Some weeks ago, I referred to the impending proposal to include beer in a trade retaliation against the US. Here is my submission sent by email today to the International Trade Policy Division of the Canadian Federal Department of Finance. I encourage you to send a similar note to the email address at the end of this post.

I would like to make this brief submission to the International Trade Policy Division on the matter of proposed retaliation one item in the proposed - beer. In my submission, I address four aspects of the proposed surcharge as it relates to beer, tariff item 2203.00.00.

First, I would like to make clear that it is not so much the presence of the item on the list but the failure of the proposal to include a sensible threshold for the proposed 100% surcharge which needs addressing. This dispute is between nations and is in reaction to trade at the wholesale and industrial levels. By allowing the surcharge to apply to imports of items, including beer, by consumers in small quantities, you are not being responsive to anything related to the Byrd Amendment. You are only punishing Canadian consumers and our US retailing neighbours - whose business is made only in tiny part by Canadian consumers. Fees and charges at the border regularly are waived for items bought by individual consumers due to, for example, length of stay. I would ask that the proposal consider making a $200 CND per visit exception to the proposed surcharge if you must impose this surcharge.

Second, that being said, I still would like to point out that the inclusion of "beer made from malt" is a selective category not in keeping with the other items on the list. Most other items reflect a wholesale importation of a product for further production. Canada trades in bulk fish, dried beans and legumes and wood products. Canada does not import bulk beer for further production and, in fact, most brands of beer which appear to be American on Canadian shelves are actually produced under license within Canada. Your inclusion of the item will not affect the trade in the brands of US beers, which is where the wholesale market truly exists. It will only address the fictitious wholesale trade. There is no wholesale dumping of US produced beer on the Canadian market. This would likely be one of the most useless attempts to flood a market ever tried in international trade as Canadians generally do not like US beer. They like Canadian brewed US brands but, as I have stated, this is a separate trade in intellectual property and not malty brew. Please ban Old Milwaukee brewing in Canada if you like. That is a separate issue, however.

Third, even among alcoholic beverages, your proposal is inconsistent. Certain wines, whiskies, rum and vodkas are included in the proposal but not gins, liqueurs and brandies. It would seem odd that bulk spirits of those categories, which might actually constitute a trade item, would be left off the list while beer, unknown to the cross-border tanker trade by the very nature of its production, would be included. Why vile cheap gin should not be included when wholesome craftsmen-like real ales are makes no sense.

Fourth, if you are insistent, make sure the tariff applies only to US beer and not beer imported to the US, resold to Canadians and then brought in. Why should we and Belgian lambic producers both suffer when it is Senator Byrd's problem we are seeking to redress.

In summary, it is my submission that beer is just an easy hit, an item on your check list of standard retaliatory categories which actually has no relation to the aims of your policy. If you insist on including it, please make it apply only at the $200 CND importation level or more. Better still, leave it off. There are only a few beer nerds like me who will be affected, who like to go over a few times a year and buy items of micro-brewed beer that we find interesting. I am glad to pay the premium I do and claim every time I drive south a couple of hours to find something different to share with pals. How the heck will stopping that have any effect on US trade policy? It won't. It will only punish what is little more than a hobby.

Thank you for your time taken considering my submission. I look forward to your response and incorporation of my suggestions if deemed appropriate.

Alan McLeod, LLB, LLM
http://beerblog.genx40.com
Kingston, Ontario