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Better Representation of Canadian Consumers

The Issue

We find more and more instances, nationally and internationally, where the participation of consumer representatives is solicited: issue tables, economic regulatory agencies, standard-setting bodies, self-regulating organizations, etc.

This participation has become essential in applying principles of good governance, and it improves the credibility and effectiveness of mechanisms for developing policies, standards and regulations.

It also enables the establishment of a better balance between the positions dictated by specific interests and those defending general interest. This balance is sound from an economic point of view since it allows the market to work better and builds consumer confidence.

What are the criteria for choosing organizations or persons who will defend or express the concerns of consumers? How do we ensure the competence and independence of those representatives? How do we ensure their accountability? How do we make sure that adequate funding is provided for effective and informed involvement?

All consumer representation players, and first and foremost the Government of Canada, should examine the relevance of setting criteria and mechanisms to ensure the representativeness, competence and legitimacy of those who play the essential role of promoting and defending consumer interests and reinforcing public trust in consultation and consensus-building processes.

After analyzing best existing practices (of Australia and the Canadian Environmental Network, notably) and the current situation in Canada, it is noted that across the country, few jurisdictions use a formal and clearly established procedure for choosing which consumer representatives to consult.

Furthermore, financial resources required to ensure this involvement are practically non-existent. This does not help to ensure the participation of representative, qualified and accountable representatives.

Consequently, the Council advocates the development of a formal policy for recognizing consumer representatives, on the model of that adopted by Australia. This approach must include the principles essential for ensuring adequate representation, to wit competence, independence, representativeness and accountability. The approach must also include the principles essential for the credibility of the processes, that is transparency of the criteria and appointment processes, responsible appointment processes at reasonable cost, an insistence on the application of rules of good governance, and the involve- ment of consumer rights organizations. Observance of those principles will be ensured by the definition of criteria for recognizing consumer representatives; those criteria are detailed in one of our recommendations.

The Council also recommends recognition of the necessity to provide sufficient resources for ensuring adequate representation, i.e., granting financial resources and offering continuous training to consumer representatives.

The framework for recognizing consumer representatives should be developed in cooperation with consumer rights groups. To that end, sufficient resources should be allocated to ensure adequate participation of these groups.

Recommendations

  1. The adoption of a framework for recognizing consumer representatives;
  2. That this framework reflect the principles essential to adequate representation, to wit:
    1. Competence;
    2. Independence;
    3. Representativeness;
    4. Accountability.
  3. That this framework reflect the principles essential to the credibility of the processes:
    1. The transparency of appointment criteria and processes;
    2. Responsible appointment processes at reasonable cost;
    3. Recognition of the application of good governance rules;
    4. The involvement of consumer rights organizations.
  4. That this framework recognize the necessity of allocating sufficient resources to ensure adequate representation.

The details of this framework could be worked out by an independent task force on which representatives of government and consumer associations would sit.

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