G/RO/W/153  
 
11 December 2014  
(14-7213)  Page: 1/2  
Committee on Rules of Origin  Original: English  
 
 COMMENTS BY CANADA ON THE PA PER PRESENTED BY UGANDA  
ON BEHALF OF THE LDC GROUP ENTITLED "CHALLENGES FACED BY LDCS  
IN COMPLYING WITH PREFERENTIAL RU LES OF ORIGIN UNDER UNILATERAL 
PREFERENCE SCHEMES" (DOCUMENT G/RO/W/148) 
The following submission, dated 9 December 2014,  is being circulated at the request of the 
delegation of Canada. 
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  At the 30 October 2014 Meeting of the Committee on  Rules of Origin, Uganda, on behalf of the 
LDC Group, presented a paper on the challenges faced by LDCs in complying with preferential 
rules of origin under unilateral preference schem es (Document G/RO/W/148).  Canada welcomes 
the paper and appreciates the efforts of the LDC Group to share its experiences with complying 
with preferential rules of origin schemes. 
Canada appreciates the opportunity to comment on the paper.  At this time, Canada would like to 
inform the authors of inaccuracies in the paper with respect to Canada's preference scheme for 
L D C s  a n d  r e q u e s t  t h a t  t h e s e  f a c t u a l  e r r o r s  b e  c o r r e c t e d .   C a n a d a  m a y  c o m e  b a c k  t o  t h e  
Committee in the future with more substantive comments on the paper.  
- Canada requests that the reference to its name be removed from Section 3.1.2(a) and 
added to Section 3.1.2(c), so as to accurately reflect the way Canada calculates the value 
percentages of rules of origin.  Canada's rules of origin specify the maximum amount of 
non-originating materials as a percentage of the ex-factory price of the good.  
(See Sub-section 2(3) of the General Preferential Tariff and Least Developed Tariff Rules of 
Origin Regulations http://laws-lois.justice.gc.ca/PDF/SOR-2013-165.pdf ). 
- Canada requests that the following changes be ma de to Table 2 in Section 3.3.7:  i) the text 
"originating contents" in column Numerator and row Canada be replaced by "Value of 
non-originating material"; and ii) the text "Equal or greater than 40 per cent" in column 
Percentage Level and row Canada be replaced  by "Maximum amount of non-originating 
material is 60 per cent, however a further 20 per cent can be sourced from certain countries listed in the regulations." 
- Canada requests that the following text in Section 3.3.8 be removed as it is inaccurate: 
"This possibility however will be severely limite d by the graduation policy of Canada taking 
into effect in 2015.  According to this graduation policy Canada will be removing benefits 
from 72 higher-income and trade-competitive countries, effective 1 January 2015 including 
China and therefore no cumulation will be possi ble with the graduated countries.  While the 
Government of Canada has expressed the intention to take action to ensure that the 
benefits of the Least Developed Country Tariff (LDCT) regime would not be reduced by 
changes to GPT country eligibility, no further action has been taken at time of this writing.  Such graduation policy is not unique to Canada since also".  Accordingly, footnote 31 should also be removed.  On 9 October 2013, Canada published new regulations that will take 
effect on 1 January 2015 and that preserve the status quo by stipulating that LDCs can 
continue to cumulate origin with the countries that are being graduated from the GPT program (see link above).  G/RO/W/153 
 
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  - Canada requests that the text "this graduation" in the penultimate sentence of Section 3.3.8 
be changed to "EU graduation".  Cambodian bicycle manufacturers will be unaffected by the Canadian GPT changes that will take effect on 1 January 2015. 
 
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