CBA had the opportunity to comment on the Consultation document: Pollution Prevention Planning Notice for primary food plastic packaging. As signatories to the Ocean Plastics Charter and members of the Ellen MacArthur Foundation’s Network, CBA members view sustainable packaging design, extended producer responsibility and the increased use of recycled content as essential components in accelerating the transition to a circular economy. CBA members have committed to make 100% of their packaging recyclable, reusable or compostable by 2025, and play an active role in deposit-return and beverage recycling programs across the country, achieving recovery rates ranging from 65% to 85%.
To support the beverage sector in its goal of beverage container circularity, we have included the following recommendations in the attached submission:
- Recommendation 1: Work with the Competition Bureau of Canada to ensure policy approaches taken to meet environmental objectives support fair, open competition among producers of store brand and branded products.
- Recommendation 2: Ensure that any pollution prevention planning policies complement and do not conflict with the goals of the Grocery Code of Conduct.
- Recommendation 3: Convene a working group of impacted brand owners to discuss the importance of harmonized policies (e.g., extended producer responsibility, recycled content
standards, labelling and pollution prevention planning) in order to reduce burden and support improved environmental outcomes.
- Recommendation 4: Ensure brand owners retain the flexibility to meet their reuse and refill goals in the way best suited for their business model.
- Recommendation 5: Conduct analysis of existing reuse models, consumers’ participation in those reuse models, and consumer acceptance of additional reusable and refillable packaging, along with an assessment of the cost implications and convenience standards.
- Recommendation 6: Clearly define the role retailers should play in collecting single-use, reusable and refillable containers.
- Recommendation 7: Explore policy mechanisms to ensure that food-grade material is used for food-grade packaging applications and not downcycled into other materials.
- Recommendation 8: Prepare lifecycle analysis to assess emissions associated with shifting from rPET beverage containers to reusable/refillable beverage containers.