Report calls for industry leadership on plastics

Proposed amendments to the Canadian Environmental Protection Act (CEPA) are likely to change the national landscape for plastic food packaging.

According to Martin Gooch of Value Chain Management (VCM), if significant changes aren’t made before Royal Assent, the bill’s well-intentioned aim to decrease the overall environmental impact of food – from farm to table – could backfire.

Why it matters: Farmers in the horticultural sector, along with those making use of plastics for feed storage and input packaging could be affected if plastic packaging becomes more expensive.

Perhaps the most high-profile aspect of the bill, which passed first reading on April 21, is its aim to strengthen protection against pollutants for communities identified as higher risk. It also attempts to prevent subsequent governments from weakening anti-pollution rules.

But the heart of Bill C-28’s proposed amendments tackle chemical substances, including the wide-ranging types of plastics used to package both domestically-produced and imported foodstuffs.

A just-released analysis published by VCM and U.S.-based Packaging Technology & Research aims to influence legislators across North America as they consider rules governing plastic use and recycling. 

A news release about the document takes particular aim at the proposed CEPA amendments, arguing that “implementing ‘one-size-fits-all’ hammer policies – such as the Canadian Environmental Protection Act – to increase the use of recyclable plastics will not reduce greenhouse gas emissions. In fact, (they’ll ultimately increase) emissions due to forced changes in packaging leading to increased food loss and waste.”

Gooch told Farmtario that VCM collaborated with the U.S. agency on the analysis due to a shared viewpoint that “we need to address issues surrounding plastics but we don’t want unintended consequences.” 

He argues increased food waste is a risk if Canada’s environment and climate change department pursues restrictions on consumer-fronting plastic packaging without adequately considering effects throughout the food value chain.

Food lost through retail-sector and post-consumer spoilage could increase significantly, Gooch says, to the point that the overall carbon footprint of the sector would outstrip the footprint from the manufacture of the plastic packaging.

Gooch says Bill C-28 could potentially ban plastics entirely by labelling them as toxic. It could start with the plastics used for grocery bags, drinking straws and cutlery but “all plastics have the same resin at their source” and the risk exists that more types will be eliminated in the future.

This assertion is challenged by a response to the proposed CEPA amendments from the Canadian Environmental Law Association (CELA). In a CELA website post, Counsel Joseph Castrilli notes the legislation would effectively separate an existing list of approximately 150 toxic substances into two categories: 19 to be banned and about 130 “that would only be subject to pollution prevention measures” that Castrilli describes as “vague” and at risk of being watered down as the bill advances toward final approval.

“The approach appears to be based on a federal government view, long supported by the chemical industry, that many of the substances on the current Schedule 1 are not ‘toxic’ in the traditional sense, and therefore should not be stigmatized and subjected to the most rigorous of measures available,” he writes.

The government says the bill creates a watch list of substances that could be a risk if there’s an increase in exposure.

Aside from the toxic label, though, equally troubling for Gooch is Bill C-28’s aim to establish and enforce recycling targets. He’s concerned this will be done without adequately consulting industrial-level plastics users and manufacturers.

The report argues for industry-driven change.

Gooch says the mishmash of recycling infrastructure in jurisdictions across Canada is a huge barrier and there is no overarching enforcement.

“Right now, you can do whatever you want as a company to design and produce a 100 per cent recyclable packaging product,” he told Farmtario. “But there’s absolutely no guarantee that those packages will ever end up being recycled.”

He outlines a litany of possible “greenwashing” efforts that ultimately create even more waste: bottles made with the most easily recyclable type of plastic that must be rejected because the label is made from a non-recyclable product, non-plastic adhesives and products needlessly made from combinations of materials and packages identified as compostable that actually break down into highly-persistent plastic microbeads.

“In Canada at the moment, there are literally tens of thousands of types of plastic packaging.”

Two provinces – Quebec and B.C. – have implemented what are known as “extended producer responsibility” (EPR) approaches to plastics production and recycling. Gooch says these systems represent an effort to take the responsibility for plastics recycling away from the consumer and put it on the manufacturer. Ontario’s EPR initiative was recently stalled, while the rest of Canada has nothing in the works.

The new VCM analysis recommends a stepped-up EPR system across the country, based on negotiated agreements with plastics manufacturers to remain within composition guidelines, as well as an amended CEPA as both a strong backbone to enforce adherence and a source for financial incentives. This, Gooch says, would encourage the creation of “a circular packaging economy” of plastic production, use and recycling. 

The plastics sector appears to be on board with this approach. In January, 30 food and packaging sector companies (including Maple Leaf Foods, Unilever, Loblaw and yogurt-maker Danone) and 24 government and lobbying agencies (including the Cleanfarms organization for recycling agrochemical containers) signed on to the Canada Plastics Pact.

The pact establishes targets for problem plastics, completely reusable, recyclable or compostable plastics and encourages more recycling and a minimum amount of recycled content to be used in plastics.

For Gooch, none of this will be possible if politicians defer to staunchly anti-plastic activists as they steward Bill C-28 toward Royal Assent. “Because it’s a complicated process, industry has to take the lead.”