Health Canada exploring mandatory packaging program, concerned with use of recycled plastic in food packaging

Health Canada is considering developing a mandatory packaging program, said John Field, chief, Chemical Health Hazard Assessment Division, Health Canada, during a Food Plastics and Packaging Consultation event organized by Food and Beverage Ontario (FBO) in Vaughan earlier this week.

Currently, packaging materials intended for use with foods in Canada may be submitted voluntarily to Health Canada for a pre-market assessment of their chemical safety, per Food and Drugs Act and Regulations. However, Health Canada is actively considering regulatory changes that would make this form of assessments mandatory. Field told event attendees that public consultations on the proposed regulation may start next year.

Field’s comments were part of an overarching discussion on plastic reduction measures, including the P2 notice, Canada Plastic Pact’s Golden Design Rules (GDR), the various extended producer responsibility programs across Canada and the recently introduced Federal Plastics Registry. The event was attended by F&B processors, retailers, packaging firms, municipal waste teams, government representatives and other sector stakeholders. An open discussion gave participants the opportunity to voice their challenges when it came to food packaging. This consultation was a follow-up to a January discussion on the same topic by FBO.

Participants acknowledged it takes years and a lot of investment to change packaging lines. Given the regulatory inconsistencies across the country and the lack of plastic alternatives to meet the industry’s food safety and shelf-life requirements, manufacturers are concerned the investments won’t yield desired results. However, they’re committed to actively work towards a circular economy, meet consumer demands for sustainably produced food, and keep plastics as much as possible out of landfills without compromising food safety.

Lack of alternatives

While the Golden Design Rules recommends the use of monomaterials, it’s not recyclable across Canada. Plus, the thickness of the plastic needs to be increased to meet the self-life requirements of products like dry pasta, which means the amount of plastic in the packaging isn’t minimized.

Another concern raised during the consultation was the fact that biodegradable plastics, which typically cost three times more than flexible packaging, don’t comply with the Golden Design Rules. Also, there is no internationally recognized definition for biodegradable materials. It varies from jurisdiction to jurisdiction, making it nearly impossible for large multinational F&B manufacturers to adopt such packaging.

Lack of consistency

The lack of consistency was a constant theme throughout the consultation. Attendees highlighted that packaging, which is deemed recyclable in Europe, isn’t in North America. They also shared their frustration with recycling programs in Canada that vary from municipality to municipality. Imagine creating packaging for each municipality and the associated costs!

Lack of consumer awareness

Food safety reasons notwithstanding, participants felt it was key to educate consumers about best recycling practices. For example, remove the non-recyclable films before recycling cardboard boxes. This will improve recycling rates as well as ensure we have higher-grade of recycled plastic for use. However, changing consumer behaviour isn’t possible overnight; it’ll take years of patient, ongoing education.

Lack of infrastructure

Another issue was the lack of infrastructure to back up Canada’s Zero Plastic Waste Agenda. There are challenges with sorting materials. As described by Doug Alexander, VP, sustainability and government relations, Belmont Food Group, Canada’s recycling system is a “catch-all” while in Europe materials are segregated by material and recycled through dedicated lines. It would be helpful to invest in technology that can automate recycling systems before demanding industry to make expensive changes that may not necessarily improve the state of plastic recycling in the country.

Toxins

A large part of the discussion centred around the lack of data to help determine the impact of microplastics on human health. Field said that at this point there are no consensus on how microplastics affect humans. He added that a lot of studies use spherical microplastics, a type of microplastics that humans aren’t exposed to. He suggested studies must be representative of what we, as humans, are exposed to. He admitted there’s evidence of toxicity in animal models but urged that most of them must be interpreted with caution.

Recycled plastic quality concerns

Field also shared Health Canada’s concerns with the use of recycled plastic in food packaging.

“We have a good handle on resins, the additives used and the amount of leeching, etc. But all bets are off when it comes to recycled plastic. We don’t have much info on how they behave. We don’t want them leeching chemicals into food. We’re looking at new risk management practices,” he explained.

At this point, there is zero science-based data to help determine how many types a plastic material can be safely reused in food packaging. The last thing one wants is a toxic package leeching chemicals into the food.

Despite all the concerns raised, the group was unanimous in its intention to create a circular plastic economy and avoid sending them to landfills.

As Alexander, who moderated the discussion said, “It’ll take time to divest ourselves from this addiction to plastics.” It’ll take years to build a society and culture that actively recycles and reuses products. Perhaps until then, it might be worthwhile for the industry to explore alternative measures like creating energy from waste, thereby keeping plastics out of landfills.