Avis d'opposition : Polytainers Inc. - Février 2022

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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 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

Polytainers Inc. has provided thin wall, rigid plastic packaging to support the food industry for 50+ years. We take great pride in having introduced many sustainability firsts to the marketplace through our constant investment in technology and our commitment to value- engineering. We are grounded in the principle that sustainability begins with designing with less in mind, which is why we provide food companies with some of the lightest packaging without compromising food safety and operational efficiency with the end goal of reducing resin usage and keeping costs from rising.

Polytainers Inc. 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.

Polytainers Inc. formally objects to the Proposed Single-Use Plastics Prohibition Regulations and requests the establishment of a Board of Review to review the recommendation

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

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

Impacts of Substitutes not Considered

Environmental Assumptions Lack Scientific Rigour

Polytainers Inc. recognizes the importance of addressing plastic waste and understands that industry must play its part to contribute to solutions. We share the common objective to create a circular economy for plastics and divert plastics from landfills. Polytainers in committed to working with governments and other organizations to implement an innovative, forward-looking plan to create a circular economy for plastics through improved product design, enhanced recovery systems, and augmented end-markets for post-consumer plastics.

Polytainers Inc. remains highly concerned with the proposed regulation as it does not support a circular economy for plastics nor provide effective measures in Canada to prevent leakage into the environment. Moreover, the proposed approach will have negative consequences on Canada’s economic recovery and industry’s growth prospects to advance towards a circular economy for plastics. Industry remains committed to working with governments to introduce solutions that leverage private sector innovations and economic opportunities in alignment with environmental goals aimed at achieving a circular economy for plastics.



Robert K. Barrett
President & CEO

cc: James Maloney, MP Etobicoke-Lakeshore

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