Notice of objection: Dyne-a-Pak - February 2022

February 23th 2022,

The Honourable Steven Guilbeault, P.C., M.P.
Minister, Environment and Climate Change
200 boul., Sacré-Coeur
Gatineau, Québec, KlA 0H3

Tracey Spack
Director, Plastics Regulatory Affairs Division
Environment and Climate Change Canada
351 Saint-Joseph Blvd.
Gatineau, Québec, KlA 0H3

Dear Minister Guilbeault,

RE: Notice of Objection and Request for Board of Review in relation to the Single-Use Plastics Prohibition Regulations, Canada Gazette, Part I, Volume 155, Number 52, 2021-12-25

Dyne-a-Pak inc. div. of ProAmpac is a proud Canadian producer of trays made of polystyrene for all our grocery chain in Canada. We are in business since more than 30 years and based in Laval Québec. We are firmly committed on many projects and group to increase the circularity of the plastic in Canada. We are also a strong believer in sustainable development. We were the first to develop and alternative product 100% compostable. Finally we have supported all the food chain industry for Canadian family during the pandemic by providing on time the ultimate trays that have the less foot print impact on environment based on all Life cycle analysis made in Canada.

Dyne-A-Pak is also a member of the Chemistry Industry Association of Canada (CIAC), the Association for Canada's chemistry and plastic sector leaders, innovators, solution providers, and world class stewardship pioneers.


 - formally objects to the Proposed Single-Use Plastics Prohibition Regulations

 - requests the establishment of a Board of Review to review the recommendation

Possible headings: Expansion of the Scope of the Prohibitions Beyond What was Included in October 2020 Consultations, New Items Added without Consultation, Scope Creep without Consultation

Possible headings: Innovative Technologies and Processes not Assessed in Determining Whether Materials are Recovery Problematic, Technology not Considered in Assessing Single Use Plastics, Bans do not take Technology into account

The Federal Government's criteria used to assess items for prohibition can be briefly summarized as: is it environmentally problematic, is it value-recovery problematic, and alternatives are available.

Possible headings: Extended Producer Responsibility Programs Address Many Concerns about Post-Use Management of Single-Use Plastics, Extended Producer Responsibility Programs not considered

Possible headings: Trades one Source of Pollution for Another Without Fully Evaluating Impacts, Pollution Changed not Reduced, Impacts of Substitutes not Considered

Possible headings: Assumptions in Strategic Environmental Assessment are Based on Incomplete Science, Incomplete Science used for Environmental Assessment, Environmental Assumptions Lack Scientific Rigor


We will remain available for any discussion, and be assure that we are strongly against that prohibition regulations only because this will not have a positive impact on our environment... and for my kids future. We are going in the wrong direction, mainly because all the alternative will be a catastrophe. Again are willingness is to find a better real sustainable solution together.


Pascal Labrie
Vice-President and General manager
Dyne-A-Pak div. of ProAmpac.


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