Notice of objection: Norwich Plastics - 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

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

Dear Honourable 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

Norwich Plastics is one of North America's leading Plastics recycling companies specializing in post industrial and post consumer Vinyl and thermoplastic reclaim and recycling. We are passionate about protecting and preserving our environment, and committed to the reclaim, recycling and reprocessing of plastics. We have been incorporated operating plastics recycling operations in Canada since 1987 and the US since 1995.

Norwich Plastics is also a member of the Canadian Federation of Independent Business, the Vinyl Institute of Canada and members of the Chemistry Industry Association of Canada's (CIAC) Plastics Division, which represents Canada's leaders in plastics sustainability- a $35 billion sector that directly employs over 100,000 Canadians.

Norwich Plastics

Possible headings: Scope Creep without Consultation

Possible headings: 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 not considered

Impacts of Substitutes not Considered

Environmental Assumptions Lack Scientific Rigour


As a plastics recycler and family business owner who has given his life to recycling plastics - I commend the ECCC for its bold approach to tackling plastic waste in our environment. The bans on these specific items will not deter litter, nor will it improve our broken municipal and commercial waste collection systems.

The assumptions made by the ECCC by the statements deeming polyvinyl chloride a problematic plastic flies in the face of the PVC-123 program that was done with ECCC to help reclaim PVC from hospitals - we are growing that program with the Vinyl Institute of Canada and easily recycling tens of millions of pounds of vinyl (post consumer and post industrial) and are shocked to see that Vinyl is being called problematic.

If anything the Vinyl industry is years ahead of other polymers when it comes to sustainability and post consumer PVC reclaim and recycling initiatives and actual programs.

I thank you Honourable Minister Guilbeault for your many years supporting our planet and ecology (and thank you for entering the political arena), and thank the entire ECCC team for its worldwide leadership in sustainability and protection of our planet and people.

If there is anything we at Norwich Plastics can do, or if there is anything further I can do personally to help Canada achieve its goals in protecting and preserving our planet, please feel free to reach out.

Tribu Persaud
Director of Business Development
Norwich Plastics


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