John, thanks very much.
Ladies and gentlemen, we appreciate being here today to talk about a subject that I assure you is very near and dear to PAC Packaging Consortium's heart.
Let me give you a little snapshot of who we are. We were founded in 1950 as the Packaging Association of Canada. We're a small not-for-profit corporation. Our member base and our corporate members include companies, government, academic institutions and individuals. We have 325 corporate members across the country. We go into the U.S. for membership as well. We have over 2,000 associates.
Or core mandate is to educate, advocate, collaborate and celebrate all safe and sustainable packaging materials and the associated systems. The key word there is “all” packaging. We're not here representing glass or plastic or fibre. We're here to speak on behalf of all packaging today.
We have a very small management team of less than 10 people, full time and part time.
I'm going to flash through our 10 minutes really quickly.
We don't like to think just about plastics and the plastics issue. We're really focused on all things to do with waste. What we mean by that, really, is that there are many non-plastic packaging materials that exist today and are recyclable and/or contain recycled content, but the recovery rates are low.
The single message I want to give you is that things that are already made of 100% recycled material and are collected at curbside are still not being recovered. As an example, folding cartons—cereal boxes—have very low rates in that regard. In fact, they're quite low compared to PET plastic and HDPE plastic. That's what our chart on this slide will quickly show you.
The problem of increasing recycling rates is systematic, including the package design, the consumer behaviour—all of us are consumers, and I call consumers the forgotten stakeholders—recovery and the recycling processes themselves.
The next slide is about plastics and how important they are in terms of the value chain. I'm not going to talk about the economic value of plastics because that has probably been addressed already, but in terms of packaging when it comes to food, what that symbolically tells you is that packaging zucchini takes you from one day on the shelf to five. Packaging of mangoes takes you from 20 days to 40. Fresh swordfish takes you from seven days to 12.
When you think about this in the environmental footprint context and holistically, and you associate everything else with that, packaging has a tremendous role, especially plastics packaging, in terms of the protection of food, and of course there is a great protection of all other products associated with that as well. Without packaging, quite simply, waste and the associated costs would skyrocket. Of course, education is vital to everybody, especially the influencers.
The next slide shows the core issues on our mind with regard to increased recovery of all packaging and plastics. There is a huge cost disparity between going into landfill and recycling. Recycling is a very expensive proposition, and it's a big issue. Package design and innovation are of course critical, because we have to be thinking about that at the front end of the process. We need to be thinking about that, and in our world we call that the “SEEscape design process”, where we think about it as circular. When we sit down and design something, we want to think about what's going to happen to it when it goes off into its next life as well.
A really critical issue is that of confused and disengaged consumers. That's a big one. Again, it's the forgotten stakeholder. Even packaging experts are very challenged when we get into this discussion.
As for what I want to say here about upgrading recovery facilities and reprocessing challenges, think about this: digital technology is incompatible with analog technology. In the world we live in, where we're seeing packaging design going on and we think it's cutting edge, we don't see the same kind of investment in the back end and the recovery end. That has to be in harmony. Otherwise.... This is a system. It's not just “design it right and the problem will go away”. That's not going to happen. Costs will come down when volume levels increase, so it's a question of scale as well.
What are we doing about it as an industry? The current slide shows you that the significant organizations in the world today that are in consumer packaged goods are really paying attention to this. They all have 2025 commitments with recovery, recycling, reusability.
I was in Walmart in Bentonville about three weeks ago. It was celebrating with a thousand people in the room. It called its initiative “Project Gigaton”. Project Gigaton talks about all things to do with the environment, but a key component is packaging. All of those other companies that you see there on that slide are suppliers to Walmart. What retailers do is that they help to drive the value chain and bring their supply chain along with it, so all of the major actors are involved.
The thing that's important about this, and I want you to understand this, is that global actors are designing for global markets, not just Canada. We shouldn't just be looking for a made in Canada solution. That's an important one. There is a very small market for these global companies, and we're part of it.
There's a huge knowledge, communication and motivation gap between the large organizations that I believe are doing it right, and the small, medium and offshore organizations that walk in your front door with the next greenest package in the world and who, if they haven't done their research, they don't have that capability. They don't have the skills set to talk that way. There's a big gap between what these big powerful organizations are doing and the smaller organizations.
What's PAC doing about it? We're publishing white papers on ocean plastics. The Ocean Wise folks have been in and we collaborated with them on this. We have packaging sustainability checklists that are design guides for people designing packaging. We've got our packaging innovation gateway. We're going to talk a little bit more about that in a couple of minutes. We have educational courses on package circularity.
We partner with CCME and we consult. I'm actually the vice-chair of the National Zero Waste Council from British Columbia, which has been before you. We're working with the City of Toronto on a pretty cool project. We're also heavily engaged with the Conference on Canadian Stewardship.
This is a typical event. By the way, I've given a lot of brochures and information about us to the clerk. There is one for May 30. It's an example of people we're bringing in to talk about disruptive innovation in plastics and packaging. All of our speakers are coming in from the U.S., such as Tom Szaky. If you haven't heard of Tom Szaky, he wasn't actually born in Canada but raised in Canada and now lives in the U.S. But look up Google Loop. It's an amazing initiative.
We've got people who are coming in who are piloting the separation of post-consumer polypropene and they're taking that back. They're turning it back into pure flakes, so it can be used in packing again.
We've got WestRock coming in, one of the largest fibre companies in the world that is now taking in coffee cups, which have been the evil packages of all time to recover and recycle. It's now taking them to eight mills. It's collecting them in eight cities in the U.S. at curbside, and it is taking them back and turning them into good products. The coffee cup solution is there, and we're going to be talking about that in Toronto on May 30.
We're looking at how government can help us. Stronger governance. We want to be part of the solution. We don't want just to be perceived as part of the problem.
When you form committees, don't just call us in like this. Have us sitting on that side of the table with you, so that we can help to collaborate and facilitate solutions. Harmonized policies are absolutely vital to success. Without harmonization across the country, we're not going to get to zero waste, so that we can communicate from province to province, municipality to municipality, and a consistent message to consumers.
Endorse a process that we're going to be starting very soon with the City of Toronto where we want to be a gatekeeper to help screen packages coming into the system. Drive investment. Help us with investments in recycling, in the back end, because that's a big area and big issue. Landfill bans are a big problem.
I have one more thing.
Good afternoon, everyone.
Éco Entreprises Québec is a private non-profit organization that represents companies in their responsibility to fund the net cost of municipal curbside recycling services. There are organizations like ours in other provinces aside from Quebec.
The mandate of Éco Entreprises Québec falls under the principle of extended producer responsibility and, for 13 years, our organization has been redoubling its efforts to push the limits of circularity in the recycling system.
We have submitted a brief for today's meeting, in which we address certain concerns and make recommendations on the four points of discussion. I will try to summarize them.
The first point raised is that of restrictions targeting certain single-use non-recyclable plastics and the industry's use of additives in the masterbatch. The use of additives, ink, mineral fillers and other products in plastic packaging is clearly problematic for their recyclability because there is a lack of transparency on that packaging's composition. The masterbatch is at the core of protection of packaged products, so the industry's use of additives in the manufacturing of packaging is not innocuous. There is also the whole issue of colour, as any pigmented plastic resin will be difficult to recycle or its mechanical recyclability will be limited.
We mustn't also forget the difficulties related to production costs and to the properties of plastic, which is a multi-use material. However, every polymer recycling cycle comes with a drop in quality of the resin in terms of its technical and aesthetic properties.
That is one of the reasons why Éco Entreprises Québec organized in early February, in Paris, a forum on plastic solutions with Citeo, our counterpart organization in France. That forum brought together more than 400 participants, including industry leaders, packaging manufacturers, businesses that market packaged products, recyclers, sorting centres and processors. To use the words of Mr. Downham, the objective was to bring all the system stakeholders to the same table to find solutions for plastics recycling, starting with the packaging design stage.
Encouraging businesses to use recycled content in plastic packaging would help stimulate local economies by creating local opportunities for plastic resins, while reducing the exporting of those materials. The use of recycled content presupposes access to quality materials that are recycled at a good price and whose supply is stable. As long as virgin material remains less expensive than recycled material, businesses will use virgin material, especially since recycled material has not yet become popular in people's minds.
I want to point out that, in 2009, Éco Entreprises Québec was the first environmental organization in the world to implement a credit for the recycled content of certain types of printed materials and certain types of plastic packaging, including PET and HDPE.
The issue we are discussing today is plastic, but I want to tell you that our organization is also interested in other materials. As Mr. Downham pointed out, fibre or glass packaging also presents challenges, and so the system should be addressed as a whole, with all its complexity.
Éco Entreprises Québec is very involved in innovation. About 40 individuals are supporting packaging ecodesign businesses, and we are providing training and personalized support. We are helping municipalities achieve a good PE—performance, effectiveness—factor for their activities of collection, sorting, and recycling of recyclable materials. We are also investing in sorting centres to improve their technology, in addition to supporting the creation of local opportunities.
In order to reduce the presence of ink and additives in packaging, a better job must be done of targeting businesses that design them. We have to start by reviewing the protection provided by that packaging, while avoiding its weakening by eliminating certain important additives, which could lead to more food waste or product breakage.
When it comes to the last point, innovation, it is important to encourage knowledge transfer and to build bridges between provinces and various administrations. I know that the federal government already has experience with providing training.
Let's take the example of plastic microbeads. We are supporting many businesses in that process. Similar programs should be developed. It is not enough to focus on single-use plastic packaging. The problem related to plastics is much more complex. The circularity of plastics must be understood. Plastic used for the first time in packaging can have a second life as a textile or a sustainable product, such as street furniture.
We should consider the system with open loops and determine whether recycled resin can supply other activity sectors, especially in packaging. It should be understood that some health and safety issues are involved. Polyethylene terephthalate, or PET, is the only resin that is currently subject to a no-objection letter regarding its use in the manufacturing of packaging in contact with food. So it is impossible to integrate recycled content into food packaging composed of other types of plastic resins.
We recommend that this innovation be financially supported. Mr. Downham provided some examples earlier. In the area of molecular recycling, businesses are starting up. There are some great ones in Canada that are performing very well on the global stage, and it is important to support them. After all, molecular and chemical recycling has been a promising option that has complemented the mechanical recycling of plastics for a number of years.
I agree with Mr. Downham that things must be considered in a global context, at least for the North American market, as material movement goes beyond Canadian borders.
Those are the various points I wanted to present to you.
I'm just reading it from the computer, which is why I have it open in front of me.
Thank you, members of the committee, for the opportunity to present here. I'm Keith Brooks, and I'll be presenting for Environmental Defence. Vito, my colleague, is here to help answer questions.
We are a national charity based in Toronto, and we have an office here in Ottawa. We work on climate change, fresh water, toxics, plastics and advocating to protect Ontario's greenbelt.
We began our stand-alone plastics program in 2018, in response to the immense public outcry that something needed to be done about plastics. We note that this government has been talking about doing something about plastics for awhile, which is encouraging. We are happy to be here in front of this committee.
We acknowledge that plastics are a contributor to increasing standards of living, and have many extremely innovative and important uses in modern society. There is, however, a downside to the proliferation of plastic, especially of single-use plastics. We're going to focus our remarks today on single-use plastics, which are products and packaging used only once or for a very short period of time.
Some of the most durable material in the world is manufactured to be used once and then thrown away. There's an issue here. At this time, we think efforts to curb the negative impact of plastics should be focused on single-use plastics, and in particular, plastic packaging. This is not to say that other plastics are free from being problematic. The plastics industry uses hundreds of toxic additives to modify the properties of plastic materials. The European Chemicals Agency recently identified over 400 chemicals of concern that are used as plastic additives, such as flame retardants, plasticizers and UV filters.
We have been advocating for changes to the Canadian Environmental Protection Act, or CEPA, to ensure that it would better address and protect Canadians from these and other toxic chemicals, but that's a discussion for another day.
Shoreline cleanups, litter audits and pretty much all of the research done on this tell us that much of the most visible plastic pollution threatening wildlife is related to these single-use plastics and plastic packaging. Although Canada has been a front-runner in tackling plastic pollution by declaring microbeads toxic and banning them from most consumer products, not enough has been done to deal with other problematic sources of plastic pollution.
In fact, Canada continues to subsidize the production of plastics, in many cases. For example, a very recent gift of $49 million to the Canada Kuwait Petrochemical Corporation was announced. By mid-2030, this facility is going to be processing 23,000 barrels of propane each day and turning it into polypropylene to make products, some of which will be single-use plastics, such as plastic packaging. We're actually subsidizing the production of more single-use plastic packaging.
These subsidies, and the production of virgin plastics, has to stop. The subsidies are, in particular, working at cross purposes with the objective we have of moving toward a circular economy, where we're using old plastics in the manufacture of new plastics, and moving away from using virgin fossil fuels to produce single-use plastics that then get thrown out.
We think the federal government should be supporting a move to a circular economy, in part by fixing Canada's broken recycling industry, to ensure that Canadians' efforts to recycle are not in vain. A report recently done by Deloitte on behalf of Environment and Climate Change Canada, as I'm sure everyone here knows, reported that Canadians recycle only 9% of the plastics we use in this country.
That same report argues that only 1% of that plastic is leaking into the environment, but in this case, that's 29,000 tonnes of plastic leaking into the environment every year. We are contributors to this global plastics pollution problem in its worst manifestation, which is leakage into the environment. We think that 29,000 tonnes number is probably an underestimate. Regardless, it's not acceptable. We can and must do better.
In addition to avoiding the loss of billions of dollars of valuable plastic to the environment or landfills, recycling plastics is more climate friendly. A study published in January of this year shows that recycled plastic reduces energy consumption by 79% for PET, 88% for HDPE and 88% for polypropylene. According to this study, recycled resin can cut emissions over virgin materials between 67% and 71% for a variety of plastics. It has a significant impact on climate change as well.
Polls indicate that Canadians support take-back schemes and bans on single-use plastics, to ensure that plastics stay out of the environment, and to increase our recycling rates. It's our view that if this government doesn't include bans of some plastics in its strategy for dealing with plastics, Canadians will reject the strategy as inadequate. Environmental groups certainly will. This is not to say we're calling for a ban on all plastics, but bans certainly have a part in the strategy this government and the nation needs to come up with.
All levels of government, of course, have a role to play in solving this problem, and many provincial governments will be moving in the near future towards extended producer responsibility schemes. We'll do what we can to support that, and to support it in Ontario in particular, where most of our efforts our concentrated, but it's very important that the federal government ensures there is a level playing field among the provinces.
In May 2018, Environmental Defence brought together 15 major environmental and civil society groups from across Canada to draft a joint declaration on plastics. That declaration now has over 40 signatories. It's been submitted to the federal government for consideration. Based on that declaration, we would recommend the following.
The Canadian government should set binding collection targets for categories of plastic packaging items. Producers should be responsible for reaching these collection targets.
Ban plastic products that have a negative impact on the environment. The EU single-use plastic list of bans could be a good place for Canada to start.
Require progressively increasing recycled content in plastic products and packaging. This is to ensure there is a demand for recycled content and that we're creating a circular economy and using old plastics to create new plastics instead of virgin fossil fuels to create single-use plastics that then get thrown out.
We need to ban problematic polymers such as polyvinyl chloride, polystyrene, and additives such as phthalates that put human health and the environment at risk and can impair the recyclability of these plastics as well.
Finally, set enforcement mechanisms and data collection requirements to ensure that these provisions are complied with.
All these measures will need to recognize that some plastic items, namely single-use plastics and some plastic materials such as those containing toxic additives, as well as PVC and polystyrene, should be recognized as toxic under the CEPA, the Canadian Environmental Protection Act. That, incidentally, was the mechanism that was used to ban microbeads. For this reason, Environmental Defence and some of the other environmental organizations that signed on to our declaration submitted a request to the federal government in June 2018 to add single-use plastics, microplastics and microfibres to the priority substance list for assessing whether they are toxic or capable of becoming toxic under CEPA. To date we have not heard back as to how the Canadian government is treating this request, despite a requirement under CEPA to provide a response within 90 days of a request being submitted. Therefore, we are following up on that request to find out what the government intends to do. Following listing as toxic, the federal government would then have powers to put in place a broad variety of measures, including those to mitigate risks and reduce the environmental impacts of plastics.
We welcome any questions that you have. Thanks for your time.
Plastics reduction is truly a global challenge. We know that plastics also have a role to play, if they are properly and appropriately managed.
We think that Canada is well-positioned, thanks to its recycling infrastructure, to accept the challenge. From retailers' point of view, we support plastics management through the three Rs hierarchy: first, prevention through reduction, then repurposing and reuse, and then recycling. Following that would be compostables. Finally, there is the landfill, which is the last resort.
Plastics are recognized for their light weight and light look, which means that many businesses will use them. That also may lead to a better GHG balance for their transportation, since they are lighter. However, their weight and their small size create their own set of challenges in the sorting and recycling stages.
Although most types of plastics are recyclable, and despite recent innovations—including in molecular recycling—as my two colleagues were saying earlier, there are various opportunities to improve the recyclability of the most problematic categories, such as polystyrene. The fact remains that for us, retailers, plastics help both extend the life of fresh foods, as Mr. Downham mentioned earlier, and meet the food safety standards, which involve very clear restrictions in terms of materials.
The consumer also really plays a key role here. If the consumer does not participate, nothing works. So it may be worthwhile to launch an education and awareness campaign for Canadians based on the science concerning plastics in order to rebalance perceptions by highlighting considerations such as the benefits and properties of those materials.
I thank all the witnesses.
I really appreciate your suggestions. This is a very complex issue with numerous aspects.
Today, I would like to focus on your comments and your recommendations. I assume that our committee will soon have to recommend very concrete, very specific measures, and that it will have to go beyond the principles of circular economy, among other things. We may agree that it is a good idea to go with circular economy, but sometimes very concrete decisions have to be made to get there.
I would like to put my first question to Mr. Telfer and Mr. Cantin, whom I will ask to answer briefly, as we have very little time.
As far as I understand, you feel that the harmonization issue is very important, be it on a provincial or a national level, or even on an international level. Should it be surmised that it could be very good for the federal government to think about establishing national standards? That would create certainty within industry and within Canadian communities. Should Canadian authorities move forward with those standards?
I can tell you what we're doing. I think it's a model for the future for us. Essentially, we started the packaging innovation gateway about four years ago. It was really all about helping brand owners take a new product and get it through the system, so that it went all the way through and into its next life. It was called the packaging innovation gateway.
It was a very informal process. We identified 15 problematic materials. It was all very nice. We had what I call “transparent collaboration”, where we had brand owners, retailers, package makers, waste management and municipalities—no provincial or federal representatives, but municipalities, because they're the primary folks who are handling and recovering the materials.
It was a very good process. The problem with it was that it wasn't collaboration; it was co-operation. We were able to bring everybody together, and they were saying that, yes, this is nice, but it was a lot of talk and no action.
We're taking it to the next level. We've modified the name to the “packaging innovation pathway”. We're starting with municipalities and with brand owners and we're going to put together a formal process whereby we can create a standard—I don't like to use the word “watchdog”—whereby we can certify packaging materials. We're going to talk about the circular economy. We'll talk about it in the circular context. A package may be a 360 or it maybe be a 270; it may be a 180 or a 90. The idea is to look at all of these packaging materials as they're coming through and we're going to give it that standard and assign it.
When a brand new product comes in and they walk in to see my friend Luc Lortie at Costco and say that it's the greenest, greatest product in the world made from bamboo or whatever, he has no clue what to do with it because he doesn't have the capability inside. He'll tell them to go and see the packaging innovation pathway, get it certified, bring it back to him, and then he'll buy it once he knows that there's a certification on it.
Our vision for this is a national body. It's a national initiative. Everybody is welcome to participate. We're forming right now. We've got our first meeting on May 17. We have the City of Toronto involved with it. We have municipalities. We've talked to Montreal. We're in discussions with Vancouver. We're talking to folks like Procter & Gamble and Molson Coors. That's where we're trying to take this thing.
Plastic is a material that behaves similarly to fibre packaging. A fibre gets shorter with every recycling cycle. So you start with one sheet of paper and turn it into a product with an increasingly short fibre, up to egg packaging, for example.
For plastic, the situation is the same, its fibres will get shorter with every cycle, once mechanical recycling has been initiated. There are limits, as we were saying earlier: mechanical recycling does not make it possible to eliminate ink and all the additives found in plastics.
In addition, certain forming processes—such as extrusion, though I do not want to get into technical details—mean that we are limited in terms of the material obtained at the end of this mechanical recycling process.
Molecular recycling makes it possible to go much further. Molecular recycling could be broken down into different things. We could go back all the way to the monomer, to the raw solution of the monomer plastic where polymer chains will be redone to remake them into plastics. Any inks or additives can be eliminated.
The interesting aspect of molecular recycling—we were talking about it as a complementary process—was that it can resolve the problem of any flexible packaging, any laminated and complex packaging containing amalgams of various types of resins.
There are advances being made all the time in plastics packaging. There are now laminated plastics out there that are compatible with polyethylene plastic recycling. In other words, those multi-laminated plastic pouches everybody loves to hate are now being made in multiple layers of a material with a barrier layer that's compatible, so it can go in with the plastic bags you're getting out of your grocery store.
The innovations are coming so fast from the packaging industry and from the likes of Dow and others that are creating these new things that by stepping back and saying let's ban things.... Polystyrene is a prime example.
There are three companies right in Canada, in Montreal, that are now taking polystyrene, EPS, and recycling it back down to the monomer level to create styrene that they can make back into polystyrene. By saying, “Oh you can't do that anymore”, what we're doing is stifling our own industry development. We're losing the opportunity to do something with all of this packaging.
If I were to choose a plastic, the ones that are most commonly recycled and worth the most and that you can do the most with, I would say it's clear plastic. I'm talking about clear as in having no colour in PET bottles and bottle grade, not thermoformed—not the things you get out of your bakery aisle. Those are very complicated to recycle.
HDPE natural, a milk jug, and polypropylene natural, so anything that's in.... It's almost white. It's semi-translucent in polypropylene. They tend to have the least amount of things in them, and you can do the most with them. They also tend to have the highest recycling rates today of all the materials. It doesn't mean we can't get them higher, but they have the most opportunity when they're captured. They can be recycled mechanically very successfully.
PET is going back into bottle grade. If you go into a Loblaws or a Walmart, that 24 pack of water is 100% recycled content, PET, so it can be done.
That's really good question. I have been around in Ontario drinking beer for a long time, so I know this system real well.
I think this is the best way to answer your question. Look at the way beer was marketed in Ontario through the Beer Store. The Beer Store is owned by the brewers. Basically, they went into that business in 1925 because of prohibition. I wasn't around then. They were forced into it. It was all about distribution and recovery.
The Beer Store was set up so you go to the Beer Store, buy your beer, take it home, put the box in the corner, put the bottles back in there and then you take the box back. That's the way it was in Ontario, with standard bottles, a standard 24 pack and standard cans—standard everything.
But guess what's happening? Laws are changing. The brewers are not changing; the laws are changing. The first thing they did in Ontario was that the Liberal government said that they're going to start to sell those products into the LCBO, but it can only sell this amount. That disrupts the distribution and recovery system. You still pay a deposit on that bottle, but if you buy a six-pack in the liquor store, you're probably not going to take it back to the Beer Store, and that's what happens. It ends up in the garbage or in the waste stream and it could contaminate the blue box.
Now another law is coming in from the Ontario government. The other guys—the Conservatives—are now going to start selling it in convenient stores. The greatest model in the world—the Beer Store, which has been around forever—is going to be disrupted dramatically because of regulation.
I'll leave that with you as a cautionary tale. It's true. Those recovery rates are so huge and the reason it's being disrupted is that all of the other beers are now coming in from all over the world. Guess what? They come in different formats. They come in different glass bottles. They come in different closures. There's no standard beer bottle anymore. There's no standard beer case of 24 or 12 or six. It's all changing. You just can't control it.
What you're asking is very difficult.
I think the point that I was trying to make earlier with the image of Walmart and all of those logos on the slide was to communicate to you that the big, powerful packaged goods companies and retailers out there, certainly in Canada, are very responsible citizens. They're doing great work, and they're doing great things.
Let me give you an example. A month ago we saw a publication about a person who is a very high-profile individual and was talking about compostable packaging. This person was a subject-matter expert on writing cookbooks but had no clue about the packaging.
The reality is that the packaging was not compostable at all. It was probably brought in from offshore, and it was probably brought in from somebody from a small or medium-sized organization who walked in and said, “This is a green product. This is an eco”—they have all kinds of words for it, right?
Procter & Gamble and those companies would never do that stuff. I assure you, they just wouldn't, but those other companies would because they're entrepreneurs. They see a green package. They saw it online somewhere. They're going to start importing it. They go into business.
We have to figure out a way to manage that better, to educate those people and to control that. I don't have an easy answer for you on that. I really don't.