Soumission de : Executive Director, Periodical Marketers of Canada
1. Part VII of the discussion paper presents the following options regarding the Revised Foreign Investment Policy in Book Publishing and Distribution. Which options, in your view, would be the most beneficial? Please explain your choice.
Maintain the book policy in its current form.
Canadian book readers and authors are well served by the book publishing industry and its ancillary components of distribution and retailing. The publication annually of some 10,000 new Canadian-authored titles demonstrates the accessibility of publishers to Canadian authors. Book buyers enjoy the availability of a broad spectrum of titles from traditional book retailers, supplemented by speciality and non-traditional outlets, and online sources. The distribution sector functions as a cost-efficient and effective means of providing product, subject to the constraints of retail choice as determined by consumer demand. While each sector faces unique challenges, we perceive no obstacles to market success as a consequence of existing Government of Canada book policy.
2. Are Canadian-owned businesses more inclined to support the creation, distribution, and/or sale of books by Canadian authors? Why or why not?
While Canadian business decision-makers must be guided by issues of market consideration, we believe Canadian-owned businesses make strenuous efforts to place material of Canadian origins before their customers.
3. Does the presence of foreign companies in the book industry currently benefit Canadians and the Canadian book industry? Please explain your view.
The expertise and financial capability of foreign-owned publishers operatingin Canada provide significant added value to the Canadian publishing industry at their present level.
4. What would be the impact, either positive or negative, for Canadians, authors, and the book industry, of opening the market to foreign firms not already operating in Canada? Please explain in the context of:
a) Book publishing:
As our field of expertise is distribution and not publishing, we wish to defer to our publishing peers for this part of the question.
b) Book distribution:
As noted in the Department of Canada Heritage summary of The Revised Foreign Investment Policy, book distribution is a labor-intensive, low profit business requiring costly infrastructure in logistics and technology. The entry of new foreign-owned players would be destructive to the viability of existing Canadian operators. Such players would be likely to rely on existing U.S.-based infrastructure and would add little or no Canadian operational capability. Over time, such entrants would erode the Canadian market to the point where Canadian companies would be no longer operationally viable. The likely consequence would be a reduction in the availability of Canadian product to Canadian consumers.
c) Book retail:
As in Section a, we defer to the retail community for expert response to this question.
5. Are there particular types of businesses within the publishing, distribution or retail sectors of the book industry (e.g. educational publishing or online retail) that require distinct treatment under the policy?
As distribution represents the essential link between producer and consumer, we believe the sector warrants consideration equivalent to the importance of its role. Without a viable distribution sector, there can be no equality of opportunity for either creators or retailers.
6. Foreign investment policies exist for the periodical publishing and film distribution industries, as well as for the book industry. Do these existing policies suggest models that could be beneficial to Canadians and to the book industry?
Members of PMC support the maintenance of existing foreign investment policies covering periodical publishing. The Canadian periodical industry is performing relatively better than its American counterpart. Newsstand sales are currently more stable in Canada than in the U.S. We credit this to the high level of editorial excellence of Canadian magazines and the demonstrated interest among Canadian for information about Canadian topics and people.
The membership of PMC consists of:
The Monahan Agency, Vernon, BC
NewsWest Inc., Calgaery, AB
Centrral News, Thunder Bay, ON
Sudbury News, Sudbury, ON
Metro News Ltd., Toronto, ON
The News Group, Burlington, ON
Benjamin News, Bois-des-Filion, QC
7. Are there any new or emerging issues in the book industry, including those mentioned in the discussion paper, that are not sufficiently addressed by the current policy? If so, how should a modernized policy respond to these?
Issues currently impacting the book industry are centered largely within the retail sector, although the effects are felt both by publishers and distributors. Emerging issues include:
1. Migration of book store sales online, via electronic editions and print copies,
2. Future viability of the returnable sales model
3. Increasing consumer preference for visual modes of communication, resulting in less time being spent reading printed products.
These issues are rooted in technological and social changes. We believe they are generally beyond the reach of government policy, assuming an absence of new policies that could be counterproductive to the ability of the industry as presently constituted to serve creators and consumers.8. The existing policy specifies the kinds of net benefit undertakings that may be sought from foreign investors in cases of indirect acquisitions, such as commitments to promote Canadian authors; to support the infrastructure of the book distribution system; to improve access to the company's Canadian marketing and distribution infrastructure; and to engage in education and research. Are there ways in which these undertakings should be modernized to better reflect the current book industry environment?
PMC strongly supports the full and complete prohibition of foreign acquisitions of Canadian cultural properties and the denial of entry to new foreign competitors.
9. What types of commitments, including those mentioned in the discussion paper, do you think have been/would be the most beneficial to Canada and the Canadian book industry?
See our response to Question 8.
What are the impacts of investor commitments related to the marketing of Canadian books, retention of Canadian staff, and sponsorship of industry initiatives and events?
We are aware of no positive impacts.
Is it beneficial to the Canadian book industry and to Canadians to require that investors commit either to expanding or restricting the scope of their businesses? If so, under what circumstances?
We are skeptical that such committments, which may be entered into in good faith, would prove economically viable for foreign investors and therefore might lead to their abandonment, as has happened in the manufacturing and mining industries.
10. Are there any ways in which foreign investment in the book industry, or changes to the foreign investment policy, might have a particular impact on publishers, distributors, or retailers who either work with official language communities in minority situations or are members of these communities? Please explain.
MC is very concerned with the assertion in the Discussion Paper that "There is currently no national book distributor or book wholesaler serving the Canadian market." In fact, a number of national wholesalers, both within and without the PMC membership, deliver such service. Several PMC members participate in the national book wholesale business of Canadian Mass Media Inc. (CMMI), a wholesaler-owned corporation. The News Group, a member of PMC, operates nationally.Collectively, retail book sales in excess of $200 million annually are realized by PMC members. In Quebec, the 20 members of l'association des distributeurs exclusifs de livres en lange francaise (ADELF) provide a similar "national" wholesale service. We are equally concerned with the assertion that "The policy around foreign investment may be acting as an impediment to attracting such a player to the Canadian market." Any adjustments to policy to encourage entry of a new foreign player would be based on a false premise and would be unwarranted and ill-advised. See also our response to Question 4(b).
Several PMC members participate in the national book wholesale business of Canadian Mass Media Inc. (CMMI), a wholesaler-owned corporation. The News Group, a member of PMC, operates nationally.Collectively, retail book sales in excess of $200 million annually are realized by PMC members.
In Quebec, the 20 members of l'association des distributeurs exclusifs de livres en lange francaise (ADELF) provide a similar "national" wholesale service.
We are equally concerned with the assertion that "The policy around foreign investment may be acting as an impediment to attracting such a player to the Canadian market."
Any adjustments to policy to encourage entry of a new foreign player would be based on a false premise and would be unwarranted and ill-advised.
See also our response to Question 4(b).
We recognize the contribution that companies of non-Canadian ownership have made to the book industry in Canada. We strongly support their continued presence as beneficial to creators, distributors, retailers and the reading public. Canadians insist on access to the wisdom and knowledge of writers around the world, and these companies provide an important pipeline for such information. By publishing the works of Canadian writers, they further strengthen Canadians' awareness of our heritage and identity, as well as providing potential foreign markets for our creators. As these desirable objectives have been attained within the framework of the existing foreign investment policy, and have been achieved through a careful balance between Canadian and non-Canadian ownership, we recommend the continuation of present policy.