Proposed integrated management approach to plastic products – what we heard

Official title: A proposed integrated management approach to plastic products to prevent waste and pollution – What we heard report

Introduction – Why we consulted Canadians

Plastic is polluting our rivers, lakes, and oceans, harming wildlife, and generating microplastics in the water we use and drink. Every year, Canadians throw away 3 million tonnes of plastic waste, only 9% of which is recycled, meaning the vast majority of plastics end up in landfills. In 2016, about 29,000 tonnes of plastic waste found its way into our natural environment. At the same time, Canada is able to reap significant benefits from reducing, reusing, remanufacturing and recycling plastics by transitioning to a circular economy that promotes innovation, resource efficiency and clean growth. Achieving zero plastic waste by 2030 could create up to 42,000 direct and indirect jobs and reduce annual greenhouse gas emissions by 1.8 megatonnes.

In November 2018, through the Canadian Council of Ministers of the Environment, the federal, provincial and territorial governments approved in principle a Canada-wide Strategy on Zero Plastic Waste. The Strategy builds on the Ocean Plastics Charter, and takes a circular economy approach to plastics and provides a framework for action in Canada.

In October 2020, the Government of Canada published a discussion paper outlining an integrated management approach to plastic products to prevent waste and pollution.Footnote 1  The discussion paper outlined the important role all partners and stakeholders can play in achieving zero plastic waste and eliminating plastic pollution, including federal, provincial and territorial governments, Indigenous Peoples, industry, civil society and individual Canadians. The paper explained how no one measure can overcome the systemic challenges standing in the way of a circular economy for plastics, and that change was needed across the plastics value chain, including:

The Government also proposed three initiatives to help effect these changes:

The Government then sought input from partners, stakeholders and Canadians to help inform the development of these measures. This What We Heard report details how the Government sought input, who provided input, and what was said. In addition, it outlines next steps for the Government’s integrated management approach as it works towards achieving zero plastic waste by 2030.

How we consulted

A public consultation period on the integrated management approach was held between October 7 and December 9, 2020. Consultations were held entirely online to facilitate national participation and due to restrictions caused by the COVID-19 pandemic. Consultation activities included:

The consultation was advertised using the Department’s social media accounts, including regular posts on Twitter and Facebook.

Further information: consultation approach and recordings of the webinars.

Figure 1: Twitter post from October 7, 2020
Figure 1: Twitter post from October 7, 2020
Long description

Figure 1 provides a screenshot of a tweet published to the official Environment and Climate Change Canada Twitter account page on October 7th, 2020. Checkout bags, straws, cutlery, ring carrier, stir sticks and problematic foodservice ware are identified as single-use plastic items with viable easy alternatives but which are harmful to our environment. The following examples of reusable alternatives are presented: reusable bag, metal cutlery, cardboard six pack rings, reusable take out containers, reusable and paper straws. The tweet announces that Canada is proposing to ban these items.

Consultation activities
Consultation method Topic Dates
Written comments All topics October 7 – December 9
Webinar 1 Overview of proposed integrated management approach to plastic products to prevent waste and pollution October 30
Webinar 2 Managing single-use plastics (Part 1) November 6
Stakeholder discussion session 1 Alternatives and limitations to single-use plastics and non-conventional plastics November 6
Webinar 3 Managing single-use plastics (Part 2) November 13
Stakeholder discussion session 2 Jurisdictional approaches and distributional impacts of proposed restrictions or bans on single-use plastic products November 13
Webinar 4 Establishing performance standards November 20
Stakeholder discussion session 3 Various proposed approaches to establishing recycled content requirements, as well as associated opportunities and barriers November 20
Webinar 5 Discussion on key technical topics raised in webinars 1-4 November 27
Stakeholder discussion session 4 Definitions and the scope of instruments; exemptions; proposed options for extended producer responsibility November 27
Indigenous engagement session Webinar and question-and-answer session for Indigenous Peoples January 8

Who participated

Participation was high across each of the consultation opportunities described above, with a broad range of industry sectors, non-governmental organizations, governments and individuals represented. The Government of Canada wishes to thank everyone who provided input.

The following section provides a breakdown of who participated in the different consultation opportunities provided.

Written comments on the discussion paper

In total, the Government received written comments representing the views of 245 stakeholders and partners in the following categories (see Figure 2):Footnote 2 

Figure 2: Breakdown of stakeholders that provided written comments on the discussion paper
Figure 2: Breakdown of stakeholders that provided written comments on the discussion paper
Long description

Figure 2 is a ring pie chart that provides a breakdown of those stakeholders and partners who provided written comments on the discussion paper during the consultation period. Of the 245 comments received, 151 were from industry, 39 were from Governments, 32 were from civil society, 21 were from other sources and two were from Indigenous peoples.

Figure 3: Industry stakeholder comments and their position on the plastics value chain
Figure 3: Industry stakeholder comments and their position on the plastics value chain
Long description

Figure 3 provides a continuous block process graphic that outlines industry stakeholder comments and their position on the plastics value chain.

5 different categories of industry stakeholders are identified. These include: resin producers; manufacturers and importers; brand owners; distributors, retailers and restaurants; and those involved in end-of-life management.

For resin producers, 20 plastic resin producers and 4 industry associations provided comments.

For manufacturers and importers, 37 manufacturers, 1 importer and 13 associations provided comments.

For brand owners, 11 different brand owners and 17 industry associations provided comments.

For distributors, retailers and restaurants, 5 individual companies and 14 industry associations provided comments.

For those involved in end-of-life management, 8 individual companies and 9 industry associations provided comments.

In addition, comments were received from 13 industry associations representing various points in the value chain.

Figure 3 shows that comments received were from companies and industry associations situated at almost every point in the plastics value chain.

Webinars

Webinars were open to anyone who registered and were hosted over Zoom. Participation is reflected in Figure 4 (below), which shows the number of participants for each webinar, as well as the number of questions and comments that were either submitted in advance by a registered participant, or during the Zoom webinar using the chat function.

Over 6,000 stakeholders received the email invitations to participate in the public webinar sessions and details and registration information were posted on the ECCC consultation webpage. Over 700 participants representing a number of different stakeholder categories (primarily industry, government and civil society organizations) and sectors participated in at least one session, with many participating in several sessions. Overall participation across all sessions totalled 1,474 participants.

Figure 4: Webinar participants, questions and comments
Figure 4: Webinar participants, questions and comments
Long description

Figure 4 is a bar graph broken down into 5 categories showing both the number of participants and number of questions and comments received during each of the five different webinars that took place over the course of the consultation period.

Webinar 1 on October 30th, 2020 had 386 participants and registered 161 questions and comments received.

Webinar 2 on November 6th, 2020 had 298 participants and 126 questions and comments received.

Webinar 3 on November 13th, 2020 saw 234 participants and 56 questions and comments received.

Webinar 4 on November 20th, 2020 had 200 participants and 61 questions and comments received.

Webinar 5 on November 27th, 2020 had 193 participants while also recording 57 questions and comments received.

Stakeholder discussion sessions

For the targeted stakeholder discussions, approximately 100 to 150 participants representing a wide variety of stakeholders, were invited to each webinar. As shown in Figure 5 below, there were

Figure 5: Participants in stakeholder discussion sessions
Figure 5: Participants in stakeholder discussion sessions
Long description

Figure 5 provides a bar graph that details the number of participants in each of the four discussion sessions that took place and which category of stakeholder or partner identified.

Eight different categories of stakeholders or partners are identified in the graph. These include: Academia; Government; Industry; Manufacturing; Civil Society; Waste and Recycling; Retailers and Brand Owners; and Producers and Suppliers.

During Session 1 on November 6th, 2020, 43 participants attended. Of these:

  • 1 was from Academia
  • 1 was from Government
  • 6 were from Industry
  • 13 were from Manufacturing
  • 8 were from Civil Society
  • 3 were from Waste and Recycling
  • 8 were Retailers and Brand Owners
  • 3 were Producers and suppliers

During Session 2 on November 13th, 2020, 49 participants attended. Of these:

  • 1 was from Academia
  • 2 were from Government
  • 7 were from Industry
  • 12 were from Manufacturing
  • 11 were from Civil Society
  • 2 were from Waste and Recycling
  • 9 were Retailers and Brand Owners
  • 3 were Producers and Suppliers

During Session 3 on November 20th, 2020, 39 participants attended. Of these:

  • 1 was from Academia
  • 1 was from Government
  • 2 were from Industry
  • 16 were from Manufacturing
  • 8 were from Civil Society
  • 5 were from Waste and Recycling
  • 5 were Retailers and Brand Owners
  • 1 were Producers and Suppliers

During Session 4 on November 27th, 2020, 34 participants attended. Of these:

  • 4 were from Government
  • 5 were from Industry
  • 10 were from Manufacturing
  • 5 were from Civil Society
  • 3 were from Waste and Recycling
  • 5 were Retailers and Brand Owners
  • 2 were Producers and Suppliers

Input from the public

In addition to the above input, the Government of Canada received thousands of emails from individual Canadians expressing their opinions on the proposed integrated management approach. Many of these emails were facilitated by environmental and industry organizations such as Greenpeace, Environmental Defence, and the Chemistry Industry Association of Canada. In total, the Government received over 24,000 emails from individual Canadians. Of these, approximately 350 were opposed to the Government’s integrated management approach, while the rest were supportive or urged the Government to do more.

Thousands of Canadians also made their voices heard through online petitions. For example, a petition supporting the Government’s integrated management approach, including the proposed ban on certain single-use plastics, hosted on the online platform Change.org and started by environmental organization Oceana collected over 100,000 signatures.Footnote 3

What we heard

This section presents a summary of comments received on the integrated management approach as outlined in the discussion paper. It summarizes a large number of comments received, and is not intended to be attributed to specific organizations or individuals. The Government of Canada also received comments on the draft Order-in-Council proposing to add “plastic manufactured items” to Schedule 1 of the Canadian Environmental Protection Act, 1999.Footnote 2

What we heard on the integrated management approach

What we heard on managing single-use plastics

What we heard on establishing performance standards

What we heard on ensuring end-of-life responsibility

Next steps

Next steps for each of the categories of actions outlined in the integrated management approach
Category Next step
Managing single-use plastics Publish draft regulations for consultations on banning or restricting certain single-use plastics
Establishing performance standards Further consultations on key elements of minimum recycled content requirements
Ensuring end-of-life responsibility Canadian Council of Ministers of the Environment to publish guidance to facilitate consistent extended producer responsibility

Draft regulations on banning or restricting certain single-use plastics will be published in Canada Gazette, Part I for a 75-day public comment period. Draft regulations are always accompanied by a Regulatory Impact Analysis Statement (RIAS). The RIAS includes detailed analysis of the potential effects of the proposed measure, including estimates of costs and benefits, a strategic environmental assessment, the application of a small business lens, and a gender-based analysis plus.

Appendix: Questions for discussion

The following questions were included in the discussion paper to help focus input:

Managing single-use plastics

  1. Are there any other sources of data or other evidence that could help inform the development of the regulations to ban or restrict certain harmful single-use plastics?
  2. Would banning or restricting any of the 6 single-use plastics identified impact the health or safety of any communities or segments of Canadian society?
  3. How can the government best reflect the needs of people with disabilities in its actions to ban or restrict certain harmful single-use plastics?
  4. Should innovative or non-conventional plastics, such as compostable, bio-based or biodegradable plastics be exempted from a ban or a restriction on certain harmful single-use plastics? If so, what should be considered in developing an exemption that maintains the objectives of environmental protection and fostering a circular economy for plastics?

Establishing performance standards

  1. What minimum percentage of recycled content in plastic products would make a meaningful impact on secondary (recycled resin) markets?
  2. For which resins, products, and/or sectors would minimum recycled content requirements make the greatest positive impact on secondary (recycled resin) markets? Why?
  3. Which resins, products or sectors are best-placed to increase the use of recycled plastic and why?
  4. Which plastic products are not suitable for using recycled content due to health, safety, regulatory, technical or other concerns?
  5. What should be considered in developing timelines for minimum recycled content requirements in different products?
  6. What would be the advantages and disadvantages to setting minimum percentage requirements that are distinct for each product grouping, sector, and/or resin?
  7. How could compliance with minimum recycled content requirements be verified? How can the Government and industry take advantage of innovative technologies or business practices to improve accuracy of verification while minimizing the administrative burden on companies?
  8. Besides minimum recycled content requirements, what additional actions by the government could incentivize the use of recycled content in plastic products?

Ensuring end-of-life responsibility

  1. How can the Government of Canada best support provinces and territories in making their extended producer responsibility policies consistent, comprehensive, and transparent?
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