Notice of objection: Inteplast Bags and Films Corporation - February 2022

February 14, 2022

The Honourable Steven Guilbeault, P.C., M.P.
Minister, Environment and Climate Change
c/o Tracey Spack
Plastics Regulatory Affairs Division
Environment and Climate Change Canada
351 Saint-Joseph Blvd
Gatineau, Québec  K1A 0H3

Dear Minister Guilbeault,

Re: Notice of Objection - Canada Gazette Part 1, Vol 155, No. 52Single Use Plastics Prohibition Regulations – December 25, 2021

Inteplast Bags and Films Corporation, with plants in Delta, British Columbia and Saint John, New Brunswick has been manufacturing plastic film bags for North American retailers, grocers and their consumers for approximately 40 years. We have operated for many years with sustainability targets both internally, in terms specified manufacturing protocols as well as externally, for example engaging in select market circular recycling programs. We enthusiastically share in the salutary goals of protecting the climate and preserving the environment. Nonetheless, we respectfully file this notice of objection on the basis of the reasons set forth below, and respectfully request that a board of review be established under section 333 of the Canadian Environmental Protection Act, 1999.

Our observations of proposed regulations are these:

Specifically, as it relates to single use plastic bags, we contend the definition falls short in that:

Further, accreditation of reusable bags in Canada is not widely known or understood.

Therefore, we request a narrower definition of single use plastic bags to include:

In addition, to avoid current market confusion we request that further details be provided regarding:

We thank you for your review and consideration and look forward to your response.

With best regards,
Janine Paley
Senior Executive Manager

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