Canadian Printing Industries Association (CPIA)

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Canadian Printing Industries Association (CPIA)



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Submission from Canadian Printing Industries Association (CPIA) received on September 19, 2001 via e-mail

Subject: Submission

PDF Version of the letter
PDF Version of the submission

September 19, 2001

Comments - Government of Canada Copyright Reform
c/o Intellectual Property Policy Directorate
Industry Canada
235 Queen Street, 5th Floor West
Ottawa, Ontario
K1A 0H5

Dear Sir/Madam:

Please find attached a submission respecting the Copyright Reform Process initiated jointly by the Departments of Industry Canada and of Canadian Heritage.

This brief is submitted by the Canadian Printing Industries Association and covers our concerns with the state of Copyright Law in Canada.

Yet again, we are extremely disappointed to note that the priorities outlined in the government's consultation paper do not take into account some very long-standing issues of concern which have yet to be properly addressed in the reform process.

These concerns have been submitted to the government time and time again, most recently during the consultation process which led to Bill C-32. We respectfully submit them again for the government's consideration and would be pleased to discuss them in person before a House Committee. We would like to remind you of the fact that copyright laws were originally enacted as a result of the existence of printing. Our industry needs to operate within the framework of statutes that are in step with the technological realities of today.

We look forward to being afforded an opportunity to present our views.


Pierre Boucher

(Logo Removed)








Submission to the


Intellectual Property Policy Directorate

Industry Canada




On the subject of Copyright

Reform Process




September 2001






The Canadian Printing Industries Association (CPIA) welcomes this opportunity to present its views as a part of the copyright reform process undertaken in June by the Departments of Industry Canada and of Canadian Heritage.

This paper summarizes the concerns of Canada’s printing industry relating to copyright law in the country and reiterates the position our industry has made during the various phases of copyright review and reform by the government.

Over the years, CPIA has outlined its copyright concerns to numerous Parliamentarians and senior officials, including the Hon. Sheila Copps, Minister of Canadian Heritage and the Hon. Clifford Lincoln, Chairman of the House of Commons Standing Committee on Canadian Heritage. CPIA actively participated in the consultation process leading to Bill C-32, An Act to Amend the Copyright Act

We support the government's view that proposed legislative amendments need to be dealt with in a gradually staged manner. We agree that more frequent revisions involving more manageable packages of issues and more narrowly focussed bills will make the review process more thorough and more efficient.

CPIA commends the Government for initiating a review process for the purpose of ensuring that Canada's copyright regime remains among the most modern and progressive in the world. We understand the need for the government to move rapidly with such issues as digital printing and Internet retransmission of broadcast programs. However, we believe that longstanding issues which have yet to be addressed in a satisfactory manner need to be dealt with without further delays. To that end, we are extremely disappointed to note that such important issues as innocent copyright infringement in print matters and works created in the course of employment are not listed as outstanding matters to be dealt with during future phases of copyright revisions. CPIA has been asking that these issues be addressed for over ten years and we have yet to receive a commitment on the part of the government that this will indeed be the case. Let us not lose sight of the fac t that the very existence of copyright legislation originated with the invention of printing.


Given the fact that the revisions of the Act will be guided by a number of principles and that two of them specifically address our issues of concern, we hope that this reform will once and for all serve to introduce legislative amendments which are much needed in our industry. These two principles are to ensure that the Act:

  • maintain a responsiveness to technological innovation and new business model;
  • clarify the law where it will reduce the risk of unnecessary litigation.

Canada’s printing industry


Not a single day goes by without every Canadian coming into contact with printed matter. Since 1751, when the first printing company opened for business in Canada, our industry has been the primary means for Canadians to share and disseminate information. Over the centuries, the commercial printing industry has fuelled the development of our society, our way of life and our economy. When all sectors of our society need to communicate - from the smallest business to the largest multinational, from community groups to the federal government - they turn to the printing and imaging industry.

Because print is everywhere, every community has a printer and virtually every Canadian can name a friend or relative employed by our industry.


Industry highlights



  • Canada’s printing industries are primarily Canadian-owned.
  • More than 76,000 Canadians work in Canada’s printing industries.
  • Over $10 billion worth of shipments will be produced by the industry this year.
  • With a gross output multiplier of 1.9, an additional $9 billion will be generated in other sectors of the economy
  • Canada’s printing industry represents close to 10 per cent of all manufacturing establishments in Canada. In terms of number of establishments, it is the largest manufacturing industry in the nation.
  • Canadian firms exported $1.1 billion of commercial printed and related matter to the U.S. in the year 2000.
  • Canada’s printing industries use some of the most advanced technologies, from electronic image scanners and computer-driven manufacturing equipment to satellite transmission and digital image creation.









Size & structure

Small firms dominate Canada’s commercial printing industry with 75 per cent of companies in the industry employing fewer than 20 employees. Less than three per cent employ more than 100 employees. The average sales for the industry, by company size, is as follows:


Size of Firm


Avg. Sales Volume






$4-6 million



$ 10 million


100 +

$110 million


The industry can be best characterized as being made up of entrepreneurs, most of whom actually worked in trade occupations within the industry before venturing out on their own.

Given its size and structure, Canada’s printing industry is sensitive to a wide range of government policies that have a direct bearing not only on the profitability of the industry, but its ability to maintain and create employment for thousands of Canadians.





Copyright is a legal system of rights that evolved following the invention of the Gutenburg printing press. Although new media have since emerged, printing remains the most widely-used method by which copyrighted works are disseminated. Printing has been and continues to be the single most important facilitator to the development of cultural industries in Canada. Posters, billboards, performance programs and tickets, sheet music, limited edition prints, software manuals and packaging, album covers, books, magazines, newspapers and the TV Guide are made possible because of printing.

The use of computed-related equipment in the printing industry has expanded significantly in recent years. The explosion of digital technology, desktop publishing and alternative media has forced firms of all sizes to constantly upgrade their equipment just to maintain market share.

With the advent of modern technology, however, the printing process has been completely transformed. Printers used to manually set type, and effectively read every word as they were typesetting. It was obviously easier, at that time, to detect copyrighted materials in books, for example.

The advent of personal computers and desktop publishing systems has rendered typesetting virtually obsolete and now most printers receive files electronically, and as such they no longer have involvement or control over content of information that is brought to them.

Printers now mainly focus on layout, scanning and colour correction before a job is put on the printing press. To meet customer deadlines, printing work is turned around so quickly that there is virtually no time to examine the content. By way of illustration, it took Gutenburg five years to typeset the Bible. Today, computer technology permits the same task to be completed in less than 15 minutes! Demanding customers expect no less.

Since technological innovation has helped bring down the cost of printing, this method of communication is also more widely available today then when original copyright laws were conceived. Printers have witnessed an increase in volume, meaning there are more jobs being printed than ever before. The printing industry in Canada now produces literally millions of customized jobs for clients, representing almost half a trillion impressions per year.

Although the printing industry has traditionally assisted in the safeguarding against copyright infringement, today’s reality dictates that it is not physically or economically possible for printers to verify whether every piece of information they receive is being used with permission. To do this would require that every printing firm in the country hire editors and have a copyright lawyer on staff - around the clock, which is obviously prohibitive.


Innocent Copyright Infringement on Print Matters

Canada’s Copyright Act must recognize the unique nature of the printing process and protect printers who are exposed to prosecution through no fault of their own.

The Canadian Printing Industries Association firmly believes that the responsibility for copyright infringement should rest with the client having the work manufactured or reproduced and not with the printer.

This would require a clarification of the innocent infringement clause in the Copyright Act, which is currently too vague and open to wide interpretation.

The Act should also recognize the reality of our digital society and place the responsibility for data input onto a computer with the client having this work manufactured or reproduced.

Hence, CPIA recommends that a special section be added to Section 38.1 (6) of the Act dealing with exceptions:


Section 38.1 (6) No award: No statutory damages may be awarded against...

"(d) a printing company which, in the course of providing services to a client, unknowingly inputs into a computer or reproduces, by any technological means, a work or other subject matter that is an infringement of copyright."


CPIA asserts that this clause will maintain copyright protection for owners while protecting the unique nature of our industry. It is also written in such a fashion as to take into account future technological innovations in the industry.





Work made in the course of employment

In all of its copyright submissions, the Canadian Printing Industries Association has stressed the integral nature of photography within the manufacturing printing process. As such, we have long asserted that copyright for such photographs should rest with the employer, not with the employee.

However, in order for the concerns of the industry to be satisfied, it remains important to clarify the definition of "employment" and to specify that the owner of copyright can be a body corporate.

CPIA, therefore recommends that the Copyright Act include the following additional words (underlined) in the definition of what constitutes work made in the course of employment.


Section 13. (2) Work made in the course of employment:

"Where the author of a work was in the employment of some other person or body corporate under a contract of service, apprenticeship, commission agreement, other forms of compensation, and the work was made in the course of his employment by that person or body corporate, the person or body corporate by whom the author was employed shall, in the absence of any agreement to the contrary, be the first owner of the copyright.(...)"


The Canadian Printing Industries Association respectfully submits that its proposed Copyright Act amendments, particularly relating to innocent infringement, not only stand the test of time but the test of reason. We believe that these amendments can easily be included in the current reform of the copyright legislation without compromising the integrity of the Act or the digital implications of new media.




About CPIA

The Canadian Printing Industries Association is a national association dedicated to the advancement of the printing and imaging industries in Canada.

Members of the Association are progressive, innovative firms engaged in the selling of services and products to print buyers throughout Canada, the United States and the world.

Member companies are involved in all aspects of the industry from pre-press activities to manufacturing of the printed product through binding and finishing. Suppliers to the industry also belong to the Association as associate members.

CPIA members range in size from small family-owned businesses to large multi-plant Canadian and international companies.

Since 1939, the Association has served as the collective body to represent the interests of its member firms for policy formation, regulation and legislation.

The Association is a member driven organization, utilizing the talents of dozens of volunteer members who serve on its various committees, including the national Government Affairs Committee. These individuals bring a wealth of knowledge and skills to CPIA and are able to research and solicit expert opinions from across the business spectrum.

Our association looks forward to actively participating in the dialogue leading to the current reform of the Copyright Act and urges the government to prioritize the issues addressed in this submissions as they have been on the table for too many years.

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