Avis d'opposition : GDI Packaging Solutions Inc. - Février 2022

(Le document suivant provient d'un organisme qui n'est pas assujetti à la Loi sur les langues officielles et il est mis à la disposition du public dans la langue d'origine seulement).

February 17, 2022

The Honourable Steven Guilbeault, P.C., M.P.
Minister, Environment and Climate Change
200 boul. Sacré-Coeur
Gatineau, Quebec  K1A 0H3
ec.plastiques-plastics.ec@canada.ca

Tracey Spack
Director, Plastics Regulatory Affairs Division
Environment and Climate Change Canada
351 Saint-Joseph Blvd
Gatineau, Quebec  K1A 0H3

Dear Minister Guilbeault,

RE: Notice of Objection and Request for Board of Review in relation to the Single-Use Plastics Prohibition Regulations, Canada Gazette, Part I, Volume 155, Number 52, 2021-12-25

GDI Packaging Solutions Inc. (GDI) is an organization that specializes in bring environmental and cost savings packaging solutions to all major grocery and retail chains in Canada.

GDI is also a member of the Chemistry Industry Association of Canada’s (CIAC) Plastics Division and the Canadian Plastics Pact, which represents Canada’s leaders in plastics industry sustainability – a $35 billion sector that directly employs over 100 000 Canadians.

GDI Packaging Solutions Inc.

• formally objects to the Proposed Single-Use Plastics Prohibition Regulations.
• requests the establishment of a Board of Review to review the recommendation.

Expansion of the Scope of the Prohibitions Beyond What was Included in October 2020 Consultations, Items Added without Consultation, Scope Creep without Consultation.

• The October 2020 consultation proposed six single-use plastic items be prohibited based on the following criteria: environmentally problematic, recovery problematic, and alternatives exist.
• Those six items were: checkout bags, cutlery, stir stick, straws, ring carriers and foodservice ware.
• No additional consultation prior to including compostable and all extruded polystyrene, vs foamed polystyrene from was consultation.
• Compostables:
  • The Regulatory Impact Analysis Statement (RIAS) indicates that compostable plastic single-use versions of the six will also be banned.
  • Rationale for including compostable plastic items not a credible or evidence-based.

Plastic Checkout Bags

• RIAS fails to fully account for the benefits of secondary uses while using a single California study as an analogue to Canadian re-use rates.
• Studies prove that a minimum gauge of 2.25 mil allows plastic checkstand bags to meet all the criteria required to be ‘reusable’ as outlined in the government definition of acceptable bags.
• Canadian studies that show that plastic checkout bags measured at 2.25 mil are not single use and have high re-use and recycle rates.
  • Canadian studies show that 77 per cent of plastic checkout bags are re-used.
  • Of the remaining 23 per cent, 15 per cent are recycled and only 8 per cent are not re-used or recycled.
  • The net result is that plastic checkout bags have a 92 per cent reuse and recycling rate.
  • Provincial Extended Producer Responsibility programs have recycling targets that will lead to improved recycling rates.
• 2020 study by Materials Recovery for the Future concluded successful pilot projects demonstrating that flexible plastic packaging can be collected, sorted and baled at a material recovery facility (MRF) through curbside recycling programs.
• Many cities in Canada use a bag-in-bag approach to collecting plastic check out bags and “soft plastics”, including ring carriers.
• Government has not competed a full analysis of what products are available to replace plastic checkstand bags. Availability of paper and other proposed material is scarce and very costly, adding enormous expense to the consumer.
• Plastic manufactures have been involved with a total circular economy program for the pick up of checkstand bags / store plastics, the recycling of such plastics (in house) and the reprocessing of plastics into new items, for the past 30 years. This ensures these bags do not enter landfill.
• Government needs to understand that the plastic industry has a well proven infrastructure in place now for the recovery, recycling, and reprocessing of plastics.
• The issue of used plastic bags entering oceans and other areas of the environment is a POLLUTION problem.
• Requesting a Board of Review take into account the contribution of each of the technologies above be considered when determining if a plastic manufactured item is recovery problematic.

Government Actions Requires

1. Increase funding for the inclusion of plastic bags to be included in municipal curbside pick up programs throughout Canada.
   Note: Once product is picked up and returned to a MURF, the industry can be Responsible to arrange for Recycling and Reprocessing of the plastic material.
2. Lead campaigns to Stop Pollution throughout Canada.

Conclusion
The following amendment needs to be added to the definition of “single use plastic checkstand bags".

1. Implement a minimum gauge requirement of 2.25 mil for the manufacturing of plastic checkstand bags.

Sincerely,

Richard Gubb
Managing Director
GDI Packaging Solutions Inc
1504 Postmaster Dr
Oakville ON
416 540 7075