The Canadian government is considering the implementation of a new order to establish fees for the registration and renewal of certifications associated with the Transportation of Dangerous Goods (TDG) Means of Containment (MOC). Presently, Transport Canada (TC) operates the MOC Facilities Registration Program without charging any fees, which places a financial burden on government resources and costs taxpayers approximately $4.8 million annually. The proposed fee structure seeks to offset these costs by requiring those who directly benefit from the service to contribute.

The new ministerial fees order will introduce charges for key activities within the MOC program, such as:

• • • Initial Registrations: New applicants seeking registration with TC will be required to pay a fee.
    • Certificate Renewals: Existing registrants will need to pay to renew their certifications, which are valid for a five-year period.

The fees will apply to:

• • • Operators of container facilities involved in the design, manufacture, requalification, or repair of MOCs.
    • Design engineers who create standardized MOCs.
    • Service providers who review MOC designs, inspect MOCs, or offer training.

The introduction of these fees aims to ensure that those benefiting from TC’s MOC services contribute to the associated costs rather than relying on taxpayer funding. This initiative aligns with Section 29 of the Transportation of Dangerous Goods Act, 1992 (TDGA), which empowers the Minister to set fees for government services. 

The estimated total cost of the proposed fees to stakeholders from 2024 to 2033 is approximately $3.01 million, with small businesses anticipated to bear around $2.13 million of this amount. The fees will be gradually phased in over a five-year period to facilitate a smoother transition for businesses:

• • • Year 1: 60% of the full fee
    • Year 2: 70%
    • Year 3: 80%
    • Year 4: 90%
    • Year 5 and beyond: 100% of the full fee

The proposed ministerial fees order is intended to establish a cost-recovery framework for the MOC Facilities Registration Program. This adjustment is expected to better align financial responsibilities, alleviate the burden on government resources, and enhance TC’s ability to manage future demands effectively.

Source: Canada (Proposed Regulation), March 25, 2023