Current Advocacy Efforts
CHFA actively participates in a Trade Association Working Group focused on sustainability and maintains continuous engagement in upcoming opportunities for consultations and advocacy that directly impact our members. Some key updates and actions include:
- In spring 2023, ECCC published a proposed regulatory framework on recycled content and labelling. CHFA promptly submitted Feedback on the Recycled Content and Labelling Rules for Plastics: Regulatory Framework Paper in May 2023. ECCC intends to review the feedback received from stakeholders and subsequently release draft regulations on recycled content and labelling in Canada Gazette, Part I, allowing for public comment before the end of 2023. At this time, the final regulations are on hold until further notice due to a federal court ruling. This ruling is connected to ECCC adding Plastic Manufactured Items (PMI) to the list of toxic substances in Schedule 1 of the Canadian Environmental Protection Act, 1999. The federal court believes this action was unreasonable and unconstitutional as it is too broad of a category.
- Additionally, ECCC released a proposal for the plastics registry in Spring 2023. CHFA actively participated by providing Feedback on the Federal Plastics Registry Consultation in May 2023. The next steps involve the targeted publication of a draft section 46 notice, also known as an information gathering survey in Canada Gazette, Part I. ECCC is hosting a public comment period, leading to the publication of the final notice in the Canada Gazette, Part I. CHFA is reviewing the plastics registry and will be advocating to ensure that the implementation process does not cause a significant burden on industry.
- ECCC published a new consultation paper in August 2023 covering targets for the reduction, reuse, redesign, and recycled content of primary food plastic packaging. This notice would set requirements for Canada's largest grocery retailers to prepare and implement a pollution prevention plan (P2 plan), aiming for zero plastic waste from primary food plastic packaging. The final notice is expected to be published in Canada Gazette I however, this is currently on hold due to the federal court hearing. CHFA actively participated in the most recent consultation by providing Feedback on the Primary Food Plastics Packaging Consultation in August 2023.
- In July 2024, Health Canada started to review its voluntary food packaging program to understand the regulatory challenges faced by industry, and investigate methods for reducing plastic waste. They are exploring options for a mandatory chemical safety program for food packaging materials by March 2027. CHFA participated by sharing feedback based on member insights and recommendations.
Through these proceedings, CHFA strives to contribute valuable input and insight to the ongoing discussions surrounding the labelling of recycled content and developing a plastics registry. These efforts align with our commitment to support our members and work towards achieving reasonable sustainability targets.