We appreciate the opportunity to provide comments on behalf of the members of the Canadian Beverage Association (CBA) in response to the Notice of intent to issue a section 46 notice for the Federal Plastics Registry.1 The CBA is the national voice for more than 60 brands of juices, bottled waters, sports drinks, ready-to-serve iced teas and coffees, carbonated soft drinks, energy drinks, and other nonalcoholic beverages. Our members directly employ more than 20,000 Canadians and operate production facilities and distribution centres throughout the country.
As signatories to the Ocean Plastics Charter2 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 2025,4 and play an active role in deposit-return and beverage recycling programs across the country, which are achieving recovery rates ranging from 65% to 85%.
Our sector supports greater consistency in the collection of data to advance the development of the circular economy in Canada. In response to the federal government’s proposal for a federal plastics registry, we have included the following recommendations in the attached submission:
- Recommendation 1: We encourage ECCC to support harmonization efforts and align the definition of “beverage container” with Ontario’s beverage container definition.
- Specifically, include only rigid plastic beverage containers in the definition and include flexible packaging that contains a beverage product in the flexible plastic packaging category.
- Recommendation 2: We encourage ECCC to align beverage container exemptions with the guidance published by RPRA.
- Recommendation 3: Although beverage producers may report total supply of packaging into a national registry, separate producer definitions are required for EPR policies to account for the distinctions between blue box and DRS programs.
- Recommendation 4: To support greater harmonization of recycling performance measurement in Canada, ECCC should ensure that definitions align with the final CSA standard.
- Recommendation 5: We have consistently advocated for the federal government to support the development of a national reporting platform, and we request that ECCC provide funding to the BCRNC to conduct the feasibility study.
- Recommendation 6: Only require producers to report (a) the resins, (b) the source of resin to make plastics products, (c) the subcategory of plastic products, (d) the total tonnes of plastic in products placed on the market in Canada, and (p) the method to determine supplied tonnes.
- Recommendation 7: Provide at least one year’s notice of new reporting requirements so producers can prepare their systems, then allow for the collection of data for a full year to report in the subsequent year.
- Recommendation 8: Delay the requirement for reporting plastic components in electric and electronic equipment until a proper assessment can be prepared on the costs and burden associated with this requirement.
- Recommendation 9: Require beverage container recycling program operators to report plastic beverage containers collected and marketed for recycling.
- Recommendation 10: Require reclaimers to report the amount of recovered plastic beverage containers processed into flake, as outlined in the draft CSA standard.
- Recommendation 11: Require waste haulers to report how much material they collect to verify recovery rates for beverage containers and other recyclable materials in the IC&I sector.
- Recommendation 12: ECCC should convene a technical working group of carton manufacturers, beverage producers and trade association representatives to establish the appropriate de minimis value.
- Recommendation 13: Use section 9 of CEPA to establish a CWS and an administrative agreement with the provinces and territories to harmonize packaging reporting.