The Trans Pacific Partnership TPP, TPP11, CPTPP and the Case for Further Negotiations

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1 The Trans Pacific Partnership TPP, TPP11, CPTPP and the Case for Further Negotiations The Canadian automotive supply sector can be segmented into several categories: large Canadian Tier 1s, Canadian subsidiaries of large international Tier 1s, medium-sized Canadian suppliers with multiple footprints and small Canadian suppliers with single footprints. Since 2015, the APMA position on the original TPP has been that the large Canadian Tier1s would be unaffected in a material sense by the reduction of tariffs, and that they may benefit from potential access to new markets. However the small and medium sized firms, which represented more than half of the 96,000 jobs in our industry, need to be protected from a proposed dramatic shift in sourcing dynamics to Low-cost Asian countries like China and Thailand. After the late 2015 automotive-specific negotiations in San Francisco and Atlanta - and before we saw the final November 2015 TPP text - we remained concerned with the stance our trading partners had taken with regards to Regional Value Content and we expressed this directly to the then-prime Minister Stephen Harper, his Trade Minister Ed Fast and the Canadian negotiating team. We were resolved to constructively support the Canadian effort in finding a balanced outcome that contributes to continued Canadian prosperity within a new Trans Pacific Partnership Agreement then and we continue to now with the new government. The final 2015 text of the TPP, and presumably the basis of TPP11/CPTPP, represented in many practical ways the materials sourcing and multi-tiered supply chain realities of the Japan-based vehicle assembly and did not reflect the dynamics of Canada s industry at that time. Japan s consumer market in 2016 was 4.9M vehicles and is production was 8.8M; they need competitive export markets access and the TPP provides them a lower cost access point to the North American Market. The Canadian-based assembly sector built 2.3M vehicles in 2016 and their sourcing is primarily localized to North America. Canadians purchased almost 2.0M vehicles in 2016 and their production/purchase ratio provides less urgency than Japan s in the search for new markets. Furthermore, more than 1.8M vehicles produced in Canada in 2016 went to the US, further underscoring our interest in ensuring that we do not concede access to our most important market to better capitalized, lower-cost competitors for little in return. Rules of Origin Lowering the Price of Entry The main concern of the Canadian auto parts sector in the TPP is the reduction in the Regional Value Content levels in the Net Cost method of compliance for vehicles (45%) and parts (35%+). In addition to materially lowering the threshold for North American market access from a NAFTA-level 62.5/60%, the TPP offered up methodology changes in calculating those figures that further reduce the effective threshold for tariff free access:

2 a) a new flexibility concept to allow for up to a 10% gross up in Net Cost compliance in the achieving of those RVC targets in 14 critical product categories if assembly requires specialised skills and the use of machines, apparatus or tools that are especially produced or installed to carry out that operation b) introducing 7 product categories that count as automatically originating, thereby allowing for a potential gross up of actually non-tpp Region parts to inflate the RVC calculation Source: The Figure below illustrates the exposure on specific parts categories that the Canadian parts assembly sector faces under TPP. Each of these figures can be compared to the 60% threshold currently in NAFTA and many are subject to a further 5-10% effective reduction in the TPP flexibility provision for complex assembly. Simply put, the TPP allows for a significant majority of a part to be assembled in a country outside the TPP advantage China without including them in the reciprocating agreement on terms. Furthermore, access to the low-cost supply chains of Asia on a volume basis is structurally out of reach for Canadian manufacturers and the advantage will fall solely to Asian-based assemblers of the TPP region. Figure 1 Trans Pacific Partnership RVC Levels by Harmonization Code HS Description # firms RVC by Net Cost Engines <50cc NA Engines cc NA Engines cc NA Engines >1000cc Engines diesel NA Engines parts Engines parts (others) NA Chassis Bodies (for vehicles of 87.03) NA Bodies (for other vehicles) Bumpers Seat belts Other parts and accessories of bodies Brakes Transmissions Axles Wheels 7 35

3 Suspensions systems Radiators Mufflers and exhausts Clutches NA Steering wheels/columns Airbags Other parts and accessories Legend Negligible Less than 10 firms firms 20+ firms Note: Companies may make parts in more than one category Non-Tariff Barriers The Export Wall The other side of the negative effects of the ROO/RVC concessions in TPP is the notion that Canadian-based vehicle assembly would however have access to the lucrative consumer markets in Japan, therefore extending the opportunity for volume grow for Canadian-based parts assembly in turn. This concept has had great carriage in the public discourse on TPP but it ignores the real issue of effective Non-tariff barriers in Japan. These must be addressed if there is to be any hope of unlocking real vehicle export potential there. Despite its size and its considerable global exposure, the Japanese market continues to the most difficult market to penetrate for foreign automakers. The figure below (Source: IHS) demonstrates a dramatic distinction between Canada s and Japan s consumer market s relationship with imports. Figure 2

4 To illustrate what stands in the way of Canadian sales into Japan, which in 2016 totalled 275 vehicles (vs. 152,460 from Japan into Canada) the following Figure is a comparative model analysis of a hypothetical offering of a Canadian-built car and SUV with a locally produced vehicle available in the Japanese Domestic Market. Our focus will be the Canadian D3 offerings because: a) Toyota and Honda-built Canadian products could theoretically be competitive but Canadian product would not be re-oriented to compete with their home market operations for market share. b) Independent Canadian-based parts suppliers are disproportionately exposed to D3 assembly in North America. In addition, the following is important to contextualize: (1) None of the Canadian operations of any of the 5 OEMs operating here is tasked with making product planning decisions for foreign markets and (2) Japanese consumers preference/culture is for smaller vehicles that the D3 currently do not assemble in Canada Figure 3: The Cost of NTB s A Comparison of Large Volume Sedans For this comparison, we look at a Brampton-built FCA LX car (Dodge Charger, Chrysler 300) and an Oppama-built Nissan Maxima (known as Teana in Japan). We are assuming the base MSRP would be similar - a hypothetical example because FCA does not have a comparable distribution network in Japan to deliver volume sales. For the purpose of this comparison, we assume that the volume export logistic cost from Brampton is $1,000 CAD, and that this cost would be passed on to the consumer (or absorbed by FCA). There is no corresponding logistic cost to the locally-built Maxima. A. Ownership Taxes Japan charges private vehicle owners 3 annual taxes for vehicle use, paid at registration time. Automobile Tax (dimensions), Automobile Weight Tax and Road Tax. All are charged on an increasing sliding rate - the first two by vehicle size/weight, the third by engine displacement. A Canadian built FCA LX car (Dodge Charger, Chrysler 300) with a base 3.6L V6 would annually cost a Japanese customer the following: (1) 19,000 AT (2) 20,000 AWT (3) 66,500 RT (The optional 5.7L V8 would increase the RT to 88,000) 105,500 Total ( 127,000 with V8)

5 A Japanese Domestic Market Nissan Maxima with the base 2.0L I4 engine would annually cost a Japanese customer the following: (1) 19,000 AT (2) 15,000 AWT (3) 45,000 RT (The optional 2.5L V6 would increase the RT to 51,000) 79,000 Total ( 85,000 with optional V6) For this product comparison, the annual ownership tax difference would be 27,500-42,000. For 5 years that incremental ownership tax number is 135, ,000 or $1,500-$2,330 CAD. B. Fuel Taxes Fuel costs $0.40/litre higher in Japan due in part to prices that comprise 52% in taxes vs 29% in Canada (Source: OECD). This adds a disproportional cost for the less fuel efficient LX vs Maxima. Using the USA EPA duty-cycle testing protocol (and adjusting for mile to kilometre conversion) with a 24,000km annual average usage basis, with a 45%/55% city/highway split and a $1.60/litre price of fuel in Japan, the 2 vehicles would use the following amount of fuel annually (with Incremental Japanese gas tax impact in parenthesis): (1) Maxima 2.0 I4: 7.4L/100 KM, $3,000 ($690 in incremental tax) (2) Maxima 2.5 V6: 9.5L/100 KM, $3,850 ($885 in incremental tax) (3) FCA LX V6: 10.2L/100 KM, $4,300 ($989 in incremental tax) (4) FCA LX V8: 12.4L/100 KM, $5,200 ($1,196 in incremental tax) The comparable difference in fuel taxes between the 2 cars model ranges in $299-$311 annually. For 5 years of ownership that number is $1,495-$1,555 in incremental Gas Taxes paid in Japan over Canada on the same cars. Japanese consumer and gas taxes put the Canadian-built car at a 5-year $3,950-$4,885 Cost of Ownership disadvantage. Logistics of sending a vehicle across the Pacific, at a volume discount, adds another $1,000 to the initial cost of ownership. Note: This analysis does not take into account that the distribution network for this or any Canadianbuilt D3 vehicle does not currently exist. Conclusion Pursuing more access to the Japanese market would be a good academic objective and we understand that the RVC negotiation in TPP needs to be competitive than NAFTA for Japan as well. But the barriers to access to that market are much more complex and Canada must take a critical look at how these impact the potential for growth for local producers. With the return to TPP11 discussions, Canada has an opportunity to negotiate better terms, it is important that we negotiate equitable market access for finished goods in addition to reworking the ROO. If we are successful, we may also make it more attractive for a currently protectionist USA to

6 consider joining on a better final reading. There is no benefit in haste for Canadian-based assembly and parts production, and Canada will do well to approach this constructively at productive pace. Flavio Volpe December 18, 2017

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