Challenging Canada’s primary food plastic packaging Problem
Last month, Environment and Climate Change Canada (ECCC) held a consultation for primary food plastic packaging with the motivation to gain insights across the public and private sectors for a Pollution Prevention Notice (The P2 Notice) that will set requirements for Canada’s largest grocery retailers to prepare and implement a pollution prevention plan (P2 plan), with an aim towards zero plastic waste from primary food plastic packaging.
Primary food packaging is the packaging that comes into direct contact with the food we consume. So, think of beverages, sauces, eggs, meat and fish, dairy, frozen fruits, vegetables, and other goods - likely a lot of packaging you’d like to avoid but feel limited or fully unable to do so.
While the Government of Canada has banned six single-use plastics, primary food packaging continues to pollute environments, contribute to overflowing landfills, and drain precious resources - all while contributing to the climate crisis. Surfrider Canada’s submission is guided by the ethos that to shift to a true circular economy for all plastics, including primary food packaging, the Government of Canada needs to embrace a Zero Waste Hierarchy. The Zero Waste Hierarchy describes a progression of policies and strategies to support the Zero Waste system, from highest and best to lowest use of materials. Zero waste is the conservation of all resources by means of responsible production, consumption, reuse, and recovery of all products, packaging, and materials without burning them and with no discharges to land, water, or air that threaten the environment or human health.
The zero waste hierarchy is apparent in the instruments recommended in Surfrider Canada’s submission to the ECCC, which needs to be implemented in an integrated manner and following the principles identified by the University of Victoria’s Environmental Law Centre report “Enhancing Plastic Recycling in Canada”.
The first principle encompasses establishing and executing a circular economy for plastic food packaging through measures that are systematically and harmoniously implemented recognizing the interdependency between these measures.
Secondly, all actors need to participate in the system redesign to function effectively and efficiently, and this includes governments, producers, retailers, consumers, and non-government organizations.
Third, governments need to work collaboratively with all aforementioned groups to standardize and harmonize standards, programs, definitions, targets, labelling, criteria and policies.
Fourth, governments need to collect baseline data and set mandatory, measurable targets that are monitored and reported on.
Fifth, country-wide circular economy educational programs for the public, businesses, universities, designers, engineers, scientists and industry are necessary for the success of the transition to a circular economy.
Finally, there needs to be continued investment in research and innovation to overcome technological barriers to support the most advanced regenerative circular economic solutions at scale.
We are thrilled that the ECCC is taking this next step in the movement to achieve zero plastic waste in Canada. However, we strongly advise the ECCC not to wait until 2035 to achieve desired results with The P2 Notice. If The P2 Notice is not attaining results in the next few years, the Government of Canada needs to regulate the targets in The P2 Notice. Additionally, there is a long laundry list of unnecessary plastic products and packaging offenders. The ECCC needs to build off of the P2 notice to address other forms of plastic. The recommendations for the P2 Notice and going beyond this notice are chronicled below, expand the accordion to learn more in each section.
Recommendations
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-Develop packaging designs that eradicate the use of plastic and shift to easier-to-recycle materials like paper and metal. Prioritize phasing out of plastic resins that are the most toxic to humans and the environment, including expanded polystyrene (EPS), which contains styrene and benzene. PFAS needs to be banned from primary food packaging and items replacing single-use plastics like paper straws.
-Develop packaging designs that eradicate the use of multiple materials, which are hard to keep in a circular system. Support one form of material in design.
-Eliminate plastic produce stickers, which are being collected more frequently during beach cleanups and contaminate composting systems.-Optimize products and packaging to minimize waste and use fewer resources during production and transportation.
-To stimulate source reduction and packaging redesign, implement a tax on virgin plastic resins, which will create a stimulus to use less virgin plastic, to use recycled plastic when necessary, and ideally shift towards the reuse of plastic and other material packages.
-The P2 Notice should also capture major suppliers that package their own food, including Sysco and Gordon Food Service (GFS).
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-Rapidly advance reusable packaging options for customers, including bulk bins, refill stations, and zones for dropping off reusable packaging and picking up replacement products in clean reusable packaging.
-Set targets for reusable packaging across the country, accompanied by transparent monitoring and progress reporting. For refill and reuse systems, the Government of Canada needs to set a return target on containers, ideally 80% by 2030 and 95% by 2035 with reporting how systems are achieving these return rates.
-Mandate the food retail and service sector to provide reusable bags and produce bags that are made from regenerative materials, including hemp and bamboo, and create a program for redistributing used bags instead of only distributing brand-new bags.
-Institutionalize incentives for customers to utilize their reusable containers, and charge higher fees for single-use packaging.
-Waste levies can be implemented as a measure to reduce primary food packaging waste and promote more sustainable options like reusable packaging. Waste levies can be applied to food packaging that is hard or not possible to recycle.
-Utilize government green procurement as a method for advancing reusable packaging systems. -
As per the Consultation document, we support prohibiting the use of the chasing-arrows symbol and other recyclability claims on plastic packaging. We are also aligned with prohibiting terms like “degradable” and “biodegradable” in the labelling of plastic packaging and single-use items. For items to be considered “compostable”, they need to meet extremely stringent standards that are made collaboratively with the industrial composting industry and made from regenerative materials like seaweed and mushrooms (as opposed to GMO compostable products made from corn and soy, which are extremely problematic for the environment). Additionally, label packing:
-With clear information on recycled content, recyclability and disposal methods, as well as any harmful additives like flame retardants.
-Can include QR codes that consumers can scan to retrieve more in-depth information about the packaging, including exposure to toxins, recyclability, reusability, carbon footprint and life cycle analysis, as well as any third-party certifications.
-Indicates any plastic packaging that is not visible so that consumers can make an informed choice, including boxes with products wrapped in plastic inside. An insidious example of this is plastic tea bags, which also contaminate compost streams and should be banned. Look to the European Union on best practices for this recommendation. -
Extended Producer Responsibility (EPR) regulations can make primary food plastic packaging producers responsible for the environmental impact of their packaging, through the entire lifecycle from production to disposal. This can make producers operationally and financially accountable for their packaging, and then report on their packaging usage, collection efforts, and recycling rates.
According to the Smart Prosperity Institute, EPR programs can provide a powerful policy mechanism that addresses barriers to a circular economy for primary food packaging, including:
“1. EPR induces the creation of a reverse supply chain for the collection and recycling of plastics, and by doing so at volume and scale, it creates a large sustained supply of quality recycled resins for the production of products and packaging. As such it will address, in part, the supply-side price disparity between fossil and recycled plastic resin feedstock;
2. It will address, in part, unpriced externalities by mitigating the discharge of plastics to the environment, emissions associated with burning plastics for energy from waste, and energy use and emissions associated with virgin resin production.” -
We are encouraged to see that the federal government will be implementing minimum recycled content standards, meaning that packaging must contain a minimum amount of recycled content to redress the current market failure. However, the P2 Notice should also create minimum recycled content standards for reusable plastic items, including bulk bins and other systems for refill, which will ideally be implemented across the country as part of the P2 Notice.
-Additionally, we urge the Government of Canada to strive for more ambitious targets regarding annual averages, including 30% by 2028, 40% by 2030 and 50% by 2035. Aggressive action is required since the fossil fuel industry shifting to plastic production as a result of the renewable energy revolution, aggressive action is required.
-Minimum recycled content regulations will also complement extended producer responsibility initiatives, which create a demand for recycled plastic and can thus create a self-sustaining system. -
Finally, while primary food packaging does create an enormous amount of waste, some other plastic packages and products also merit urgent attention. Work needs to be done to:
-Optimize all products and packaging to minimize waste and use fewer resources during production and transportation. For instance, eliminating water from all cleaning and detergent products will result in a more concentrated product and thus compact packaging that uses less materials and creates less emissions in transport.
-Stimulate a circular economy for food retail equipment and infrastructure, including shopping baskets and carts, which can be made from recycled plastic, including marine debris.
-Establish a timeline for phasing out plastic cooking utensils and kitchen equipment sold by food retailers, including pots, pans, and reusable food containers.
-Establish a timeline for phasing out plastic personal care items sold by retailers, including toothbrushes, toothpaste, floss, hairbrushes, elastics, plastic razors and cartridges,
