Listing all plastic products as toxic takes away from their vital societal role

Let us be clear, one piece of plastic waste in the environment is one too many. Canada’s plastics industry is committed to solving the plastic waste problem and has set a goal to make 100 per cent of plastic packaging recyclable or recoverable by 2030 and embracing advanced recycling technologies to make plastics packaging 100 per cent recovered and recycled by 2040.

By making plastics completely recyclable and transforming waste into new plastic items and other products, we can help Canada realize its goal of zero plastic waste. `


On May 12, the federal government listed plastic manufactured items on the Canadian Environmental Protection Act (CEPA) Schedule 1: List of Toxic Substances. The listing provides the federal government with full authority to regulate all plastic manufactured items, including introducing bans on items such as grocery bags, straws, stir sticks, six-pack rings, cutlery, and certain food ware.


While the government has exercised its authorities, we are disappointed that safe inert plastic materials that play such important roles in the lives of Canadians are being labelled as toxic substances. The Minister heard clearly from our industry, and a broad cross-section of other industries where plastics play an important role, that such a move would do little to keep post-consumer plastics out of the environment.


We continue to believe that CEPA is not an appropriate tool for managing post-consumer plastic waste – and is certainly not the solution for eliminating it. The purpose of CEPA Schedule 1 is to manage chemicals found to be harmful to human health and/or the environment, either through regulation or bans. Plastics do not fit this category on a molecular basis. Plastics are a vital component to a number of industries that will be significantly harmed by this listing and ban. It’s why we have been advocating instead for a national circular economy framework that includes six strategic areas of focus to build a circular economy for plastics in Canada.

• Product design

• Increase access to recycling and collection

• Improve sortation capabilities

• Strengthen mechanical and advanced recycling capabilities

• Grow and expand end-markets

• Engage and educate consumers


Environmental Impacts

Listing plastic manufactured items on Schedule 1 of CEPA impedes the ability of industry and the provinces to develop sustainable environmental goals and circular economy practices for plastics.


A number of studies have already shown that plastics are more environmentally friendly than alternative or replacement materials. According to a study done by the Imperial College of London, if all plastic bottles were replaced with glass, the additional resulting CO2 emissions would be equivalent to adding 22 large coal-fired power plants. Shellie Miller, a professor at the University of Michigan also found that plastics have fewer environmental impacts than glass or metal alternatives. Without plastics, greenhouse gas emissions would be higher, making it even more challenging to meet climate goals.


Even more concerning, the CEPA listing would now allow the federal government to ban additional plastic items with minimal public consultation. The bans themselves could be for the use of plastics or as restrictive as manufacturing bans. In either case, Canada’s economy pays the price and vital plastic products that save lives, keep consumers and workers safe, and allow our transportation and infrastructure systems to operate cleaner and more efficiently are placed at risk.


Impact Abroad

Now that the CEPA listing is final, the federal government is expected to publish draft regulations for the implementation of the ban on the specified plastic products. With these regulations expected in the Fall, we encourage the federal government to rethink its objective of having the bans in place by the end of 2021 in order to allow supply chains and businesses that operate cross-border the time to transition. After all, it is only upon the release of the regulations that we will know exactly which products will be impacted – size, gauge, etc.


In particular, this move must be in line with our trade commitments between Canada and its largest trading partner, the United States. Plastic products are Canada’s third largest import category from and fifth largest export category to the United States. Additionally, the Canadian plastic industry supports over 93,000 jobs and includes 830 companies, 75 per cent of which are small and medium sized enterprises.


Significant disruption for these companies and jobs could create cascading economic impacts that could hurt Canada’s national economy.

Conclusion

The plastics industry continues to stress that a ban on plastic products will not address many of the current issues with low recycling and recovery rates. The industry supports a lifecycle view of plastics – from design to recycling infrastructure and innovative technologies that can create new products – which would effectively eliminate plastic waste and enable Canada to continue using this valuable resource.


Industry realizes that plastics belong in our economy, not in the environment. That’s why it’s important to take action to ensure that advanced recycling technologies are working with existing mechanical recycling systems to recycle more products. This approach will enable a more circular economy in Canada without endangering consumers or businesses.


CIAC and its members and partners will continue to encourage governments to partner with them to pursue their shared goal of establishing a circular economy for plastics. Instead of bans, all levels of government should focus on the development of a comprehensive framework of policies and tools dedicated entirely to managing post-consumer plastics to support this goal. Implementing the Canadian Council of Ministers of the Environment Zero Plastic Waste Strategy will more effectively address plastic waste in the environment and demonstrate true leadership on the issue.

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