Minister's response to notice of objection: U.S. Chamber of Commerce

April 21, 2021

Neil Bradley
Executive Vice President and Chief Policy Officer
Myron Brilliant
Executive Vice President and Head of International Affairs
U.S. Chamber of Commerce
1615 H St NW
Washington DC  20062-2000
U.S.A.

Dear Neil Bradley and Myron Brilliant:

I am responding to the Notice of Objection that you filed on behalf of the U.S. Chamber of Commerce regarding the proposed Order to add plastic manufactured items to the List of Toxic Substances in Schedule 1 to the Canadian Environmental Protection Act, 1999 (CEPA). The proposed Order was published in the Canada Gazette, Part I, on October 10, 2020.

Subsection 332(2) of the CEPA states that any person may file a Notice of Objection requesting that a Board of Review be established. As set out in subsection 333(1) of CEPA, the mandate of a Board of Review in this instance would be to inquire into the nature and extent of the danger posed by plastic manufactured items.

I have fully and carefully considered the issues set out in your Notice of Objection. Your Notice did not contain any information relating to the scientific basis for the proposed Order. The scientific considerations that underlay the proposed Order are related to the ability of macroplastics to have an immediate or long-term harmful effect on the environment or its biological diversity as set out in section 64 CEPA.

With regard to the non-scientific points raised in your Notice of Objection, these are being considered alongside other comments received on the proposed Order. They will be addressed in the Regulatory Impact Analysis Statement that is published with the final Order.

I appreciate your bringing the U.S. Chamber of Commerce’s concerns to my attention.

Please accept my best regards.

Sincerely,

The Honourable Jonathan Wilkinson, P.C., M.P.

c.c.:
Chuck Chaitovitz, U.S. Chamber of Commerce
Martin Durbin, U.S. Chamber of Commerce
Neil Herrington, U.S. Chamber of Commerce
Gary Litman, U.S. Chamber of Commerce
David Weissman, U.S. Chamber of Commerce