Notice of objection: Layfield Group Ltd. - February 2022

Tuesday February 22nd 2022,

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

Tracey Spack
Director, Plastics Regulatory Affairs Division
Environment and Climate Change Canada
351 Saint-Joseph Blvd.
Gatineau, Québec, K1A 0H3


Dear Minister Guibault,

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

Plastics are the most environmentally friendly material and offer the lowest carbon footprint for almost every application. By banning or prohibiting plastic we are creating a much worse problem for the environment. Why would we ban plastic in favour of more harmful materials? If our biggest challenge is global warming over the next 100 years we need to strongly consider the unintended consequences of these actions.

The Layfield Group is a vertically integrated manufacturing, distribution, and installations company. We provide tailored solutions that give our customers peace of mind, protect our communities, the environment, and our families. We are proud to offer a variety of sustainable plastic packaging solutions that address end of life concerns including Bioflex™ This is a recyclable and degradable form of plastic that can also include recycled content. Every KG of this waste will not only disappear in our generation but also has the potential to power an electric car for 25KM’s leveraging gas collection systems in modern landfills should it escape mechanical recycling streams.

Layfield Group Ltd. 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.

Layfield Group Ltd.

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

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

Expansion of the Scope of the Prohibitions Beyond What was Included in October 2020 Consultations

The October 2020 consultation proposed six single-use plastic items be prohibited based on the following criteria: environmentally problematic, recovery problematic, and alternatives exist.

Innovative Technologies and Processes not Assessed in Determining
Whether Materials are Recovery Problematic

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.

Extended Producer Responsibility Programs Address Many Concerns about Post-Use Management of Single-Use Plastics, Extended Producer Responsibility Programs not Considered

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

Assumptions in Strategic Environmental Assessment are Based on Incomplete Science, Incomplete Science used for Environmental Assessment, Environmental Assumptions Lack Scientific Rigour


We recognize that there is a lot of pressure for government to take steps towards a more circular economy. We urge the government to consider the unintended consequences. While we believe adding recycling and circular infrastructure will be viewed positively, we know bans not based in science, in fact do more damage and can create significant harm politically and practically.

We believe strongly that Bioflex™ technology can be quickly introduced and we are happy to share how we see this as a far more sustainable solution, to start making a difference in our generation.


Mark Rose
President - Flexible Films Layfield Group Ltd.


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