	Overturned	Admin. Closure	Total Decisions
C170	111	37	10	11	1	22
C189	1	0	0	0	0	0
C190	0	1	0	0	0	0
C192	1	0	1	0	0	1
C194	0	0	0	0	0	0
C315	818	207	37	6	1	44
C318	0	0	0	0	0	0
C319	0	0	0	0	0	0
C341	0	0	0	0	0	0
C343	206	39	24	14	0	38
C345	3	1	2	1	0	3
C346	0	1	1	5	0	6
C362	348	39	26	4	0	30
C368	4	3	0	0	0	0
Total	1,492	328	101	41	2	144

2.4 Effectiveness and Efficiency

Are the most appropriate means being used to achieve the objectives of the export programs?

One gap in the legislative frameworksconcerns the definition of an exporter.

The wording “causes them to be exported” in the definition of an exporter in the Reporting of Exported Goods Regulations does not mean the person involved in the transportation of the goods, but the person who owns and is requesting to move the goods. The exporter is therefore responsible for any non-compliance that may have been caused by the freight forwarder.

The lack of export-related resources and tools means that there are inefficiencies in exit controls.

In the air mode, border services officers have to examine goods in warehouses or on the tarmac where often goods have already been staged for loading. There are a multitude of warehouses -- some airside, others several kilometres away outside the port. Officers can spend hours over a shift driving to warehouses to conduct examinations, reviewing manifests and declarations (B13A forms may not have been dropped off at their office), and driving back to the office to check databases and conduct research to verify a report or shipment. Officers prioritize their activities by focusing on warehouses associated with specific airlines and of perceived higher risk. The distance to travel, the paper format of the declarations and the absence of an automated risk-assessment system reduce the number of examinations that could be conducted.

There are staff in both the regions and at HQ that have worked in the area of exports for many years. Their knowledge, passion and leadership have contributed to the results achieved.

Staff in one port have negotiated agreements with several shipping companies with the result that those companies voluntarily disclose their billing information to the CBSA. This gives the export control team access to information earlier than if they were to use the submitted export declarations to target strategic goods.

Staff have shown that developing relationships with clients and key players in and around the port of exit facilitates their work. For example, warehouse managers may contact CBSA officers if they come across shipments that merit further attention. CBSA staff also conduct outreach activities with exporters and service providers to promote future compliance (usually following a series of AMPS penalties).

Export Resources

The CBSA spends approximately $4.7 million on export-related activities.

3.0 Conclusions, Recommendations and Management Response

Overall, the evaluation found that the CBSA's involvement in export processes and related activities is entrenched in legal frameworks and is relevant. Since 2001, there has been a greater international push for countries to secure their exports, i.e. abandoning the idea that one country's exports is another country's imports and that it is the importing country's responsibility to determine the admissibility of the goods. Canada is a signatory to several international agreements on secure trade and non-proliferation of nuclear and other weapons, and, for some of these agreements, Canada must report on its activities. The Government of Canada has recognized the importance of export security and through its investment in the Air Cargo Security Initiative. Between fiscal years 2006-2007 and 2008-2009, the CBSA received $12.1 million to support Transport Canada in designing and developing secure processes for outbound air cargo.

Canadian exports have increased substantially over the last four years. They were valued at $399 billion in 2003 compared to more than $463 billion in 2007. The CBSA's overall budget for export-related activities at HQ and in the regions is around $4.7 million for both policy and enforcement. This includes $0.6 million for operations and maintenance for tools, facilities, systems (including CAED), system support and training.

Export programs have been operating at a minimal level. CBSA export-related activities are not supported by a number of important tools. Unlike for imported goods, there is no overall database whereby electronic manifest information is stored to verify export permits and declarations. Similarly, the CBSA does not have an IT system that allows for automated risk assessments of exports. Limited examination facilities and tools constrict program effectiveness and efficiency, minimizing the extent to which export verifications and examinations are conducted. However, the CBSA's export-related activities have contributed to improved export reporting and have benefited from the leadership and commitment of dedicated staff.

Based on feedback from interviews and site visits, it is clear that a roles and responsibilities document would be helpful not only to regional staff and management but also to those working at HQ. Border services officers have access to up-to-date SOPs for their work pertaining to strategic export control and examinations, but there are no SOPs for compliance verification of non-strategic goods

There is little training available to the border services officers who deliver the export programs in the regions. Above and beyond the initial, brief in-service training, officers are assigned to shadow an experienced officer for several shifts, and then they are on their own. While job shadowing is a cost-effective method to train officers, it is only as effective as the officer being shadowed. There are no lists of what needs to be covered for the shadowee to use when training an officer.

Recommendation 1: Consider solidifying and enhancing the management structure to support a defined CBSA exports program by undertaking the following:

Outline and define the roles and responsibilities of the EP Unit (Admissibility Branch), the SEC Section (Enforcement Branch), the Goods Processing Section (Operations Branch) and the regions, and distribute these to all program partners.
Improve communications between the export units at HQ.
Design and deliver training (in coordination with key OGDs), create checklists for shadowees to use when training new staff on export-related activities, and develop SOPs for compliance verification of non-strategic goods.
Develop and implement a performance measurement strategy.

Management Response:
The CBSA concurs with this recommendation. The Admissibility Branch will lead in establishing an export working group at HQ that will include representation from the Enforcement and Operations branches. This group will be tasked with defining roles and responsibilities, improving communications and developing a performance measurement strategy by June 2009. The recommended checklists for shadowees to use when training new staff on export-related activities and SOPs for compliance verification of non-strategic goods will be developed by December 2009. A discussion paper on a training strategy for the exports program will be developed in consultation with the Training and Learning Directorate (Human Resources Branch). The training strategy will address the identification of training and resource needs and will be prepared by the Admissibility Branch by December 2009.

The evaluation also found a number of gaps and vulnerabilities in the CBSA's approach to the security of facilitative programs (i.e. Summary Reporting and carrier MOUs). While these programs provide efficiencies and have enhanced export reporting, security assessment processes are minimal, which allows for unmitigated residual risks. This brings into question whether participants should be treated as low risk, particularly since the export reports are submitted after the goods have departed.

Recommendation 2: Consider developing options to enhance the security of existing facilitative programs by undertaking the following:

Enhance the risk-assessment process to ensure that companies participating in Summary Reporting and MOU signatories are subject to the same standard of security assessment as is undertaken for the PIP, CSA and FAST programs
Enhance understanding of the relative risks associated with exports and non-compliant export reporting.

Management Response:
The CBSA concurs with this recommendation. The Admissibility Branch will review the risk-assessment process for Summary Reporting applicants and take the lead in the development of a risk-assessment process for MOU signatories by January 2009. The performance management strategy, referred to in Recommendation 1, will include the monitoring of the compliance of companies using Summary Reporting in terms of commodities exported and the “proof of report” requirement under the MOUs. The Admissibility Branch, jointly with the Enforcement and Operations branches, will conduct compliance stints and other enforcement activities to develop baseline data to formulate an export risk profile by July 2009.

From 2005-2006 to 2007-2008, 38.9% of all lines reported for exports fell under chapters 84 and 85 of the HS.[ 55 ] From 2005-2006 to 2007-2008, a total of 7,229,023 lines of exported commodities were reported to the CBSA, of which 900,920 (or 12.46%) were reported using B13A forms. However, of these, 651,506 lines (or 72.3%) were used to declare goods classified under HS chapters 84 and 85.[ 56 ] These items include various kinds of machinery, appliances and sonar and electrical equipment, many of which are strategic and dual-use goods per the ECL and fall under the Nuclear Non-Proliferation List or the Nuclear-Related Dual-Use List. Recent compliance stints from 2008 indicated that about half of the B13A forms examined were for the export of machinery, appliances and electrical equipment and about half of the goods reported this way were non-compliant. B13A forms therefore represent a higher degree of risk.

In the air mode of transportation, there is only a two-hour window for officers to review the export reports, to risk assess them, to get to the warehouses that are distributed over several kilometres and to conduct examinations. While there is a two-hour time frame in place for the rail mode, officers have more time to conduct their review because the REVU has access to rail companies' billing information.

Recommendation 3: Continue to design and develop a single electronic reporting system in which all export-related information is stored. In addition, consider the following steps:

Eliminate the paper B13A reporting option and implement mandatory electronic reporting.
Ensure that the new system can accommodate compliance verification and targeting, and that it has report and historical functions to support performance measurement and trend analysis.
Expand the export reporting time frame for air and rail shipments.

Management Response:
The CBSA concurs with the need to design and develop a single electronic reporting system in which all export-related information is stored. The Admissibility Branch will lead the development, by December 2009, of detailed business requirements for a new system, including compliance verification and targeting needs, and report and historical functions for performance measurement and trend analysis. The development and implementation of this new system will be dependant on overall CBSA priorities and on obtaining the necessary financial and human resources. The Admissibility Branch will prepare, by October 2009, a policy paper on mandatory electronic reporting and the expansion of reporting time frames for rail and air modes.

One gap in the legislative frameworks concerns the definition of an exporter.

Management Response:
The CBSA concurs with this recommendation. The Admissibility Branch will prepare legislative and regulatory amendments.

Appendix A: List of key acts governing export reporting

Act of Parliament	What the law requires	What procedures apply
Canadian Environmental Protection Act	Affects materials, substances and goods stipulated by the Transportation of Dangerous Goods Regulations and the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations, as well as plants and animals covered by the Convention on International Trade in Endangered Species.	Apply for a permit through the appropriate federal or provincial department, depending on what is to be exported, e.g. Fisheries and Oceans Canada for fish or the Saskatchewan department of agriculture for livestock. Present licence and any health certificates as well as the export permit as needed at the port of exit nearest to the point of departure within the time frame prescribed.
Controlled Drugs and Substances Act	All drugs, precursor chemicals and controlled substances under schedules I, II, III and IV of the Act may not be exported (nor possessed for export) unless in accordance with the related regulations. The regulations set out the requirements and procedures for any licences and certificates required for exportation that fall under this Act.	Obtain appropriate registration and/or licence from Health Canada depending on the schedule that applies. Present licence and export permit as needed at the port of exit nearest to the point of departure within the time frame prescribed.
Cultural Property Export and Import Act	A licence to export is needed for objects that appear on the Canadian Cultural Property Export Control List. Objects less than 50 years old or that were made by a natural person who is still living are excluded.	Request a paper permit application form from Canadian Heritage (the form is not available online). The permit application becomes a valid permit once it has been signed by one of the licence-issuing border services officers across Canada (there are currently 17). The permit must be presented to the Canada Border Services Agency (CBSA) with a declaration at the port of exit (and at the port of entry if the goods are returning from being temporarily exported).
Customs Act	Part V, section 95: “…all goods that are exported shall be reported at such time and place and in such manner as may be prescribed.” Must report goods[ 57 ] that are valued at more than CAN$2,000; that are controlled or restricted; and that are destined for other than the United States, Puerto Rico or the U.S. Virgin Islands.	A General Export Permit OR an individual export permit AND an export declaration (i.e. using CAED, a B13A form, Summary Reporting or G7-EDI). Present all relevant licences/ certificates as well as export permits as needed at the port of exit nearest to the point of departure within the time frame prescribed.
Export and Import Permits Act	Sets out the Export Control List and Area Control List for which exports would require a permit. Administered by Foreign Affairs and International Trade Canada (DFAIT). Enforced by the CBSA.	Register with the Controlled Goods Directorate of Public Works and Government Services Canada. Apply to DFAIT for an export permit. Include permit number on completed export declaration that is presented to the CBSA office nearest to the port of exit within the time frame prescribed.
Firearms Act	Firearms and ammunition are controlled exports, as per the Export and Import Permits Act, the Criminal Code (section 103) and the Firearms Act.	Obtain the proper business licence and export permit. Present licence and export permit as needed at the port of exit nearest to the point of departure within the time frame prescribed
Food and Drugs Act	All food, drugs, pharmaceuticals and cosmetics require an export certificate from Health Canada as per section 37 of the Act and related regulations in accordance with international trade agreements. Enforced by the Canadian Food Inspection Agency (CFIA) and the CBSA as stipulated.	Complete and sign (including witnesses) the Health Canada export certificate (available online) stating that the goods for export do not contravene any known requirement of the laws of the country of import. Present certificate and export permit as needed at the port of exit nearest to the point of departure within the time frame prescribed.
Health of Animals Act	Section 19 (1): “No person shall export an animal from Canada by vessel or aircraft unless (a) prior notice of the export of the animal has been given to a customs officer in charge of the place where the animal is to board the vessel or aircraft and the animal has been presented to a veterinary inspector in accordance with subsection (2) at that place; and (b) a certificate of the veterinary inspector has been received by the person certifying that all the prescribed requirements respecting the health, protection and transportation of the animal have been complied with.” The CFIA enforces the related regulations; the CBSA enforces the export requirements at the border.	Comply with the Canadian Environmental Protection Act. Obtain a veterinary certificate for the health of the animals to be exported. Present with the export permit (and declaration if necessary) a copy of the veterinary certificate to the pilot or master agent of the vessel and to the chief CBSA officer at the marine or air port of exit. The vessel or aircraft are not to depart without the veterinary certificates testifying to the health of onboard animals. The Health of Animals Act also covers the conditions of transport.
Nuclear Safety and Control Act	Section 26 (a): “Subject to the regulations, no person shall, except in accordance with a licence, (a) possess, transfer, import, export, use or abandon a nuclear substance, prescribed equipment or prescribed information.” The Canadian Nuclear Safety Commission (CNSC) is the federal authority that licenses the export of nuclear and dual-use equipment technology.	Apply to the CNSC for a licence; separate licences are needed for processing, transporting and using nuclear substances. Present licence and export permit as needed at the port of exit nearest to the point of departure within the time frame prescribed.
Transportation of Dangerous Goods Act	Regulates the transport of all dangerous goods. Under the Act, no person may handle dangerous goods unless all safety standards and prescribed documentation requirements are complied with, and all containers, packages and means of transport are clearly marked with prescribed safety marks. Dangerous goods are classified as explosives, gasses, flammable and combustible liquids, flammable solids, oxidizing substances, poisonous and infectious substances, radioactive materials, corrosives and any other substances and organisms deemed dangerous. The Act is administered by Transport Canada and enforced by the CBSA at the border.	Have all verifying documents available for a CBSA officer to check and to ensure that containers are clearly marked according to safety standards and are consistent with the shipping documents. Present documents with export permit as needed at the port of exit nearest to the point of departure within the time frame prescribed.

Appendix B: Export-related monetary penalties (Administrative Monetary Penalty System)

No.	Legislation	Regulation	Contravention	Penalty Condition	Penalty Basis
C005	Customs Act, section 7.1		Person provided information to an officer that is not true, accurate and complete. The information required to be provided in any permit, certificate, licence, document or declaration in respect of imported or exported goods is incorrect.	1st - $100 2nd - $200 3rd + - $300	Per document
C170	Customs Act, subsection 95(1)		Exporter failed to report the export of goods on an export declaration within the legislative timeframes prior to export.	1st - $1,000 2nd - $2,000 3rd + - $3,000	Per shipment
C189	Customs Act , paragraph 95(3)(a)		Person who has reported goods under subsection 95(1) of the Customs Act failed to answer truthfully any question asked by an officer with respect to the goods.	1st - $1,000 2nd - $2,000 3rd + - $3,000	Per instance
C190	Customs Act, paragraph 95(3)(b)		Person who has reported goods under subsection 95(1) of the Customs Act or the person who has possession of the goods at the time of the request by the customs officer failed to present goods, remove any covering from the goods, unload the conveyance or open thereof or unpack any package.	1st - $1,000 2nd - $2,000 3rd + - $3,000	Per instance
C192	Customs Act, section 96		Person who reported goods under subsection 95(1) of the Customs Act failed to export goods and failed to report failure to export the goods.	1st - $1,000 2nd - $2,000 3rd + - $3,000	Per shipment
C193	Customs Act, subsection 97.1(2)		Exporter or producer of goods failed to provide officer with a copy of certificate of origin on request.	1st - $1,000 2nd - $2,000 3rd + - $3,000	Per request
C194	Customs Act, subsection 97.1(3)		Person who has completed and signed a certificate of origin in accordance with subsection 97(1) of the Customs Act failed to notify person to whom the certificate was given, of incorrect information.	1st - $100 2nd - $200 3rd + - $400	Per certificate
C195	Customs Act, subsection 97.2(1)		Person who exported goods or caused goods to be exported failed to keep records at the place of business in Canada or at a designated place for a prescribed period.	1st - $1,000 2nd - $5,000 3rd - $10,000 4th + - $25,000	Per audit
C315		Reporting of Exported Goods Regulations, section 5	Exporter failed to provide to customs, according to the legislative timeframes, any export permit, licence or certificate required.	1st - $1,000 2nd - $2,000 3rd + - $3,000	Per document
C316	Customs Act, subsection 95(1)		Exporter failed to submit an export summary report.	1st - $2,000 2nd - $5,000 3rd + - $10,000	Per summary report
C317	Customs Act, subsection 95(1)		Exporter submitted written summary report for goods that do not qualify for summary reporting.	1st - $1,000 2nd - $2,000 3rd + - $3,000	Per shipment
C318	Customs Act, subsection 97.2(1)		Person who exported goods failed to make such records available to an officer within the time specified.	1st - $1,000 2nd - $5,000 3rd - $10,000 4th + - $25,000	Per occurrence
C319	Customs Act, subsection 97.2(1)		Person who exported goods failed to truthfully answer any questions asked by an officer in respect of the records.	1st - $1,000 2nd - $5,000 3rd - $10,000 4th + - $25,000	Per occurrence
C341	Customs Act, subsection 95(1)		Exporter failed to report a shipment on an export summary report.	1st - $1,000 2nd - $2,000 3rd + - $3,000	Per shipment
C343	Customs Act, subsection 95(1)		Person failed to report in bond cargo to customs outbound.	Flat rate - $1,000	Per shipment or manifest
C345	Customs Act, subsection 95(1)		Exporter failed to report goods subject to export control prior to export.	1st - $2,000 or 20% of the value of the goods, whichever is greater 2nd - $4,000 or 40% of the value of the goods, whichever is greater 3rd + - $6,000 or 60% of the value of the goods, whichever is greater	Value of goods
C346	Customs Act, paragraph 95(3)(a)		Person who has reported goods under subsection 95(1) of the Customs Act that are subject to export control, failed to answer truthfully any question asked by an officer with respect to the goods.	1st - $2,000 or 20% of the value of the goods, whichever is greater 2nd - $4,000 or 40% of the value of the goods, whichever is greater 3rd + - $6,000 or 60% of the value of the goods, whichever is greater	Value of goods
C348	Customs Act, section 7.1		Person intentionally provided false information in any permit, certificate, licence, document or declaration required to be provided for imported or exported goods under the Customs Act, the Customs Tariff or the Special Import Measures Act or under any other Act of Parliament that prohibits, controls or regulates the importation or exportation of goods.	1st - $2,000 or 20% of the value of the goods, whichever is greater 2nd - $4,000 or 40% of the value of the goods, whichever is greater 3rd + - $6,000 or 60% of the value of the goods, whichever is greater	Value for duty or value of goods
C362		Reporting of Exported Goods Regulations, section 5	Exporter failed to indicate the General Export Permit (GEP) number in the permit field of the export declaration.	1st - $100 2nd - $200 3rd + - $300	Per missing GEP number

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To what extent are the export programs aligned with CBSA and government-wide priorities?

To what extent is the export programs' rationale valid and addressing an actual need?

How effective are the management and delivery of the CBSA's export programs?

To what extent are the design and delivery of export-related activities effective?

How effective are the channels of communication for managing and delivering the export programs?

How effective is the training for the delivery of export-related activities?

How effective is the performance measurement of the export-related activities?

To what extent have the export programs increased the compliance of exports?

To what extent has the CBSA enhanced the control of strategic exports?

To what extent have the export programs contributed to increased exporters' knowledge of reporting regulations and policies?

Are the most appropriate means being used to achieve the objectives of the export programs?

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