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Thread: Canadian Government and Online Opticals ...........................

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    Redhot Jumper Canadian Government and Online Opticals ...........................

    The Competition Bureau, as an independent law enforcement agency, ensures that Canadian businesses and consumers prosper in a competitive and innovative marketplace. We are a federal institution that is part of the Innovation, Science and Economic Development Canada portfolio.

    Bringing competition into focus


    Competition Bureau encourages online competition in the eye wear industry

    The Competition Bureau (Bureau) has a long history of advocating for increased competition and innovation in the health care sector. For years, the Bureau has provided advice to governments, regulators and other decision-makers (collectively, decision-makers) on ways to enhance competition, while at the same time achieving legitimate public policy goals. Competitive markets are responsible for delivering many of the products and services upon which our health care system relies, and healthy competition can lead to innovation in product and service delivery, increased consumer choice and lower prices.

    Over the last few years, the Canadian eye wear industry has been in a state of steady growth, fueled in large part by an increasing number of Canadians requiring corrective lenses. There have been numerous advancements in visual health technologies, and competition in the industry has sparked innovation in products such as eyeglasses and contact lenses. Competition has also led to changes in how eye wear has traditionally been advertised and sold to consumers, most notably via the Internet. However, purchasing prescription eye wear over the Internet may not be so easy in the future given different regulations in place across the country and ongoing litigation that could impact how online eye wear retailers operate.In this edition of the Competition Advocate, the Bureau examines certain regulations governing the dispensing of prescription eye wear, and explores the implications that they may pose for online eye wear retailers. To enable consumers to benefit from online competition in retail eye wear sales,the Bureau calls upon decision-makers to take competition into consideration when implementing and reviewing regulations that govern the industry.

    The eye wear industry at a glance

    Expenditures on vision care services have been on the rise in Canada since 2012. With an ageing population in need of corrective lenses and eye wear making a comeback on the fashion scene, sales in the industry have flourished. In 2017, retail eye wear sales in Canada were estimated to be nearly $2.1 billion, with prescription eye wear sales accounting for over 80% of the total (or roughly $1.7 billion).

    Online competition in the eye wear industry has provided consumers with access to lower-cost products and greater convenience. In 2012, CBC's Marketplace broadcast a segment on the high price of prescription eyeglasses sold in Canada. The CBC reported on price differentials between eyeglasses sold in-store and those sold online. Their findings suggest that eyeglasses sold at traditional brick-and-mortar retail outlets could be at least 50% more expensive than those purchased online.

    With the recent surge in online eye wear sales, warnings have come from some industry associations. In a 2014 position statement, the Canadian Association of Optometrists (CAO) cautions that the unregulated sale of eye wear over the Internet can compromise patient care. Similar warnings have been issued by provincial regulatory bodies, including, among others, the Nova Scotia Society of Dispensing Opticians, the College of Opticians of Ontario, the Saskatchewan Association of Optometrists and the Opticians Association of Canada, British Columbia Chapter.


    Consumers can benefit from purchasing eye wear
    Online


    Competition in the eye wear industry has provided consumers with access to lower-cost products and greater convenience. In 2012, CBC's Marketplace broadcast segment on the high price of prescription eyeglasses sold in Canada. The CBC reported on price differentials between eyeglasses sold in-store and those sold online. Their findings suggest that eyeglasses sold at traditional brick-and-mortar retail outlets could be at least 50% more expensive than those purchased online.

    Further support for lower online vs. offline prices is offered in a study published by the United States Federal Trade Commission (FTC). In their report, the FTC found that contact lenses sold online were on average $15 USD cheaper than those sold offline, though wholesale clubs offered the lowest average prices
    overall. An FTC Bureau of Economics Working Paper also examined the online and offline prices of contact lenses and found that, when controlling for differentiated retail services, offline prices were approximately 11% higher than online prices.
    In addition to cost savings that can be realized by making purchases over the Internet, nearly half of all Canadians find online shopping to be more convenient than visiting a brick-and-mortar retail outlet. In the online world, customer reach can also extend to regions across Canada, including remote locations that may not be well served by traditional retailers. For example, Internet retailing of eye wear appears to have improved access to eyeglasses and contact lenses for a number of consumers living in rural or otherwise under serviced Ontario communities.


    source:

    http://www.competitionbureau.gc.ca/e...eng/04377.html
    Last edited by Chris Ryser; 11-13-2018 at 01:33 PM.
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    Redhot Jumper OOA response to competition bureau report – online dispensing of eyewear

    OOA RESPONSE TO COMPETITION BUREAU REPORT – ONLINEDISPENSING OF EYEWEAR


    The Competition Bureau recently published an article advocating for provincial governments and regulators to provide greater access to online eyewear sales.This highlighted an issue that has been around for quite some time in our industry.
    The Ontario Opticians Association (the “OOA”) believes consumers should have the right to make purchasing choices … but they must be safe choices. The OOA supports changes to the regulations and standards of practice that permit opticians to better utilize the internet to serve their clients.
    The fact that a corporation chooses to operate only online should not give them the right to circumvent the regulatory rules which the Ontario Government has putin place to protect the public. Corporations can comply with the law by properly involving opticians in the dispensing process and still have successful business models. Furthermore, the OOA is committed to assisting its members to determine how current technology can be used to safely perform the controlled acts that they have been authorized to perform. The OOA believes that current technology provides the opportunity to allow for safe practice if appropriate controls are in place.

    Dispensing has been designated, at law, as a controlled act within the Regulated Health Professions Actin Ontario. The law recognizes, and it has been confirmed by the Ontario courts that an act that has been designated as a controlled act is inherently dangerous and therefore has been taken out of the public domain. This is intended to ensure that only those individuals with the appropriate skills, education and knowledge, as evidenced by their registration with the appropriate regulatory agency, are permitted to perform particular tasks.

    Published August 13, 2018



    continue:
    http://ontario-opticians.com/2018/08...-bureau-report
    Last edited by Chris Ryser; 11-13-2018 at 01:46 PM.
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    It's ironic to me that the competition bureau is ruling on what is obviously, a monopoly, taking over an industry illegally, and justifying it with price.

    We all just sit back and watch as luxotica takes over the retail of the planet, becomes vertically integrated with design, labels and manufacturing. Takes over the largest internet retail company, clearly contacts (now clearly), while merging with the lens monopoly, who has already paid for private labs, and incentivized independents to use their products with loss leader equipment, not before esslior bought transitions, and became unified with Nikon in Canada. The colleges sit only in advisory capacity on the board of this illegal company, while they police us, until finally an injunction is laid against the monster, only to be appealed with their bottomless pockets, while their online presence becomes so established that it cannot be challenged.... And what are we told? "It's more competitive" what will they acquire next? Cooper vision? B&L, Safilo, Zeiss, Hoya? They are behind the dispensaries of Costco, Walmart, and other discounters where they sell product cheaper to the patient than what they charge you, same goes for Lux frames with lenses, why use a wholesaler and a lab, why take. Measurements at all? when you can fill though them... And drop ship? That's next... Online exams.. Robotic adjustments.. You will be relegated to a kiosk, doing troubleshooting. That's the future of your business, and your profession.

    Meanwhile most ecps prostitute themselves out for Ray bans made in China, or Oakley and crizal, for short term profits, while they sell new models against you and discos online... and you offer to adjust frames for a fee? This type of ECP disgusts me. You provide the pd for free or a charge our of fear, of negative reviews? It's a drop in th bucket for what you are about to give up.

    How do the associations, the academic institutions, the colleges take money from the enemy, to sell their products for them down the road? Do you belong to their buying group? Do your patients get insurance from essilor Nikon luxotica clearly? Ever see the featured products if your private labels in the "independent" buying group flyer

    You deserve what you get if you deal with this company, in any capacity. You cannot negotiate with these people. Why is there not an industry wide boycott? Internationally?
    Its time to stand up. Without us, they are nothing.. But act now or our profession will die, and every price, brand, and facet of this industry will be controlled from Italy until it is taken over by Amazon, or China. It is not inevitable, only if we are weak.
    Last edited by Clearly_a_monopoly; 12-21-2018 at 10:19 PM.

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    Thumbs up

    Well said

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    And yet independent owner-operated ECPs, bruised and battered, carry on in the midst of the tsunamis and ground shifting in the market. We are fewer in number I think than ever. But to survive you adapt or fade away (or sell to a chain, or private equity). Interestingly I see more advertising on mass media by the likes of WARBY PARKER and HUBBLE - both attempting to disrupt all of us, going vertical and totally bypassing ESSILUX, JNJ, CIBA ALCON etc.. and apparently raising capital to do so - so some people believe that the old model run by the monopolies is vulnerable too - they seem to be making in-roads.

    SO what if Essilux doesn't buy out Warby...What if JnJ doesnt buy out Hubble....maybe Amazon does....or amazon just decides one day to dive deep into optical and create their own brand (imagine what they will do with AI and their strangle on online sales) -

    Essilux is also vulnerable. GE, BEAR STEARNS. No one is too big to fail. AI and Amazon lurk in the not-so-far background...

    Online exams - definitely an even greater threat to every ECP -

    Meantime, I see as many patients every day as I ever have, average sale is down, so I adjust where I can, try new promos and tweak operations to be more efficient. We are adapting. Good luck to all and Merry Christmas, Happy New Year to my fellow ECP warriors.

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    Redhot Jumper The selling pricing in the optical retail market will have to be changed ............

    Quote Originally Posted by optimensch View Post

    SO what if Essilux doesn't buy out Warby...What if JnJ doesn't buy out Hubble....maybe Amazon does....or amazon just decides one day to dive deep into optical and create their own brand (imagine what they will do with AI and their strangle on online sales) -

    Essilux is also vulnerable. GE, BEAR STEARNS. No one is too big to fail. AI and Amazon lurk in the not-so-far background...

    Online exams - definitely an even greater threat to every ECP -

    Meantime, I see as many patients every day as I ever have, average sale is down, so I adjust where I can, try new promos and tweak operations to be more efficient. We are adapting. Good luck to all and Merry Christmas, Happy New Year to my fellow ECP warriors.



    Thank you for your straight forward post ..........................................

    With Alibaba, the world 's third largest commercial website coming out to public view, with their manufacturing pricing of just about anything produced on the world market, the basic value of just about any product, at the manufacturers level, on the market is now visible to anybody, and at their fingertips.

    The selling pricing in the optical retail market will have to be changed to a reasonable markup, as most other products, with added charges for excellent or not so excellent services. This is the only way the public will understand the pricing of the optical retail market.

    The products sold on line are having a normal conventional pricing markup, from the manufacturing level to retail pricing, compared to inflated ones due to their services rendered in the optical retail level.

    Warby Parker has become the loudest and most visible of all online optical s, and will probably be gobbled up by UnitedHealth, but EyeMed and VSP will have to react somehow.
    Chris Ryser
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    Redhot Jumper The industry is already now controlled ...............................

    Quote Originally Posted by Clearly_a_monopoly View Post

    You deserve what you get if you deal with this company, in any capacity. You cannot negotiate with these people. Why is there not an industry wide boycott? Internationally?

    Its time to stand up. Without us, they are nothing.. But act now or our profession will die, and every price, brand, and facet of this industry will be controlled from Italy until it is taken over by Amazon, or China. It is not inevitable, only if we are weak.

    ............................it is too late to stand up. I have warned OptiBoard members periodically of the danger that was building up for more, than the last 12 years. There are only about 24% independents left on the optical retail circuit in the USA.

    The industry is already now controlled, by the fused Essilux out of France and growing fast on a world wide basis. The corporation is also heavily banking on internet sales of eyeglasses.
    Chris Ryser
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    http://optochemicals.com............................. http://arcoatings.com

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    The selling price will only have to change if you intend to compete directly with Essilux online
    B

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    Blue Jumper With a close to a online majority, among optical eyeglass sellers ...................

    Quote Originally Posted by Barry Santini View Post

    The selling price will only have to change if you intend to compete directly with Essilux online
    B



    Barry......................I disagree with your above statement, and here is why..


    With a close to a online majority, among optical eyeglass sellers, ESSILUX is actually and physically targeting the next and future generations of eyeglass users, that live, eat, sleep and drive with their cell phones in their hands, and have any information wanted at their fingertips, while having already reached 14% of the total USA optical retail sales by online optical s .

    Also with the latest publicity on the worlds third largest commercial website; https://www.alibaba.com/trade/search...yeglass+frames, the public or anybody else, can now easily see the value of optical frames and lenses, as well a car windows, and so forth, at the manufacturers price level.


    The consumer now has the capability to easily find out what a product is worth at the start of its origin, and how much he/she, is willing to spend for it and, all of that in seconds or a few minutes.

    ..............and lets not forget that Essilux is a high quality corporation and will continue doing so.
    Chris Ryser
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    Quote Originally Posted by Chris Ryser View Post
    Barry......................I disagree with your above statement, and here is why..


    With a close to a online majority, among optical eyeglass sellers, ESSILUX is actually and physically targeting the next and future generations of eyeglass users, that live, eat, sleep and drive with their cell phones in their hands, and have any information wanted at their fingertips, while having already reached 14% of the total USA optical retail sales by online optical s .

    Also with the latest publicity on the worlds third largest commercial website; https://www.alibaba.com/trade/search...yeglass+frames, the public or anybody else, can now easily see the value of optical frames and lenses, as well a car windows, and so forth, at the manufacturers price level.


    The consumer now has the capability to easily find out what a product is worth at the start of its origin, and how much he/she, is willing to spend for it and, all of that in seconds or a few minutes.

    ..............and lets not forget that Essilux is a high quality corporation and will continue doing so.
    Let's not fear monger here and be realistic. All products manufactured in the world including that suit jacket from Sri Lanka starts at about $1 but that doesn't mean you pay that and will still need a suit jacket that fits properly and looks good. It's gotta ride by donkey or camel to the airport for that 15 hour flight to North America which certainly is no longer $1.

    The fact public can now see the value of low quality chinese frames which isn't realistic for many reasons - you need to buy large volume, you need to wire US funds up front (and may never see your products after you pay), you need to pay for shipping, you need the proper importing paperwork, and you need to want to buy that crap in the first place.

    As for lenses, sure that liquid monomer to start the process is relatively inexpensive. Now let's toss in the molds, curing, tape, alloy, surfacing polishing equipment, coating machines, edgers and the expertise to turn that monomer into a pair of quality lenses. Have you got about $300K to $5M in capital put aside to buy that initial liquid monomer?

    It's all relative.

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    It's health care. It's not something you buy online.

    I keep telling people this.

    You want DIY? You have it.

    But the history of vision care has shown that it is an exacting science, not easily mastered even by professionals.

    It's plain foolishness to think the advent of electronic commerce has somehow changed the nature of vision care itself.

    We have fools in government. Hardly a newsflash.

    Yet we must not roll over. That's our professional obligation.
    Last edited by drk; 12-28-2018 at 10:41 AM.

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    Quote Originally Posted by drk View Post
    It's health care. It's not something you buy online.

    I keep telling people this.
    The reality we're facing is that the market disagrees with you.

    So, now what? From what I see here, the options are either a) play ball in the name of service or b) shove out the unbelievers in the name of protectionism. And I don't think there's going to be a survivable middle ground five years from now.

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    "The market" is the wrong concept.

    There's "a market" for streaming entertainment. There's "a market" for securities. There's "a market" for sporting goods.

    Is there a "health care market"? Does "a marketplace" control cancer care?

    To a degree, only.

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    Quote Originally Posted by drk View Post
    "The market" is the wrong concept.

    There's "a market" for streaming entertainment. There's "a market" for securities. There's "a market" for sporting goods.

    Is there a "health care market"? Does "a marketplace" control cancer care?

    To a degree, only.
    In as much as insurance providers are functionally cartels in our warped version of a "health care market," yes, I would argue that if it functions and quacks like a market...

    We're past the point of patients treating themselves as patients, or eyewear as medical devices. So what do we do now? If we look at the reality of where we are now -- that we exist within a marketplace that's cartel-controlled -- then that will better-inform strategic decisions five, ten, etc. years from now.

    We can attack the problem from a belief that things should be a certain way, but failing to recognize that they are not that way now is critical to fixing the issue. But that's a problem that needs to be taken apart from all perspectives: ten years from now, why are independents still a better option than online? Do we know they for certain will be? How can we make that possible future a reality today? That's what we have to solve now.

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    What's up? drk's Avatar
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    Well, first things first.

    Any organization or individual that doesn't have foundational principles will blow in the breeze. What are ours (optometry, opticianry)? Is there an "opticianry" left? Have they divided and conquered? Let's assume there is a remnant to rise like a phoenix.

    But that's another thread.

    We're not "past" anything. "Don't go all wobbly on me, George the Gaspowered Robot". Click image for larger version. 

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    In your state, and now mine, legislation has been passed to allow vision care to opt out of these vertical VCP arrangements, for example. Just one of many examples of issues that need addressed.

    I go all Sir Edmund Burke on you, now: Click image for larger version. 

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    And: Click image for larger version. 

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    (Even though this thread is about Canadians, they're still a Commonwealth.)

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    Don't get me wrong, my original thoughts weren't intended to come from a "sky is falling" perspective, rather the perspective of: let's say the sky has fallen, and we've lived through it. Now what?

    And you're right, that's probably a different thread. But I don't think that charging people for PDs is going to make Warby stop being a problem. We all agree to that, right?

    Long story short, we do need a unified reason to exist. And that's a conversation to start having now.

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    The problem is larger than we personally experience. AI etc. is interfering in other aspects of health care.

    Technology: a tool. Is used for good, is used for not-so-good.

    But it is used by PEOPLE and people are in need of moral leadership.

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    Show people better. Many, not all, will come.

    Better is definitely NOT just the frame or lens.

    B

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    Redhot Jumper ..............................Shipment these days is done by the regular FEDEX/UPS/DH

    Quote Originally Posted by Lab Insight View Post

    Let's not fear monger here and be realistic. ...........................................

    The fact public can now see the value of low quality chinese frames which isn't realistic for many reasons -
    you need to buy large volume, you need to wire US funds up front (and may never see your products after you pay), you need to pay for shipping, you need the proper importing paperwork, and you need to want to buy that crap in the first place.

    ...............................If you would have checked the link to Alibaba I gave in the previous post, you would have seen loads of companies that are willing to sell quantities from one on up, at a certain price.

    ...............................If you order you will get an invoice for the price plus transport, and pay by transfer or a credit card, same as if you order from here.

    ..............................Shipment these days is done by the regular FEDEX/UPS/DHL ect, who also take care of the import duty and customs paperwork.

    All this old believe that everything coming from the far east is crap, while you use the same products on a daily basis from one of your regular wholesalers at their own markups.

    It is about time to see todays reality.
    Chris Ryser
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    Chris, if you think those frames are so good, go buy them.

    They are trash and not comparable to what good opticians sell. You're out of touch.

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    On a major publication as Alibaba you will find them all..............

    Quote Originally Posted by Robert_S View Post

    Chris, if you think those frames are so good, go buy them.

    They are trash and not comparable to what good opticians sell. You're out of touch.


    On a major publication as Alibaba you will find them all...............from scrap to the top notch quality. You
    Advertise and pay for it.

    So your above statement is not quite valid and I am not out of touch. I have sold thousands of Liters of Zero-Fog
    into the automotive manufacturing industry in China and India through advertising on Alibaba between 2005 and 2017.
    Chris Ryser
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    Quote Originally Posted by Chris Ryser View Post
    ...............................If you would have checked the link to Alibaba I gave in the previous post, you would have seen loads of companies that are willing to sell quantities from one on up, at a certain price.

    ...............................If you order you will get an invoice for the price plus transport, and pay by transfer or a credit card, same as if you order from here.

    ..............................Shipment these days is done by the regular FEDEX/UPS/DHL ect, who also take care of the import duty and customs paperwork.

    All this old believe that everything coming from the far east is crap, while you use the same products on a daily basis from one of your regular wholesalers at their own markups.

    It is about time to see todays reality.
    Up until the time I began seeking partial retirement, the products we sourced on a daily basis - we had full control of the supply chain and even today none of our products are found on Alibaba which IMHO is just a dumping ground for low quality over stock.

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    ..
    Last edited by Robert_S; 12-29-2018 at 08:11 AM. Reason: Duplicate post

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    Quote Originally Posted by Chris Ryser View Post
    On a major publication as Alibaba you will find them all...............from scrap to the top notch quality. You
    Advertise and pay for it.

    So your above statement is not quite valid and I am not out of touch. I have sold thousands of Liters of Zero-Fog
    into the automotive manufacturing industry in China and India through advertising on Alibaba between 2005 and 2017.
    Show me a top quality pair.

    And also, what the heck has zero fog got to do with frames???

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    Blue Jumper Show me a top quality pair. ...............................................

    Quote Originally Posted by Robert_S View Post

    Show me a top quality pair.

    And also, what the heck has zero fog got to do with frames???

    I introduced the L'Amy frames into Canada in the 1960's and 70's, as well as the German NIGURA Line (now Rodenstock). So I do have a fair knowledge on top quality frames.

    On Alibaba as of today you have a choice of, 93'378 results for "eyeglass frames", which consists most probably of all sorts and quality levels, advertising at :

    https://www.alibaba.com/trade/search...yeglass+frames

    So you should have a fair choice of good and or bad ones within that amount listed.

    Also ZeroFog has only to do with the lenses not fogging up, if treated with it, but the automotive industry decided, over 10 years ago that their dashboards could fog up in some emergency situation, and is protecting them by applying the product there, and found my advertising on Alibaba.
    Chris Ryser
    ________________________________________
    DLO. NA.IC.I.T.PO

    http://optochemicals.com............................. http://arcoatings.com

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