Environment & Climate Change Canada (ECCC) has published a consultation document  called “Pollution prevention planning notice (P2) for primary food plastic packaging: targets for reduction, reuse, redesign and recycled content.”

While the produce industry has moved quickly to meeting targets on recycled content, the new proposed rules would have a major impact on the produce industry in Canada – a sector that’s responsible for only two per cent of plastic use in the country. The Canadian Produce Marketing Association (CPMA) is most alarmed that produce companies would be required to have fresh fruits and vegetables distributed and sold in bulk and/or plastic-free packaging with targets of 75 per cent reduction of plastic by 2026 and 95 per cent by 2028.

In addition, the federal government plans to ban non-compostable PLU stickers by 2030 – a regulation that would add an additional estimated cost of $30 million to move to PLU stickers with certified adhesives, ink and substrates. In two other European jurisdictions, similar regulatory efforts have been legally challenged and met with limited success due to the challenges with certifying all three elements of the PLU sticker as compostable.

The P2 Notice would require Canada’s largest grocery retailers that generate grocery retail sales in Canada of more than $4 billion annually to prepare and implement a P2 plan to meet targets for reduction, reuse, and redesign of primary food plastic packaging, including recycled content targets.

“While this looks like a retail only requirement it is truly a full supply chain change to how we pack, ship and sell fresh fruit and vegetables in Canada and from around the world,” explains Ron Lemaire, president, CPMA. “This plan has the potential to impact access and availability of produce in Canada, impacting cost, food inflation, food loss/waste and food security.”

Lemaire continues: “The federal government is asking for changes that are not aligned with how the global food system works and conflicts with policy frameworks already in place. The goal of reducing plastic by 75 per cent by 2026 is not achievable. The assistant deputy minister of ECCC has been briefed, but it’s important to put on the record that hiding behind a politically driven agenda is not an acceptable answer to developing policy that undermines food availability and negatively impacts Canadians.”

The federal government’s 30-day consultation period ends August 30, 2023.

“Grower input on this consultation will be vital to frame the unintended consequences of moving forward with these proposed targets and our need to have produce exempt from the proposed rule,” says Lemaire.

CPMA has prepared a one-pager with key questions that growers should be addressing.  if you have questions please contact Jane Proctor (jproctor@cpma.ca) or Ron Lemaire (rlemaire@cpma.ca)

For the federal government’s consultation document, link here: https://www.canada.ca/en/environment-climate-change/corporate/transparency/consultations/consultation-pollution-prevention-planning-notice-primary-food-plastic-packaging.html

Source:  Canadian Produce Marketing Association August 14, 2023 communiqué