Sustainability

In October 2020, Environment and Climate Change Canada (ECCC) unveiled a series of proposed measures to achieve the government's objective of zero plastic waste by 2030. Among these measures was the proposal to ban or restrict certain single-use plastics.

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 December 2024, the Competition Bureau published a draft guideline for provisions related to the Deceptive Marketing Practices section on Bill C59. This guideline was developed to clarify how the new anti-greenwashing and general deceptive marketing provisions will be enforced. The draft also outlined key terms such as what is considered adequate and proper testing and an internationally recognized methodology. CHFA provided feedback which emphasized the need for flexibility in the new provisions, particularly to accommodate the potential challenges faced by small and medium-sized businesses in Canada. In consideration of SME’s ability to innovate and grow in the sustainability space, we encouraged further access to resources, education, and an adequate timeline to adapt to any upcoming changes. We also requested revisions to the definition of internationally recognized methodology to avoid adding further pressure and costs to an already strained industry. To learn more, click here.
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, to learn more click here.
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. CHFA provided initial comments on the draft Guide for Reporting to the Federal Plastics Registry and will be reviewing the final version when it is published. We repeated our opposition for producers to annually report the quantity and types of plastic they place on the Canadian market, expressed concerns on the duplicative efforts across EPR reporting portals, inclusion of Institutional, Commercial, and Industrial (ICI) waste streams in reporting, and the proposed implementation timeline. CHFA will continue its advocacy efforts in an effort to minimize burden on industry throughout the implementation process.
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 had intended to review the feedback received from stakeholders and subsequently release draft regulations. However, the regulations are currently on hold due to a federal court ruling which considered the government’s decision to classify all plastics as toxic as non-constitutional. More specifically, the case of adding Plastic Manufactured Items (PMI) to the list of toxic substances in Schedule 1 of the Canadian Environmental Protection Act, 1999. The federal court had ruled this action unreasonable and unconstitutional by blanketing all plastics as toxic. These files will remain on hold until the ruling is lifted.
ECCC published a 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.

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.