June 13, 2018
The Right Hon. Justin Trudeau, P.C., M.P.
Prime Minister of Canada
80 Wellington Street
Ottawa, Ontario K1A 0A3
Canada

Subject:

Notice of intent to impose countermeasures action against the United States in
response to tariffs on Canadian steel and aluminum products

Dear Prime Minister Trudeau:
The National Marine Manufacturers Association (NMMA) Canada, the national association representing
the recreational boating industry in Canada, represents the producers of more than 80 percent of boats,
engines, trailers, accessories and gear used by North American boaters. The regional marine trade
associations represent dealers and marinas in each province and together our industry generates $10
billion in revenues with a GDP of $5.6 billion and employs 75,000 Canadians. There are nearly 5000
marine related businesses across Canada, many of them small and family-owned, with $2.9 billion in
wages and remitting $868 million in taxes.
NMMA is extremely concerned by some of the Government of Canada’s proposed countermeasures in
response to the United States’ (U.S.) imposition of tariffs on imports of certain steel and aluminum
products from Canada. While the industry understands the government’s need to respond to these unfair
tariffs being imposed by the U.S., a number of the proposed countermeasures regarding recreational
boats, if implemented, will have a significant negative impact on our industry. Tariffs pertaining to the
following goods are of particular concern to NMMA Canada:
1.
2.
3.
4.

8901.10
8903.91
8903.92
8903.99.90

Inflatable boats
Sailboats, with or without auxiliary motor
Motorboats, other than outboard motorboats
Outboard motorboats, other vessels for pleasure or sports

These proposed countermeasures will severely impact the flow of manufactured boats across our border
and will result in prohibitive price increases to Canadian consumers. In 2017, more than 100,000 new and
pre-owned boats were sold in Canada. Of those, more than 65% were imported from the U.S. While
NMMA would like to see these tariffs benefit Canadian manufacturers, the fact is that there are simply not
enough domestic boat manufacturers to supply the Canadian market, and U.S. imports are critical to
ensure the ongoing competitiveness of the recreational boating sector in Canada. As a result of the
proposed countermeasures on recreational boating goods, a $50,000 pontoon boat purchased after July
1 will now cost a minimum of $65,000.
Indeed, the greatest impact of maintaining the four proposed tariffs on recreational boats will be mostly
felt by middle-class Canadians. Of the more than 43% of Canadian adults who enjoy boating each year,
nearly 60% of them have an average household income of under $100,000. In addition, boaters in
Canada spend about $7.35 billion each year when they are on boating trips. These tariffs would have a
significant impact on middle-class communities across Canada as prices of boats are expected to
increase by more than 25%, affecting middle-class employees who depend on the industry for jobs.
Moreover, when reviewing the list of proposed Canadian countermeasures closely, boats appear to be
the only recreational product listed. Our members view this as an unfair and unjustified hit on the
recreational boating sector, which unnecessarily targets our industry.
14 McEwan Drive West, Unit 8, Bolton, ON L7E 1H1
Tel: 905.951.4048   Website: www.nmma.ca

 Outlined below are the industry’s specific requests of the Government of Canada:
1. Remove 8901.10, 8903.91, 8903.92, 8903.99.90 from the proposed scope of countermeasures to
align with other recreational products;
2. Countless boats will have already been purchased or ordered but will cross the border after the
July 1 deadline. Should these tariffs be imposed, the Canadian dealer will be responsible for the
tariff and unable to pass through the cost. We ask that should the four tariffs remain, a grace
period of six months be implemented to allow Canadian dealers to adapt to the new pricing
scheme; and,
3. Should the tariffs proceed, and subsequently be removed in a few months, we request the tariff
be paid back so as to not unfairly burden the Canadian importer/dealer who will not have been
able to pass the cost through.
As a result of the recent actions from the U.S. and counter tariffs, Canadian dealers are already
cancelling orders and bracing for a sales downturn. Lead times for ordering are generally three to six
months out and some dealers cannot cancel as they have a contractual obligation for orders already
placed. This comes at a particularly bad time for recreational boating, as the industry gears up for the
summer boating season.
The recreational boating industry understands the complicated situation the Government of Canada finds
itself in. However, we must emphasize that the proposed Canadian countermeasures will have severe
negative and long-term impact to the jobs, taxes and tourism that recreational boating represents – and
generates – across Canada. We urge the government to find a swift solution to the trade situation with the
U.S. and consider the critical impact on the marine industry from these actions. This tariff will cause
irreparable and disastrous damage to the industry, from which it would likely never recover.
If you have any questions, please do not hesitate to contact Sara Anghel at sanghel@nmma.org or at
905-951-4048.
Yours truly,

Sara Anghel, President
NMMA Canada

Rick Layzell, CEO
Boating Ontario

Lisa Geddes, Executive Director
Boating BC

Patricia Nelder, Executive Director
Atlantic Marine Trades Association
CC:

Alain Roy, Executive Director
Association Maritime du Quebec

Jim Flood, Treasurer
Mid Canada Marine Dealers Association

Hon. Chrystia Freeland, Minister of Foreign Affairs
Hon. Marc Garneau, Minister of Transport
Hon. Bill Morneau, Minister of Finance
Hon. François-Philippe Champagne, Minister of International Trade
Hon. Andrew Leslie, Parliamentary Secretary to the Minister of Foreign Affairs (Canada-U.S.
Relations
Hon. Wayne Easter, Vice Chair, Canada-United States Inter-Parliamentary Group
Hon. Judy Sgro, Chair, Standing Committee on Transportation, Infrastructure and Communities
Hon. Robert Nault, Chair, Standing Committee on Foreign Affairs and International Development
Mr. Brian Clow, Director, U.S. Canada Relations, Prime Minister’s Office
Hon. Michael L. MacDonald, Senator & Vice Chair, Canada- United States, Inter-Parliamentary
Group