OLD VERSION of the Canadian copyright levy on blank audio recording media
- or -
The "Blank CD-R Tax" FAQ

The current FAQ appears at http://neil.eton.ca/copylevy.shtml

***** Dead URLs on this page are deactivated *****

Completely revised on
Sunday, December 17, 2000

to see the year 2000 (out-of-date) FAQ page go here

to see the 1999 (out-of-date) FAQ page go here

to see the 1998 original (out-of-date) FAQ page go here

The new levy on CD-Rs is 21¢ each. It starts January 1, 2001.

Contents:


I have heard rumours that the Canadian Government is taxing blank CD-RS - is this true? (modified 2000-12-17)

No, there is no tax, but yes, there is a levy (see the difference below).

In mid 1998, a series of wild rumours began circulating about the proposed levy to be placed on blank audio recording media. Dozens of people on news://ott.forsale.computing and news://alt.comp.periphs.cdr suggested that starting January 1, 1999, the price of blank CD-RS would increase by $2.50 each. Since such media was selling at that time for as little as $1.70 per disk (retail), a $2.50 increase, if it had taken place, would have more than doubled the cost of CD-Rs. Note that as of 2000-12-17 it is possible to buy CD-RS for as little as $0.50 each (retail).

Prices quoted here are in Canadian dollars and generally exclude any taxes (such as GST, HST, QST, RST).

These rumours, some of which were repeated by otherwise reputable news outlets, resulted in "runs" on any retailer (Costco/Price Club was often cited) with CD-RS at a reasonable price. In some cases it individuals bought entire skid loads (1000s) of CD-RS at one time. The rumours also caused some sellers to attempt to gouge customers based on the supposed shortage. One persistent poster on news://ott.forsale.computing offered CD-RS at $8.00 each, despite the fact that there were lots of CD-RS available (although not necessarily all brands) at an average price of $2.00.

What is a levy? (modified 2000-12-17)

On March 19, 1998, new federal copyright legislation came into force. Among other things, the legislation provides for a levy to be collected on blank audio recording media.

It is called a levy (and not a tax) because it is not collected by any level of government, it is collected by a group representing the recording industry. In a letter to the Copyright Board of Canada released Monday, January 18, 1999, the five collectives that filed tariffs for a proposed levy on blank audio recording media announced the creation of the Canadian Private Copying Collective (CPCC).

The Copyright Board decides on the amount of the levy and what media it applies to. The recording industry submits its proposed levies and the Copyright Board holds hearings to hear any objections to the proposed levy amounts. Note that the Copyright Board CANNOT change the law, they can only determine the levy value. The levy can be changed every 2 years.

The first time the Copyright Board set the levy was December 17, 1999. The law allowed their ruling to be retroactive to January 1, 1999. However, the CPCC letter mentioned above advised the Copyright Board that all members of the CPCC agreed to delay collecting the levy on blank audio recording media until the Board rendered its decision on the proposed levy or until December 31, 1999, whichever was earlier. So the levy started on December 17, 1999.

What other countries collect a levy like this?
Is Canada alone?

At least 25 countries, including most G-7 and European Union members, have introduced comparable regimes with respect to the private copying of sound recordings. Canada is one of the last to do so.

The USA is often held out as an example of a place where "this could never happen", but as far as I can tell, it has been law there since December 8, 1994. It is part of Title 17, section 1004, and if you go to:

you will find this paragraph:

    (b) Digital Audio Recording Media. - The royalty payment due under section1003 for each digital audio recording medium imported into and distributed in the United States, or manufactured and distributed in the United States, shall be 3 percent of the transfer price. Only the first person to manufacture and distribute or import and distribute such medium shall be required to pay the royalty with respect to such medium.

Note, however, that in the US there is NO levy collected on "ordinary" CD-RS When the legislation was last changed (in 1994/1995) CD-RS were not seen as a media intended for copying music. There IS a levy applied to other digital media, such as DAT and CD-R Audio.

In a posting to news://alt.comp.periphs.cdr on Sat, 18 December 1999 19:25:25 +0100, Sybren <S.J.Hettinga@student.tudelft.nl> wrote the following (edited for length):

"We have this kind of thing here in the Netherlands since 1 September '99.
To clear some things up:

  • the levy here is about 8¢ for "computer" CDR's and about 40¢ for "audio" CDR's.
  • this levy makes it *legal* to copy audio CD's for personal use. Commercially selling copied audio CD's is still (obviously) illegal.
  • the money goes to the Buma/Stemra (a sister organisation of the RIAA), and is redistributed to all registered artists according to their respective sales. So yes (for the cynics out there), even the most obscure artist out there really does get his money (as *all* record labels register the albums they release).
  • The 40¢ for "audio" CDR's was derived from the current levies on audio tapes, MiniDisk's and DAT's.
  • The 8¢ for "computer" CDR's was chosen because research showed that 1/5th of all "computer" CDR's ended up being used for the copying of audio CD's."

Can I now legally copy audio CDs for my friends?

The simple answer is NO, but you can legally copy your friend's audio CD for YOUR OWN use.

To paraphrase the introduction to the Copyright Board's ruling:

    On March 19, 1998, Part VIII of the Copyright Act came into force. Until then, copying any sound recording for almost any purpose infringed copyright.

    Part VIII legalizes one such activity: copying of sound recordings of musical works onto recording media for the private use of the person who makes the copy.

It does not matter whether you own the original sound recording (on any medium), you can legally make a copy for your own private use.

To emphasize this point, endnote 4 of the Copyright Board's ruling says:

    Section 80 does not legalize (a) copies made for the use of someone other than the person making the copy; and (b) copies of anything else than sound recordings of musical works. It does legalize making a personal copy of a recording owned by someone else.

Is there a government website that explains all this?

The Copyright Board did not have a website until early December 1999, which is part of the reason for this page. You can find their website at http://www.cb-cda.gc.ca/.

Sometime on or before Wednesday, January 20, 1999, the Department of Canadian Heritage added a page to their website titled:

Cultural Industries - INFORMATION ON THE PRIVATE COPYING PROVISIONS OF THE COPYRIGHT ACT

It answers many common questions such as why there is a levy, who benefits from it, and so on. The also have a link to the CPCC newswire press release .

There is some information about the Copyright Board at this government site.

Why is the Copyright Board so secretive? (modified 2000-12-17)

The Copyright Board has been very cooperative and open throughout this process. However, they do have a very small staff. Of all the players in this drama, they were the last to have a website, but you can find it now at http://www.cb-cda.gc.ca/.

I contacted the Copyright Board by phone in late 1998 and had a very informative conversation with Mr. Mario Bouchard, General Counsel to the Copyright Board. He was kind enough to send me the equivalent of a FAQ via email. I have formatted it in HTML and placed it on this website.

 I contacted Mr. Mario Bouchard again on July 23, 1999 to get an update on the progress of the hearings.

 I contacted Mr. Mario Bouchard again on November 10, 1999 to get an update on the progress of the hearings.

Mr. Mario Bouchard contacted me on December 17, 1999 to inform me about the decision and website.

Mr. Claude Majeau, Secretary to the Board, contacted me on March 20, 2000 to inform me that the Canadian Private Copying Collective had filed a statement of levies it proposes to collect for the years 2001 and 2002. This statement was published in the Canada Gazette on Saturday, March 18, 2000.

Mr. Mario Bouchard contacted me on December 7, 2000 to inform me about the progress of the new hearings.

Mr. Claude Majeau, Secretary to the Board, contacted me on December 16, 2000 to inform me that the Copyright Board had announced (on Friday, December 15, 2000) its decision on the Private Copying tariffs for 2001-2002.

When does this become law?

It has been law since March 19, 1998.

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When did the levy start? When will it change? (modified 2000-12-17)

The levy started December 17, 1999. The levy will change on January 1, 2001. The levy is set for a period of 2 years and the law enabling the levy allowed it to start January 1, 1999. The next possible change would be January 1, 2003.

What is the amount of the levy? (modified 2000-12-17)

The amount depends on the media in question, as shown in the following table. The levy is applied per unit. The length or size of the media does not matter (except for audio cassettes 40 minutes long or less, as shown below).

Medium
NEW
2001-2002

levy per unit
requested
2001-2002

levy per unit
OLD
1999-2000

levy per unit

Audio cassettes over 90 minutes in length

29¢ $1.00 23.3¢
Audio cassettes over 60 minutes in length and up to and including 90 minutes in length 29¢ 75¢ 23.3¢
Audio cassettes from 40 minutes up to and including 60 minutes in length 29¢ 50¢ 23.3¢
Audio cassettes 40 minutes long or less 0 - see note ??? - see note 0 - see note
CD-R Audio, CD-RW Audio and MiniDisc 77¢ $1.75 60.8¢
CD-RS and CD-RWs 21¢ 50¢ 5.2¢
Microcassettes (commonly used in dictating machines) 0 - see note ??? - see note 0 - see note
Digital audio tapes (DATs) 0 - see note ??? - see note 0 - see note

 

Note:

The items marked with "???" were not specifically mentioned in the application for new levies. The items above with no levy are excluded because the Copyright Board says "Audio recording media that are clearly meant for purposes other than private copying are excluded. A case in point are microcassettes commonly used in dictating machines. Digital audio tapes are another, as for all practical purposes, they are used by professionals, not by individual consumers."

The Canadian Private Copying Collective filed a statement of levies it proposed to collect for the years 2001 and 2002. This statement was published in the Canada Gazette on Saturday, March 18, 2000. The full statement of levies is available on the Copyright Board website and is called the Private Copying Tariff, 2001-2002.

Who sets the levy and who can change it? (modified 2000-12-17)

The levy is set by the Copyright Board for a term of 2 years. The first levy period covered 1999 and 2000. The new levy will be in effect for 2001 and 2002. In theory, the levy could change on January 1, 2003, but the "collectives" have to propose new rates and the Board has to hold new hearings.

When were the hearings held? (modified 2000-12-17)

Hearings to consider the levies the Canadian Private Copying Collective proposes to collect for the years 2001 and 2002 concluded on November 28, 2000. The hearings took 7 days. The Copyright Board hopes to issued its ruling December 15, 2000. The detailed reasons for approving the new levies will be published in January 2001.

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Can I object to the proposed levies for 2001-2002? (modified 2000-12-07)

It is now too late to object. You had to file written comments before the date was set for hearing final arguments. Any person who wished to object to the statement had to file written objections with the Board within 60 days of the publication of the notice, that is, no later than May 17, 2000. You HAD TO follow the instructions provided on the Copyright Board website in order to be considered a formal objector.

Note that the ONLY practical thing you can object to is the proposed value of the levy. The Copyright Board is bound by law to set a levy, they CANNOT change the legislation. This means it is pointless to:

  • ask the Board to reject the tariff as a whole
  • ask to have levy compensation paid to owners of computer programs, movies, or literary works - the remuneration applies only to sound recordings of musical works
  • ask to have the levy collected at the retail level (it is remitted by manufacturers or importers of media)
  • ask for exemptions or refunds for media NOT used for reproducing musical works - the law does not consider the actual end use made of the media. (The only exemption allowed for by law is for media that are sold to a society, association or corporation that represents persons with perceptual disabilities.)

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How can I avoid the levy? (modified 2000-12-17)

With CD-R media selling for as little as 50¢ per unit, the new 21¢ levy on CD-RS has the potential to significantly raise the price of this media. The effect of this increase could take as long as a year to be seen because the old levy (5.2¢) applies to any CD-R media that was "purchased" prior to December 31, 2000. Note that a retailer or distributor can "purchase" the media before the change date, specifying that it be delivered after the change date. So, in theory, big retailers could place huge orders to avoid the new, higher levy for a while.

If you buy any blank recording media outside Canada and use it yourself they will not be subject to the levy. Why? Because YOU are the importer and you are not selling blank media. It is the sale of blank media by the importer or manufacturer that triggers the levy.

More importantly, make sure you don't get ripped off by confused or shady retailers collecting "the tax".

By law, no levy is payable on sales to associations representing persons with perceptual disabilities. There are no other exceptions.

There are several groups that will not have to pay the levy by agreement with the CPCC. These include:

  • religious organizations
  • broadcasters
  • law enforcement agencies
  • courts
  • tribunals
  • court reporters
  • provincial ministers of education
  • members of the Association of Universities and Colleges of Canada
  • music and advertising industries

The accurate description is that the levy for them is zero-rated, but enough of that. This is NOT a legal requirement and so depends on the goodwill of the CPCC. Those interested in finding out more about this so-called zero-rating scheme may contact CPCC at telephone (416) 486-6832 or facsimile (416) 485-4373.

How can I avoid getting ripped off?

Remember that the levy is applied ONLY when a manufacturer or importer sells the blank audio recording media.

  • Retail stores do NOT have to "collect the tax" - the levy is built into their wholesale price
  • Canada Customs does NOT have to collect the levy at the border if you import blank audio recording media
  • Canada Post (or any other courier) does NOT have to collect the levy from you if you import blank audio recording media
  • You do NOT have to remit the levy UNLESS you sell blank audio recording media. So if you import CD-RS, write data to them, and ship them to customers, they are NOT subject to the levy.

Some retailers may try to take advantage of the artificial shortage cased by panic buying to raise their prices. None of the price rise will be passed on to the intended beneficiaries of the levy (recording artists, etc.).

Some retailers mistakenly believe that they need to raise their prices to collect the levy. However, the levy is not applied at the retail level, it is applied to importers and manufacturers. None of this "just-in-case" retail price rise will be owed to or passed on to the intended beneficiaries of the levy (recording artists, etc.). The retailers will pocket it all. (Note that a special case exists where the retailer is directly importing the media, because they are both the importer and the retailer.)

What are blank audio CDs or CD-R Audio?

There are special CD-RS called "blank audio CDs" made for use in home recording units that allow the users to copy audio CDs. These are referred to as "CD-R Audio" by the Copyright Board. They attract a levy of 77¢ each.

These CD-RS include a specially embossed section on the disk that is read by "consumer" CD recorders such as the Phillips CDR560S. You cannot use regular CD-RS in these recorders. For more info see:

  • http://www-us.sv.philips.com/sound/cdr/products/range/560s/
  • http://www.proactiveelectronics.com/blank+cd.htm
  • http://www.kodak.com/country/US/en/corp/pressReleases/pr19980916-23.shtml

At the last URL you will find this paragraph:

    Kodak audio discs carry a special ATIP code that identifies the disc as compatible with audio CD recorders. To protect the copyright of professional artists and music publishers, the CD recorders also contain a Serial Copy Management System (SCMS) code that allows users to record only from an original pre-recorded CD, preventing them from making copies of a custom-recorded CD.

Who is Neil Herber?

Neil Herber works for Eton Systems, a technical publishing company that creates, writes, edits, and publishes reference and marketing material for clients in the high-tech, scientific, and engineering communities. More details are available on the Eton Systems corporate website.

Disclaimer:

IMPORTANT NOTE FROM NEIL HERBER: I am not a lawyer, but I have discussed most of the points I make here with a lawyer. You should not rely on any of this material for making business decisions of any type. Consult with your legal advisor. Material from government websites is provided for informational purposes only. The government websites all have their own disclaimers.

 


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