As part of Canada’s plan to move toward the goal of zero plastic waste by 2030, the Government of Canada is seeking to reduce plastic pollution and move Canada towards a circular economy that keeps plastic in the economy and out of the environment. This plan includes establishing a Federal Plastics Registry that will require producers to report annually on the quantity and types of plastic they place on the Canadian market, how it moves through the economy, and, most importantly, how it is managed at its end-of-life.
As previously reported to members, CA’s has been engaged in the government’s consultations to date regarding a plastics registry including their initial July 2022 Consultation paper: a proposed federal plastics registry for producers of plastic products and their more recent Technical paper: Federal Plastics Registry published in April 2023.
The next step in this process was taken on December 30, 2023 with the government’s publication in the Canada Gazette, Part I of a Notice of intent to issue a section 46 notice under CEPA with respect to reporting of certain plastic products. This will begin the creation of an inventory of data. “The goal of the Registry is to collect information to support actions to prevent plastic pollution, helping to keep plastics in the economy and out of the environment. The section 46 notice would require producers of plastic products to provide the Minister of the Environment with information about the lifecycle of plastics in Canada. Through the Notice we are looking to collect information on a large sector of the economy and provide Canadians with meaningful and standardized data on plastic from production to end-of-life across the country that can inform and measure actions to prevent plastic pollution.”
Although NO ACTION is needed from members presently, in reviewing this Notice, members can begin to prepare for the formal launch of this survey, likely in early spring (April 2024), by getting a sense as to the type of information that the government is seeking to gather.
Importantly, members should consider their relationships with any Producer Responsibility Organizations (PROs) used to meet their obligations under the various provincial Extended Producer Responsibility (EPR) programs as there will be provisions for ‘producers’ to request information be submitted on their behalf by PROs. Initiating early discussions with your PROs to see, what, if anything they are doing in relation to this Registry, could be very helpful in helping to plan your engagement with the Registry moving forward.
Important Note:
At present, the proposal extends to household products as well as institutional, commercial, and industrial (IC&I) products. This is a very big scope, with IC&I data being much more difficult to identify. Cosmetics Alliance is seeking clarity on this scope and asking officials for a preliminary ‘carve-out’ for IC&I data to allow more time for data collection. CA is also seeking clarity on definitions and process to address how ‘information readily available in your possession’ will be defined. This will clarify expectations for engagement, particularly with regards to ‘end of life’ data that will be better accessed through the waste collection and recycler community.
The survey data will be critical in shaping a comprehensive approach to material circularity, which in turn, should inform regulatory policies regarding plastic waste, recyclability, and sustainability. Most importantly, a federally coordinated approach (if designed and implemented in close collaboration and coordination with Provincial/Territorial/ Municipal authorities) is critical to avoid a patch work of waste management policies across the Canadian landscape.
CA is currently assessing the Notice with our Technical Committees, and preparing comments on behalf of the membership. We will keep members informed of developments.
