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September 07, 2023

Value Chain Management International (VCMI) is responding to Environment and Climate Change Canada’s (ECCC)  August 1, 2023 consultation paper which contains aggressive targets for reducing plastic use. 


One of the greatest risks facing industry today is well-intended though poorly conceived policies write the authors: Martin Gooch, Delia Bucknell and Peter Whitehead. Poorly conceived policies and the mechanisms required for their execution have the potential to worsen the issue(s) that they seek to address. Policies and regulatory mechanisms must be based on empirical evidence.


VCMI agrees with the overall aims and direction of policies and regulatory mechanisms published by ECCC regarding addressing plastic pollution; however, the detailed objectives published by ECCC in April and August 2023 (particularly the latter) are, in VCMI’s opinion, unachievable and will lead to widespread unintended consequences.


Key takeaways from VCMI’s response:


1   Hammer policies are an unnecessarily high risk approach to address complex problems, particularly when the proposed mechanisms for change are out of context and untested in relation to the problem(s) seeking to be addressed.


2   Policies must recognize the scale of the conflated relationships that exist between plastic pollution and GHG emissions. Addressing both issues is vital, though addressing each issue requires the execution of complementary solutions.


3   ECCC urgently needs to establish constructive dialogue with industry on addressing plastic pollution. Failure to do so could well result in ECCC losing its credibility as an authoritative government body.


4   The topic of plastic pollution cannot be viewed in isolation. Doing so will undoubtedly lead to widespread unintended consequences.


5.  The need for negotiated agreements is particularly critical in Canada’s federated system, where provinces/states and municipal governments can impede change initiatives by having implemented conflicting regulations and misaligned systems.


VCMI’s commentary can be accessed HERE.


Source:  Value Chain Management International September 7, 2023 news release



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Submitted by Karen Davidson on 7 September 2023