Notice of objection: Hymopack Ltd - February 2022

February 23, 2022

The Honourable Steven Guilbeault, P.C., M.P.
Minister, Environment and Climate Change
200 boul., Sacré-Coeur
Gatineau, Québec, K1A 0H3
ec.plastiques-plastics.ec@canada.ca

Tracey Spack
Director, Plastics Regulatory Affairs Division
Environment and Climate Change Canada
351 Saint-Joseph Blvd.
Gatineau, Québec, K1A 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


Hymopack, A Division of ProAmpac, is a leading North American manufacturer of plastic shopping bags and can liners.

Hymopack is also a member of the Chemistry Industry Association of Canada’s (CIAC) Plastics Division, which represents Canada’s leaders in plastics industry sustainability - a $35 billion sector that directly employs over 100,000 Canadians.

Hymopack

- 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 Rigour

Conclusion

I sincerely hope the government is willing to reconsider its decision, based on science and facts. The current position does not make economic or environmental sense, and other options can and should be investigated further. I am willing to continue the conversation and provide alternatives.


Sincerely,

Gerry Maldoff
President
Hymopack, Ltd.


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