Notice of objection: Winpak Ltd. - February 2022

February 22, 2022

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

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

Winpak LTD is a Canadian-based packaging convertor headquartered in Winnipeg, Manitoba. We manufacture and distribute high-quality packaging materials and packaging machines, primarily used for the protection of perishable foods, beverages, pharmaceuticals, medical and personal care products. Winpak specializes in three main streams of packaging – Flexible Packaging; Rigid Packaging and Lidding; and Packaging Machinery. Winpak employs about 1400 people in our 4 Canadian operations.

Winpak 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.


Expansion of the Scope of the Prohibitions Beyond What was Included in October 2020 Consultations, New Items Added without Consultation, Scope Creep without Consultation

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

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


Plastic is a safe and inert material that is critical to the production and safe distribution of thousands of food, health, and consumer items that enable our modern way of life. Plastics will also be crucial in helping us achieve a low-carbon sustainable future. They keep agricultural products fresher and reduce food waste. Given they are lighter and more flexible than alternatives, plastic packaging offers a lower carbon footprint than alternatives and leads to reduced transportation emissions.

We strongly agree plastic waste does not belong in our environment, instead, plastics can and should be continuously reused in the economy. We are committed to sustainability goals and to establishing a circular economy for plastics based on the following six principles:

We believe government and industry both have important roles to play, and we need to work together on the management systems, infrastructure, and technologies to address post-consumer plastic waste. Bans and substitutions block our innovative and collaborative capabilities to allow best-suited materials to function for end uses. Focus placed on recycle infrastructure, investment in technology solutions for capture and recycle, consumer education, and expansion of robust markets for recycled materials will ensure all plastic stays out of the environment and contributes to a Circular Economy.


Phillip Crowder
Director, Corporate Sustainability
Winpak LTD

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