Fees for Dangerous Goods Container Registrations

Summary#

This is a proposed ministerial order called the Order Fixing Fees for Registrations Related to Dangerous Goods Means of Containment published in the Canada Gazette, Part I on March 25, 2023. It would make operators, design engineers and some service providers pay fees when they apply for or renew certificates to design, make, repair or requalify containers used for transporting dangerous goods. Comments on the proposal are open for 60 days from publication.

What it does#

• Introduces fees for two application types: initial registration and renewal of a certificate of registration. Fees apply to anyone who must be registered to design, manufacture, requalify or repair means of containment (MOC), and to some third‑party service providers (inspectors, trainers, design reviewers).
• Sets final fee amounts at:
  • Operator of a container facility or service provider: $1,700 (per registration/renewal).
  • Design engineer: $808 (per registration/renewal).
• Phases in the fees over five years with these example steps:
  • Up to March 31, 2025: 60% of the full fee (e.g., $1,020 for container facilities).
  • April 1, 2025 – March 31, 2026: 70% (e.g., $1,190).
  • April 1, 2026 – March 31, 2027: 80% (e.g., $1,360).
  • April 1, 2027 – March 31, 2028: 90% (e.g., $1,530).
  • From April 1, 2028 onward: 100% (full fees).
• Continues to recover travel, lodging and meal costs when Transport Canada staff inspect foreign facilities.
• Requires payment at the time of application; fees are non‑refundable (but Transport Canada has a remission policy that can return part of the fee if service timelines are missed).
• Introduces an online application/payment system and a service standard: applications should be handled (or an inspection requested) within 45 business days of being considered complete.
• The order would come into force on the 180th day after publication in the Canada Gazette, Part II.

Who's affected#

• Operators of container facilities that design, manufacture, repair or requalify MOCs.
• Design engineers who create standardized container designs.
• Service providers who inspect MOCs, validate designs, or provide training.
• Numbers to note from Transport Canada’s analysis:
  • About 1,670 active domestic certificates and 215 held by foreign entities today.
  • An estimated 80% of affected domestic entities are small businesses (about 1,336 small businesses, by Transport Canada’s count).
  • Total cost to registrants estimated at $3.01 million over 2024–2033 (present value). Domestic users would pay about $2.66 million and foreign users about $0.35 million. Small businesses would bear roughly $2.13 million of the total.

Why it matters#

• The order shifts part of the program cost from general taxpayers to the companies that directly benefit from being registered — Transport Canada expects to recover about 17% of the program’s current costs through these fees.
• Real impacts could include higher operating costs for small MOC providers. Some small or rural providers told Transport Canada they might stop offering MOC services if fees make their work uneconomic. That could reduce local availability of inspections, requalification, or certain containers.
• Transport Canada says the fee revenue will fund a modern online system, clearer timelines, and better service tracking. That could make application processing more predictable for industry.
• This is a proposal, not final law. The public comment period is 60 days from the notice in the Canada Gazette, Part I, and the order would take effect 180 days after it appears in the Canada Gazette, Part II.