Discussion Document: Towards a Proposed Canada-wide

Proposed Canada-wide Strategy for Sustainable Packaging

DISCUSSION DOCUMENT

TOWARDS A PROPOSED

CANADA-WIDE STRATEGY FORSUSTAINABLE PACKAGING

DRAFT FOR CONSULTATION

Canadian Council of Ministers of the Environment

February 2009

Towards a Canada-wide Strategy for Sustainable Packaging ndash Draft for Consultation

PREFACE

Packaging is necessary to preserve and transport products but the materials are oftenused just once and making them consumes significant quantities of energy and resourcesIn recent years governments across Canada have become increasingly concerned aboutpackaging waste and resource use Consumer demand for greener products and reducedpackaging has also increased At the same time retailers have begun to push for moresustainable packaging both to reduce supply chain costs and to meet consumer demandfor green products and packaging Across the supply chain businesses are increasinglyembracing sustainability as a strategic objective and business imperative

Responding to these concerns the Canadian Council of Ministers of the Environment(CCME) Extended Producer Responsibility Task Group (EPRTG) has created thisdiscussion document to aid in the development of a strategy to reduce packaging inCanada and promote more sustainable packaging choices This strategy would form partof a larger proposed Canada-wide Action Plan making producers responsible for end-of-life management of products This document addresses the need for a strategic approachto packaging and proposes potential key elements for a Canada-wide approach onsustainable packaging

How can you contribute

We need your help to build an effective and meaningful strategy For this strategy to besuccessful input from you as producers importers brand owners retailers non-government organisations stewardship organizations consumers and governments isimportant

Your feedback is welcome and can be submitted electronically using the response formattached We would appreciate your response by May 29 2009

After this consultation all feedback will be considered in completing a strategy topropose to CCME

DISCUSSION DOCUMENT TOWARDS A CANADA-WIDESTRATEGY FOR SUSTAINABLE PACKAGING

EXECUTIVE SUMMARY

The Extended Producer Responsibility Task Group (EPRTG) was established in 2005 bythe Canadian Council of Ministers of the Environment (CCME) with a mandate todevelop a broad approach to extended producer responsibility (EPR) and productstewardship focusing first on packaging

The EPRTG has created two documents to facilitate the conversation around these issues1) Discussion Document Towards A Canada-wide Action Plan for Extended

Producer Responsibility2) Discussion Document Towards A Canada-wide Strategy for Sustainable

Packaging

This discussion document on sustainable packaging is part of the broader proposedCanada-wide Action Plan for Extended Producer Responsibility

PurposeThe purpose of the proposed sustainable packaging strategy is to reduce packaging wastein Canada and promote more sustainable packaging choices at all life-cycle stages fromraw material acquisition to disposal andor reuse and recycling The proposed strategywill increase awareness of sustainable packaging choices introduce incentives to makemore sustainable choices and potentially provide for systems to optimally recoverpackaging materials The proposed strategy applies to all types of packaging includingbut not limited to packaging of food beverages and other products by manufacturers anddistributors in-store packaging by restaurants and retailers and transport packaging

The proposed strategy provides draft guidelines to stakeholders involved in theproduction and consumption of packaging and to governments and partners as they worktowards its implementation

Guiding PrinciplesThis proposed strategy includes four key principles

Extended Producer Responsibility (EPR) ndash extends a producerrsquos responsibility fora product to the post-consumer stage of a productrsquos life cycle and encouragesconsideration of end-of-life management impacts during the design phase

Life-cycle sustainability ndash integrates environmental economic and socialconsiderations into decision making by all packaging actors and takes a closed-loop approach to material management where the flow of materials eliminateswaste

Zero waste ndash seeks to redesign the way resources are used with the aim ofeliminating waste by focusing on redesigning products and processes to reducewaste before it is made and design products for greater reuse of resources

Polluter pays ndash promotes the internalization of environmental costs and the use ofeconomic instruments as a way to ensure that those responsible bear the costsattached to choices with environmental impacts

Proposed ActionsThe actions proposed by the strategy under consideration include the following Introduce province-wide EPR requirements for packaging within a set time frame

(eg five years) following the approval of the proposed Canada-wide Action Planfor EPR

Negotiate agreements with specific industry sectors to reduce packaging andimprove its sustainability

Support the development of consistent guidelines standards andor visualidentification for reusable recyclable and compostable packaging and recycledcontent of packaging

Support the development of sustainability criteria for packaging that reflect theentire life cycle

Support the development of educational initiatives that promote sustainablepackaging design and best practices This may include a recognition program torecognize efforts to redesign packaging

Support the establishment of an ombudsman to address specific complaints ofexcess packaging identified by consumers

ImplementationMultiple considerations have been presented for implementation of the actions proposedin the strategy including possible legislative and program development by provinces andterritories partnerships with existing organizations the creation of a nationalcoordinating entity (to develop standards and function as a packaging ombudsman) arole for the federal government and the use of a various legislative and regulatorymeasures to harmonize the implementation of the strategy A timeline is also included toillustrate the possible timing of implementation and how these actions address the goalsof the strategy

A Note on Best Practices

In support of the development of the strategy the EPRTG researched best practices toaddress packaging sustainability An overview of some of the best practices reviewedwith a variety of case studies is included in Appendix D

Table of Contents

PREFACEi

DISCUSSION DOCUMENT TOWARDS A CANADA-WIDE STRATEGY FOR

SUSTAINABLE PACKAGINGii

EXECUTIVE SUMMARY ii

1 INTRODUCTION 1

2 THE NEED FOR A NATIONAL SUSTAINABLE PACKAGING STRATEGY 3

3 KEY ISSUES 8

4 PROPOSED CANADA-WIDE STRATEGY FOR SUSTAINABLE

PACKAGING10

5 PROPOSED ACTIONS 14

6 MEASURING SUCCESS24

7 POSSIBLE TIMELINE 25

Appendix A ndash Executive Summary of the Discussion Paper Towards a

Canada-wide Action Plan for EPR26

Appendix B ndash Overview of Packaging Management Programs in Canada 29

Appendix C ndash Key Packaging Issues 32

Appendix D ndash Overview of Best Practices 36

Appendix E - Sustainable Packaging Resources44

1 INTRODUCTION

This introduction provides the context for this discussion paper on sustainable packagingincluding its relationship to the proposed Canada-wide Action Plan for ExtendedProducer Responsibility as well as the strategyrsquos objectives and scope

The Extended Producer Responsibility Task Group (EPRTG)EPRTG was established in 2005 with a mandate to scope a broad approach to EPR andproduct stewardship with a focus on packaging The EPRTG has created two documentsto facilitate the conversation around these issues

1) Discussion Document Towards A Canada-wide Action Plan for ExtendedProducer Responsibility

2) Discussion Document Towards A Canada-wide Strategy for SustainablePackaging

These two proposed initiatives are complementary Extended producer responsibilityrequires producers to take financial andor physical responsibility for the packaging at theend of its life and this is an integral element of Canada-wide Strategy for SustainablePackaging Similarly approaches to EPR requirements for packaging in this strategy willbuild on the guidance provided in the Canada-wide Action Plan for EPR Moreinformation on the action plan and its link to the packaging strategy can be found inAppendix A ndash Executive Summary of the Canada-wide Action Plan for EPR

Objectives of the Sustainable Packaging StrategyThe EPRTG is seeking input on this proposed packaging strategy that will promote theproduction and use of more sustainable packaging in Canada eliminating unnecessarypackaging where possible The proposed strategy aims to achieve concrete outcomes andmeaningful measurable and transparent results When implemented this strategy shouldencourage producers and consumers to make more sustainable packaging choices

Scope of Proposed Packaging StrategyThe proposed strategy applies to all types of packaging including but not limited to Packaging of food beverages and other products by manufactures or distributors In-store packaging by restaurants and retailers (such as take-out containers) Transport packaging

Some exceptions may be appropriate in certain cases This strategy does not apply toprinted paper though provinces and territories may choose to introduce EPRrequirements for printed paper in conjunction with packaging

What is packaging

Packaging refers to all materials fabricated containers and other components used inthe containment protection movement and display of a product or commodityPackaging plays a number of important roles it protects the product enables itsdistribution provides information about the product inside and it may make the

product more attractive and easy to use

Packaging is made from a variety of materials including paper (milk cartonscorrugated containers) plastic (water bottles) glass (jars and bottles) aluminium (popcans foil packaging) and steel (canned foods)

This proposed strategy is intended to promote consideration of the effect of the entire lifecycle of packaging ndash from what goes into acquiring the raw materials for the packagingto its manufacture transportation and consumption through to disposal andor reuse andrecycling as raw material for future products and packaging

Figure 1 The Packaging Life Cycle1

1Source Waste amp Resources Action Programme For more information see httpwwwwraporguk

2 THE NEED FOR A NATIONAL SUSTAINABLE PACKAGINGSTRATEGY

Packaging serves important functions but also presents major challenges This sectiondiscusses the nature of the packaging problem the current status of packaging in Canadaand the opportunities available in implementing a national sustainable packagingstrategy

The Problem

Packaging serves an important function in the protection of goods By protecting goodsand preventing loss through spoilage and breakage packaging can prevent waste Forexample the shrink wrap on a cucumber can extend its life from three to ten daysmaking it more likely to be consumed2 As a result the goods as well as the water andenergy that went into their production and transportation do not go to waste

Packaging also presents a number of problems Most packaging serves its function for only a brief period of time before reaching

the end of its life and then it becomes a cost burden to municipal wastemanagement systems

Certain types of packaging are difficult to recycle (eg composite) Throughout its lifecycle packaging can cause negative environmental and

economic effects (ie use of primary resources energy used in production andtransport collection and recovery systems required for diversion or landfilling)

Determining the appropriate amount and type of packaging is a challenge that is likelybest answered by producers The type and amount of packaging used is also influencedby factors such as household size disposable income and concern over consumer safetyand convenience3 Factors such as these led to a 10 per cent increase in packaging in theEuropean Union between 1997 and 2004 despite packaging reduction and recoveryrequirements that have been in place in the EU since 19944

How Much Packaging is Generated in Canada

The last Canada-wide Statistics Canada survey on packaging was completed in 1996 aspart of CCMErsquos National Packaging Protocol initiative At the time Canadians disposedof 88 kilograms of packaging waste per person each year including residential wasteinstitutional commercial and industrial (ICampI) waste packaging and packaging used intransportation5

2Industry Council for Packaging and the Environment 2007 Shrink wrap - necessary An investigation by the

Cucumber Growers Association (httpwwwincpenorgresourcedataincpen1docscucumberwrapapril2007pdf)3 Packaging Council of Australia 2008 The Status of Packaging Sustainability in Australia Final Report4 European Environment Agency 2008 Generation and recycling of packaging waste assessment (CSI 017)5 Canadian Council of Ministers of the Environment 1998 National Packaging Protocol 1996 Milestone Report

In 2002 the European Union estimated packaging makes up roughly 17 per cent of itsmunicipal waste stream (by weight)6 Data from some provincial waste audits suggeststhis estimate may apply to Canada as well For example Stewardship Ontario theorganization that runs the Blue Box program in Ontario estimates households in Ontariogenerated 733993 tonnes of waste from packaging materials in 2006 By using StatisticsCanada data on waste disposed and materials prepared for recycling in Ontario it can beestimated that packaging generated represents roughly 14 per cent of the residential wastestream7 A 2005 Greater Vancouver Regional District Waste audit echoes these findingswith packaging making up roughly 18 per cent of the waste stream by weight8

Less is known about the amount of packaging waste that is found in the ICampI wastestream but it is certain the majority of waste sent for disposal is from non-residentialsources According to Statistics Canada in 2006 waste from the ICampI sectors representedabout 60 per cent of the total waste stream9 The City of Ottawa estimates its ICampI wastestream is made up of 25 per cent ldquoBlue Box materialsrdquo and 15 per cent old corrugatedcardboard10 This means that up to 40 per cent of the ICampI waste stream is packagingmaterials including aluminium cans plastic bottles and old corrugated cardboard

How is Packaging Waste Managed in Canada

Various actors currently play a role in the management of packaging in Canada The federal government regulates imports labelling requirements and restrictions on

packaging with respect to food and product safety Provinces and territories introduce requirements for packaging waste and resource

management by municipalities and businesses Most municipalities are responsible for management of residential waste collection

and recycling Some municipalities establish their own initiatives to encourage moresustainable packaging and reduce packaging waste

Private waste haulers generally manage industrial commercial and institutional wasteand recycling though municipal waste systems may provide this service as wellparticularly for small- and medium-sized enterprises

Industries and businesses make decisions on how to package products Businessesmay undertake voluntary initiatives to reduce packaging or encourage take-back ofpackaging

Consumers may influence packaging through individual purchasing decisions andimproving recovery rates of packaging materials in participating in diversionprograms

6 Commission of the European Communities 2006 Report from the Commission to the Council and the EuropeanParliament on the Implementation of Directive 9462EC on Packaging and Packaging Waste and its impact on theEnvironment as well as on the functioning of the Internal Market7 Estimates calculated based on Statistics Canada 2006 Waste Management Industry Survey and Stewardship Ontario2007 Annual Report8 Greater Vancouver Regional District 2005 Solid Waste Composition Study Technology Resource Inc9 Statistics Canada 2006 Waste Management Industry Survey Business and Government Sectors Catalogue no16F0023XIE10 City of Ottawa 2008 Diversion 2015 Industrial Commercial amp Institutional (ICampI) Waste 3R Strategy

The following table summarizes stewardship activities relating to packaging currentlyundertaken by Canadian provinces and territories Please see Appendix B for furtherdetails

ProvincesTerritories BeverageContainer Refund

Multiple MaterialEPR Requirements

Plastic BagsInitiatives

Newfoundland ampLabrador

Nova Scotia New Brunswick Prince Edward Island Quebec lozOntario lozManitoba Saskatchewan Alberta British Columbia lozNorthwest Territories NunavutYukon

Legend Initiative implemented Initiative pendingloz Government-industry voluntary initiative

Benefits of a Sustainable Packaging Strategy

Historic approaches to packaging have focused on end-of-life management measuringprogress through changes in the weight of packaging sent for disposal Howevermeasures like weight or recycling rates alone may not be appropriate for measuringbroader objectives such as energy input and greenhouse gas generation

Decisions about packaging design and material selection need to consider the productsystem What are the needs of the product being packaged to ensure it will be protectedHow far will the packaged product travel How will the packaging be managed whendiscarded Sustainability also considers whether packaging materials can be locallysourced and if they are healthy to people and the environment throughout their life cyclePackaging designers must keep these questions in mind at the same time as they areconsidering the cost of producing the package and other client demands such asaesthetics

A sustainability-based approach creates a framework for decision making that is sensitiveto these needs At the same time it recognizes that everyone benefits from reducingunnecessary packaging while meeting social economic and environmental performanceobjectives

The development of a sustainable packaging strategy presents a number of opportunitiesfor all participants in the packaging life cycle For example Innovative packaging design can reduce costs for industry through the use of fewer

resources and lower transportation costs Better packaging design can create a more competitive product Reduced packaging results in less waste and toxics produced and fewer resources

used (eg energy) which benefits waste managers consumers the environment andsociety as a whole

The Benefits of Packaging Redesign

Unilever Canada Ltd significantly reduced the ecological footprint of liquid laundrydetergent through the triple-concentrated Sunlight Small amp Mighty The concentratedformula allowed a package size reduction from 295L to 946ml providing a 54 per centsavings in plastic and 51 per cent savings in corrugate used in the packaging andtransport of the product In addition 76 per cent less water was used in the manufacturingprocess and 67 per cent less diesel fuel was used to transport the smaller package andproduct11

ConAgra Foods redesigned Huntrsquos Ketchup to make it easier to manage at its end of lifeThe plastic-based package formerly a multilayer bottle was redesigned to a single layerbottle using Constar Incrsquos DiamondCleartrade PET (polyethylene terephthalate) and itsoxygen-scavenging technology The single-layer PET bottle is easier to recycle at its endof life uses fewer materials to manufacture and is 12 per cent lighter12

Why a National Strategy

Measures to achieve packaging reduction and sustainability throughout the packaging lifecycle will likely be influenced by decisions made at the design stage These designdecisions are largely made by producers at a national or global level and are not solely aresponse to the requirements of individual provinces and territories Rather than pursuingindividual approaches that may confuse consumers and other stakeholders it is importantfor industry governments and other interested stakeholders to work together towardsustainable solutions

11 Packaging Association of Canada Sustainable Packaging Leadership Awards Gala ndash Special Issue report published inassociation with Canadian Packaging (April 2008) p S1212 ConAgra Foods Huntrsquos Ketchup Brand Focus (httpphxcorporate-irnetphoenixzhtmlc=202310ampp=Hunts)

A national approach could result in a number of potential benefits that may not berealized through individual actions by provinces and territories such as

Harmonizing legislated requirements reducing the administrative and costburdens to affected businesses

Creating a catalyst for industry action to make changes in response to the visionand goals of the strategy

Facilitating coordination of actions between federal provincial and municipallevels of government when undertaking initiatives

3 KEY ISSUES

The EPRTG has identified eight key issues or concerns related to packaging which wereconsidered in the development of this proposed strategy for sustainable packaging whichcould benefit from your input Each of these issues is summarized below More detail oneach issue can be found in Appendix B

1 Information on Packaging Generation and Management The production (type andquality) use and management of packaging in Canada is not currently reported and madepublic in a consistent manner In order to better understand the nature of packaging inCanada focus actions and set meaningful targets additional data is required Cost-effective approaches to data collection are needed

2 Low Packaging Recovery Rates Life-cycle sustainability for packaging requires thatpackaging is created to the greatest extent possible using secondary resources such asreused or recycled packaging rather than virgin materials such as fossil fuels Lowrecovery rates for packaging need to be addressed

3 Communication of Proper Management Consumers are an integral part of the resourcerecovery process and labelling is a vital tool in managing packaging and making suitablechoices Identifiers for packaging products need to be created

4 Appropriate End Markets Different packaging materials are handled in a variety ofways after the packaging has been used Some are reused and recycled into newpackaging while others are ldquodowncycledrdquo to lower value uses or are sent to landfillbecause there is no market for the material Use of materials with higher potential forreuse and recycling needs to be encouraged

5 Excessive Packaging Consumers consistently express frustrations with excessivepackaging such as packaging that is difficult to open is used only once andor is non-recycleable Avenue of communication and education needs to be created to linkconsumer concerns with industry decisions about packaging choices

6 Designing Sustainable Packaging Packaging producers rarely consider end-of-lifemanagement in the design phase This can result in packaging that is difficult to managePolicies aimed at influencing package design more effectively need to impact producerswho operate at a national or global level

7 External Constraints in Packaging Decisions Decisions about packaging depend on anumber of factors such as product protection health and safety standards and shipmentcosts Federal legislation regulates labelling food and product safety environmentalclaims and import requirements These constraints to sustainable packaging measuresneed to be dealt with

8 Toxicity Concerns Packaging toxicity is a significant concern Environment Canadais currently engaged in an extensive process under CEPA to review and where necessary

restrict the use of substances of potential concern used in product manufacturingincluding packaging on human health and the environment Toxicity concerns need to bea part of the sustainable packaging discussion

4 PROPOSED CANADA-WIDE STRATEGY FOR SUSTAINABLEPACKAGING

The following strategy framework is proposed for a CCME Canada-wide Strategy forSustainable Packaging Proposed key actions and timelines are described in subsequentsections

Vision

CCME envisions a Canada where packaging is safe and of benefit to people theeconomy and the environment and where zero waste is created throughout the packaginglife cycle

The purpose of this proposed strategy is to reduce packaging waste in Canada andpromote more sustainable packaging choices at all life-cycle stages To do this the waypackaging is produced designed and evaluated needs to be changed This proposedstrategy can help to increase awareness among all packaging actors of sustainablepackaging choices introduce incentives for more sustainable choices and present ideasfor systems that can provide for the best recovery of packaging materials

This proposed strategy provides a number of ideas for goals and guidelines forstakeholders involved in the production and consumption of packaging and forprovincesterritories as they work towards its implementation This proposed strategyrecognizes that a phased approach is necessary to achieve success with options that canadapt to changing products and technology The successful implementation of thisproposed strategy would result in quantifiable performance deliverables and targets

The development and implementation of this proposed strategy will make progresstoward CCMErsquos vision for sustainable packaging in Canada and is part of the overallproposed EPR action plan Through a harmonized approach across the country emphasison resource efficiency and continuous eco-innovation and producer- and consumer-driven demand for sustainably packaged products Canada can become a world leader insustainable packaging

Guiding PrinciplesThis proposed strategy was developed with four key principles in mind

Extended Producer Responsibility (EPR) ndash extends a producerrsquos responsibility for aproduct to the post-consumer stage of a productrsquos life cycle and encourages considerationof end-of-life management during the design phase

Life-cycle sustainability ndash integrates environmental economic and social considerationsinto decision making by all packaging actors and takes a closed-loop approach to materialmanagement where the flow of materials eliminates waste

Zero waste ndash seeks to redesign the way resources are used with the aim of eliminatingwaste by focusing on redesigning products and processes to reduce waste before it ismade and design products for greater reuse of resources

Polluter pays ndash promotes the internalization of environmental costs and the use ofeconomic instruments as a way to ensure that those responsible bear the costs attached tochoices with environmental impacts

Goals to be considered Increase the level of extended producer responsibility related to packaging design

recovery reuse recycling and disposal Optimize packaging design to reduce negative effects throughout a packagersquos life

cycle (production use and end-of-life management) Reduce the overall quantity of packaging materials generated and disposed Ensure that all packaging actors are engaged in making more sustainable

packaging choices to meet these goals

Potential TargetsThe Canada-wide Action Plan for Extended Producer Responsibility (CAP) proposes thefollowing targets for packaging

EPR framework legislation andor regulations within a set time frame (egfiveyears) after the CAP is signed

Operational EPR requirements for all packaging in place within a set time frame(eg six years) after the CAP is signed

Performance measures and targets for EPR requirements need to be set by provinces andterritories based on proposed guidelines prepared as part of the EPR Canada-wide ActionPlan process

Feedback received through the consultation process and information gained throughreporting can be used to assist in creating and adjusting overall packaging reductiontargets

Potential overall targets could include zero growth (relative to sales) of packaging by weight or volume in three years reduce packaging within two years of achieving zero growth

Additional targets could be set related to sustainability criteria or packaging productstandards such as recyclability or compostability dependant upon the actions that remainas part of this strategy These targets could then be incorporated into provincialterritorialEPR requirements

Proposed Roles and ResponsibilitiesAll actors involved in the packaging life cycle ndash from the designer to the consumer ndashhave a role to play in achieving the goals of the strategy Participation from all levels ofgovernment the ICampI sectors environmental groups and the public will be important indriving better packaging design and reducing waste throughout the packaging life cycle

Ideas for Government to Consider

Municipal ProvincialTerritorial and Federal Governments

Set clear policy objectives to reduce the environmental and social impacts related topackaging

Introduce extended producer responsibility requirements for producers of packaging Introduce supporting requirements as necessary to facilitate packaging reduction and

proper management through EPR Build relationships to achieve change provide incentives and recognition for those

that demonstrate positive change and provide toolsguidance for those that lag behind Help to engage actors involved in the packaging life cycle including consumers Support material suppliers and industry associations to collect data and assess

progress

Ideas for Producers to ConsiderSuppliers Converters Fillers

Understand the full life cycle of packaging Understand and comply with provincial and federal requirements including EPR

obligations Identify environmental social and economic impacts and benefits Pursue opportunities for improvement and change Collaborate with recyclers and municipal collection services to address highest-

impact packaging products Develop new packaging materials and products with sustainability in mind (eg

cradle-to-cradle potential) Make technical data on material sustainability available to manufacturers and

retailers

Ideas for Retailers to ConsiderBrand owners Distributors and First Importers

Identify greatest impacts or opportunities for change and set priorities Understand and comply with provincial and federal requirements including

applicable EPR obligations Partner with government packaging suppliers and producers to meet strategy goals Encourage suppliers to eliminate overpackaging and use reusable recyclable or

compostable packaging Educate customers solicit supplier ideas and mandate minimum performance Provide more sustainable packaging choices for in-house branded products and take-

out packaging Contribute data by setting targets monitoring and publicly reporting on progress

Ideas for Consumers to ConsiderResidential Industrial Commercial and Institutional Sectors

Identify impacts and opportunities for change Reduce waste generated through purchasing choices Engage in waste diversion by participating in local waste management initiatives run

by municipalities retailers or producers Ask questions ask municipalities about collection and recycling ask manufacturers

about product packaging and talk to family or colleagues about lessons learned

Ideas for Waste Managers to ConsiderCollectors and Processors

Assist and support consumerswaste generators in their efforts to reuse and recyclewaste wherever possible

Contribute data monitoring and publicly report on progress

Ideas for Non-Governmental Organizations to Consider Promote and educate on the need to reduce packaging waste and conserve Canadarsquos

natural resources Initiate or provide support for research to reduce packaging waste and improve

management Partner with industry and government in activities to meet the strategy goals

Discussion Questions

We would like your feedback regarding this potential Canada-wide Strategy forSustainable Packaging framework The following questions are offered for discussion

1 Would you support the vision guiding principles goals and targets and roles andresponsibilities as outlined in the document Are there changes you would suggest

2 Are there other guiding principles that should be considered

3 Are the proposed targets appropriate What alternatives can you suggest

4 What is the best way to access and coordinate data needed to support the strategyCan you suggest existing or potential sources of data that could support performancemeasurement of the strategy

5 Have the roles been effectively identified and defined Have any key responsibilitiesbeen missed What do you see as youryour organizationrsquos role

5 PROPOSED ACTIONS

This section provides an overview of the actions proposed to meet the goals and targetsof the strategy Extended producer responsibility requirements established by provincesand territories are the primary actions suggested to achieve the goals of this proposedstrategy which is in line with the proposed Canada-wide Action Plan for EPR

While the EPR requirements are being established this strategy proposes additionalsupport measures for their implementation as well as short-term measures to supportprogress on this strategyrsquos goals

A Extended Producer Responsibility (EPR) Canada-Wide ExtendedProducer Responsibility for Packaging

Key Action Introduce EPR requirements for packaging within a set time frame (egfive years) of the approval of the Canada-wide Action Plan for EPR

The proposed Canada-wide Action Plan for EPR (CAP) includes the concept thatprovinces and territories establish EPR-based province-wide requirements for packagingPackaging requirements introduced by provincesterritories would be based on theprinciples and guidance being developed as part of the EPR action plan Theserequirements would apply to both the residential and ICampI sector and cover all types ofpackaging used for non-hazardous13 products including service and transport packaging

Current waste diversion initiatives do not provide sufficient incentives for producers toredesign their products Regulators and program developers must look at ways to drivereduction and sustainable design when designing EPR initiatives

Following the guidance of the CAP EPR requirements will strive to Transfer physical andor financial responsibility of managing waste packaging to

the producer Provide incentives for producers to strive toward zero waste by redesigning

products and processes to reduce waste before it is created Improve the end-of-life management of packaging waste Track the flow of materials Collect detailed information on the introduction of packaging into the

marketplace along with its recovery and disposal rates Use collected information to set reduction recovery and recycling targets Measure progress against targets Research and promote best practices in packaging waste management and

reduction

13 Packaging used for hazardous products would require special handling These are usually managed separately frompackaging used for non-hazardous products These would be captured in municipal hazardous and special waste EPRprograms

Guidance provided as part of the EPR CAP encourages provincialterritorial EPRrequirements for packaging to provide producers with flexibility in meeting the overallobjectives of the requirements For instance producers may discharge their obligations asindividual producers by acting individually by involving a contracted service provider orthrough collective recovery programs These may at the producerrsquos discretion involveretail or municipal partners EPR requirements should encourage take-back initiativeswith or without supporting refundable deposit systems

Where collective schemes with steward fees are implemented to meet EPR requirementsprogram developers should set fees that recognize and reward producers for minimizingthe environmental impact of the packaging they produce This can be accomplished bysetting higher fees for packaging with a greater environmental impact Program costs willalso need to capture the cost of managing packaging that is disposed as well as what canbe recovered Sustainability criteria could also be developed with a fee structure toreward more sustainable packaging while reflecting waste management costs

A Canada-wide approach to EPR for packaging can help to create a level playing field forindustry and provincesterritories will be in a better position to drive sustainable designand reduction

To allow for regular and consistent monitoring of achievements reporting requirementscould be standardized nationally through the guidance provided in the Canada-wideAction Plan for EPR

Proposed Activities For Provincesterritories

- When reviewing existing requirements or implementing new onesjurisdictions would consider guidance provided in the Canada-wide ActionPlan for EPR

Additional activities to be coordinated nationally- Develop sustainability criteria for packaging (see supporting measure 3)- Develop guidance on financial incentives (eg fee-setting methodologies for

collective schemes) that will reward the sustainability performance ofpackaging

Implementation Considerations Provincesterritories may introduce EPR requirements for packaging through new

legislation and regulations or revise existing legislation or regulations Provincesterritories could collaborate with neighbouring jurisdictions to facilitate

harmonization in design and implementation requirements Provincesterritories with similar packaging recovery systems and infrastructure

currently in place could work collaboratively to establish similarobjectivestargets for accessibility collection and diversion

Coordination at the national level could improve efficiency and effectiveness ofEPR for packaging EPR activities that could potentially be coordinated includedata collection reporting research the promotion of best practices and publiceducation

There are several potential entities that could participate in coordinated activitiessuch as provincial or industry stewardship organizations where they exist orthrough establishment of a consortium of individual stewards or a national entity

A national coordinating body could also manage data collection to measureprogress Canada-wide in meeting the EPR requirements and the overallperformance in meeting the goals of the strategy

B Supporting Measures

EPR requirements alone may not be sufficient to substantially influence packagingdesign particularly in terms of reducing packaging or improving its sustainability in theshort term Therefore supporting measures to encourage producers to continue and insome cases begin to strive for sustainable packaging are recommended such as buildingpartnerships with industry to encourage early reduction efforts along with standards thatinstitute best practices

1 Negotiated Agreements with Industry

Proposed Key Action Negotiate agreements with specific industry sectors to reducepackaging and improve its sustainability

There is significant interest among industry leaders to improve packaging design andmanagement Negotiated agreements with specific industry sectors could provide anopportunity to build on momentum already present among industry leaders Agreementsare also an important tool in moving towards sustainable packaging Agreements withindustry associations that commit to early action on packaging reduction andimprovement of the overall sustainability of packaging could be pursued Suchagreements would showcase the sectorrsquos ability to affect packaging reduction throughoutthe supply chain and facilitate effective recovery of packaging resources

Agreements may include the following Data collection and developing baselines Annual targets (eg zero growth of packaging in sector) Reduction and management activities (eg pilot programs) Industry and consumer education Reuse opportunities identified Determining the need for standards (ie for purchase or use of types of

packaging) and supporting tools (eg labelling) Integration of sustainable design guidelines Annual public reporting on specified performance indicators

Proposed Activities Identify interested industry partner(s) Establish objectives and targets (eg zero growth in packaging in sector) Negotiate an agreement or pilot project aimed at reducing packaging Monitor success of reduction efforts Develop additional agreements if measurable results achieved Ensure lessons learned and partner expertise are considered as provinces and

territories develop EPR requirements for packaging

Implementation Considerations Agreements could be initiated by a number of different government partners

CCME the federal government a group of provincesterritories or an individualprovinceterritory could negotiate agreements with an industry partner acting onbehalf of all

Government partners could indicate expected outcomes and industry could decidehow they meet the objectives

Action plans could be developed by the industry partner to meet the objectives ofthe agreement and they could be reviewed regularly With the use of externalaudit andor compliance mechanisms progress could be public and measurable

2 Identification and Development of Guidelines Standards andor VisualReferences

Proposed Key Action Support the development of consistent guidelines standardsandor visual identification for reusable recyclable and compostable packaging andrecycled content of packaging

Consistent guidelines and standards for packaging would help to optimize recovery ofpackaging and guide decision making Guidance could be voluntary encouraged bygovernment incentives or become (through regulation if appropriate) mandatoryLabelling and visual references would be considered where identification would benefitconsumers andor end-of-life managers

ReuseThere may be significant opportunities for reuse of particular packaging categories suchas glass bottles used by the wine industry Packaging wine in glass bottles requires highenergy use due to shipping the heavy glass and recycling it into new bottles Furtherresearch is needed to explore the viability of reuse given overall environmental footprintand food safety considerations Also reuse depends greatly on standardizing containersfor refill systems

Further work on the development of guidelines and other supports for reuse systemswould consider existing initiatives requirements such as

The Province of Quebec regulation mandating that all water containers greaterthan eight litres that are for sale within the province be refillable

The bottle-return-for-refill program run by the beer industry in Ontario throughThe Beer Store

RecyclabilityConsumers must know if a package is recyclable or not in order to participate in recoverysystems and to make informed decisions when purchasing The recycling symbolcurrently used to identify packaging for recycling (the mobius loop) is one of the mostrecognized labels in North America Although widely used the symbol is not arequirement in Canada It can also be misleading particularly when applied to plasticpackaging as there are seven resin codes and most municipal recycling systems onlyaccept 1 and 2 plastics In Britain the Waste amp Resources Action Programme (WRAP)and the British Retail Consortium recently developed a label system to help consumersidentify the likelihood that products will be recycled depending on the percentage ofauthorities collecting the material

In partnership with industry CCME could support the development of recyclabilityguidelines for packaging to clarify the recyclability of the package within the Canadiancontext Recyclability is dependant on the package material construction of the package(eg composite packaging is difficult to recycle) access to a recovery system andrecycling technology as well as end-market demand Recyclable material could bedefined by access to recycling facilities rather than whether technology exists to recycleit CCME could also support industry or not-for-profit organizations in exploring anddeveloping clear visual markers for recyclability The purpose of this process would be toassist consumers producers and waste managers during design purchase and end of lifemanagement by identifying whether the packaging is recycleable

CompostabilityA packaging compostability standard would facilitate composting in municipal or privatecompost facilities At this time most compostable plastics will not break downadequately in backyard composters or in landfills With funding support from severalprovinces the Composting Council of Canada developed a voluntary Canadian standardand certification program for compostable plastic bags The standard was released in2007 through the Bureau du normalisation de Quebec (BNQ) Quebec initiated theprocess due to problems associated with the management of bio-based bags mislabelledas compostable The standard only covers plastic bags and phase 2 of the project hasbeen proposed to address a broader spectrum of plastic packaging products

Standards for compostable material specific to material type (eg paper or plastic) wouldrequire packaging that claimed to be ldquobiodegradablerdquo ldquodegradablerdquo or ldquocompostablerdquo tomeet standards for compostability in municipal composting systems CCME could alsosupport the development of clear visual markers for compostable plastic packaging toensure they are distinguishable from non-compostable plastic A visual marker couldallow for better end-of-life management of compostable plastic and help to avoidcontamination of recycling systems

Recycled contentMany manufacturers of packaging or packaged goods already produce or use packagingcontaining recycled materials Boxboard for example is made mainly from recycledpaper and most corrugated cardboard boxes contain high levels of recycled contentThere are still many available opportunities to include recycled materials in packaging orto increase the current recycled content

An increase in recycled content would complement a move towards enhanced extendedproducer responsibility As companies become more responsible for ensuring that wasteresulting from their products or packaging is diverted there will be an increased need forsecondary markets to utilize this material Requiring recycled content in packaging willstimulate secondary markets by creating an increased demand for recycled materials Inaddition some packaging may be re-manufactured using the material from which it wasmade thereby creating a ldquoclosed looprdquo For example a large percentage of aluminiumcans are currently recycled into new aluminium cans Recycled content requirements forpackaging will likely result in other environmental benefits such as a decreased relianceon raw materials potentially lower energy requirements and a resulting reduction ingreenhouse gas production Economic benefits arising from increased recycled content inpackaging include the development of green industries and new or improved markets forrecycled materials

Development of recycled content requirements would require further assessment ofopportunities to increase recycled content as well as consideration of the effect on theoverall sustainability performance of the package

Proposed Activities Fund an organization such as the Composting Council of Canada to develop a

compostability standard for plastic packaging Commission a study to assess the viability of introducing a reuse system for

certain packaging such as in the Canadian wine industry Establish a working group to develop more effective recyclability identifiers Establish a working group to explore opportunities for increased recycled

content use Explore provincially harmonized regulations or federal regulations where

appropriate

Implementation Considerations The benefit of harmonizing product guidelines and standards nationally needs to

be considered once more specific proposals are developed The guidelines standards and visual identifiers could be developed through a

multi-stakeholder process including the involvement of NGOs producers andwaste managers to ensure that necessary concerns are addressed

Partnerships with existing organizations that are currently involved in standardsetting such as the Canada Standards Association could provide technicalexpertise and ensure that CCME is not duplicating efforts

The introduction of packaging requirements at a national level could beconsidered by the federal government which is already engaged in settingstandards and labelling requirements (eg food safety labelling)

The introduction of legislative authority over packaging environmentalperformance may need to occur should the federal government wish to assume astronger role in this area However the federal government could also likely act ina coordinating role without any changes to existing authorities

The federal government could also open dialogue with national regulatingagencies (eg Health Canada) to ensure sustainability issues are considered whenestablishing requirements or guidelines for packaging in areas where theypresently have authority such as the use of recycled content in food packaging

3 Sustainability Criteria for Packaging

Proposed Key Action Support the development of sustainability criteria for packagingthat reflect the entire life cycle

Sustainability criteria will inform how we measure progress on the strategy and helpCanadians assess the state of packaging sustainability now and in the future

Currently sustainability guidelines metrics and scorecards exist or are being developedby industry but widely used standard criteria reflecting the full life cycle of packagingare not available To date much of the work on sustainability of packaging has focusedon its environmental impact With this in mind it may be necessary to develop the criteriain phases beginning with environmental criteria which can be most readily applied topackaging Criteria development would build from the work done by organizations suchas Sustainable Packaging Coalition in the United States Other international sustainabilitymeasures for packaging should also be considered The development of sustainabilitycriteria will likely be need to be an evolving process as international knowledge andexpertise in this areas builds Eventually the criteria would look at the entire life cycleincorporating environmental economic and social factors Once developed the use of thecriteria could be integrated into most aspects of the strategy including EPR requirements

Where EPR programs with fee structures exist the sustainability criteria could beconsidered when establishing fee-setting methods In this way fees would bedifferentiated based on the sustainability of the product including the impact of non-waste factors such as greenhouse gas emissions use of recycled materials and workersafety

Packaging producers could also use sustainability criteria to report consistently onimprovements in design Industry associations could encourage such improvements byeducating members on these criteria

Proposed Activities Establish a working group with expertise in life-cycle assessment and sustainable

packaging production to develop draft criteria Consider integrating criteria into provincial and territorial EPR requirements and

programs (where appropriate) Encourage producers to use criteria to assess and improve packaging

sustainability and report publicly in a standardized manner Develop standard reporting framework

Implementation Considerations The development of sustainability criteria could benefit from national

coordination This could be an appropriate role for the federal government anational entity or led by representatives of a number of provincesterritories Itmay also be appropriate under an EPR approach for this work to be undertakenand coordinated nationally by industry

Identification of the appropriate technical experts with knowledge in life-cycleassessment and sustainable packaging production would be necessary to developsustainability criteria Participation of international expertise may be considered

The development of sustainability criteria would benefit from partnerships withexisting organizations NGOs and industry to ensure that CCME is notduplicating efforts and is advancing the sustainability of packaging as efficientlyand effectively as possible

4 Industry Education and Promoting Innovation

Proposed Key Action Support the development of educational initiatives that promotesustainable packaging design and best practices This may include a recognitionprogram to recognize efforts to redesign packaging

The design stage offers the most opportunity for packaging reductions so it is essential toensure product and packaging designers understand how to design packaging forsustainability CCME could encourage implementation of sustainable packaging designguidelines (such as SPCrsquos Design Guidelines) through education and recognition or buildon existing awards programs such as the CCME Annual Pollution Prevention Awards

This approach would capitalize on current industry initiatives such as the one-dayEssentials of Sustainable Packaging course developed by Packaging Association ofCanada the Sustainable Packaging Leadership Awards and the Wal-Mart SustainablePackaging tradeshow Education and recognition could be aimed at sectors that facechallenges and would particularly benefit from added support such as small- andmedium-sized enterprises (SMEs) producers redesigning packaging and retailers whowant to influence suppliers to achieve improvements in sustainability

Sector-based working groups could work to establish and promote best practices such astake-back programs packaging reduction options reusable containers and security andmarketing alternatives to overpackaging Education programs could showcase bestpractices for retailers

Proposed Activities Identify clear target audience(s) for education and recognition Create educational materials in partnership with existing organizations or

initiatives Create a website or use the CCME website to create a webpage that provides

details on the recognition program and access to the educational materials Provide through the website one-stop access to online resources on sustainable

packaging design

Implementation Considerations To ensure CCME is not duplicating efforts and is advancing the sustainability of

packaging as efficiently and effectively as possible partnerships with existingorganizations NGOs and industry could be used to develop educational materialsand recognition program

5 Engage Consumers

Proposed Key Action Support the establishment of an ombudsman to address specificcomplaints of excess packaging identified by consumers

Packaging that is much larger or heavier than the product contains more layers thanseems necessary to protect the product or is difficult to open or recycle is often seen asunnecessary overpackaging While there may be legitimate reasons why such packagingis necessary the issue of excessive packaging is often frustrating for consumers Whileconsumers need help understanding why packaging exists in its various types andquantities they also require an outlet to express their concerns about excessivepackaging Producers should consider these issues and be held accountable for the useand production of excessive packaging

Establishing a sustainable packaging ombudsman to respond to citizen complaints aboutpackaging would be an opportunity to link consumer concerns and produceraccountability In addition to addressing specific complaints the ombudsman role couldinclude working with industry to encourage packaging that has the minimum impact onthe environment while ensuring product integrity Considerations would include thevolume weight and number of packaging layers the potential for reuse recycling andcomposting of product materials and the environmental impact of packaging productionand transportation

The ombudsman would also be able to provide an assessment of outstanding issues withparticular products or classes of products This would allow for consideration as towhether a regulation to place limitations on the containers (such as product-to-volumeratio material choice or number of layers) would be necessary for particular products

Proposed Activities Establish a working group to develop a mandate and funding options for the

ombudsman Establish parameters for assessing the excessiveness of packaging Assess success achieved and determine whether outstanding issues necessitate

regulatory measures

Implementation Considerations The establishment of a packaging ombudsman would require a single body to act

in this role A multi-stakeholder board may be required to support the credibility of the

ombudsman

We would like your feedback regarding these proposed actions The following questionsare offered for discussion

1 Would you support the actions and activities proposed in the strategy Are there anyactions or activities you would not support Why

2 Which items would you identify as priorities What additional or alternative actionswould you suggest

3 EPR requirements for packaging are the key action proposed in the strategy Do youagree that this the best approach to achieve the goals of the strategy

4 What do you see as youryour organizationrsquos role in implementation of the strategyrsquosproposed actions and activities What barriers do you see to effectiveimplementation Are there incentives or support that would allow you to play a moreeffective role

6 MEASURING SUCCESS

Canada-wide key performance indicators are being proposed through the Canada-wideAction Plan for EPR and would be used to measure the performance of EPR requirementsfor packaging Guidance on reporting will be developed as part of the Canada-wideAction Plan however further guidance materials specific to packaging EPR performancewould be needed to demonstrate how initiatives go beyond diversion and how the amountgenerated has been reduced Additional targets would need to be set for packagingcategories building from the key performance indicators recommended in the CAPProvincesterritories would implement these targets independently

Monitoring and performance measurement is not only necessary for progress in meetingEPR requirements but also to assess progress made towards the packaging strategy goalsCurrently the strategy includes two potential overall targets achieve zero growth ofpackaging by weight or volume in three years and achieve reductions in packaging withintwo years of achieving zero growth Targets would need to be finalized and theappropriate means of collecting data would need to be identified

Baseline data would be collected as a result of EPR requirements implemented as part ofthe Canada-wide Action Plan EPR Additional sources of baseline data could includeprovincialterritorial waste audits and additional industry or partner reporting resultingfrom supporting measures introduced as part of the strategy

As sustainability criteria are developed additional key performance indicators will beneeded The sustainability criteria will help to assess the progress made towardsimproving packaging sustainability For example key performance indicators for theoverall strategy may eventually include per cent change in amount of energy used inpackaging production

The strategy could operate like a business plan that continually evolves through amonitoring and reporting process Each progress report published would influence futurerevisions to the strategy For example revised targets would be set when original targetsare achieved

Reporting on the status of packaging management in Canada could occur in relation tothe goals set out in the strategy within a set time frame (eg every two years) with areview of the strategy for example every five years This reassessment of objectives andprogress would allow the strategy to be flexible and relevant to priorities over time

7 POSSIBLE TIMELINE

ACTIONS ALIGNMENT WITHGOALS

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

Early Action (Prior to EPR Requirement Implementation) - Year 1-3

Develop guidance materials for Canada-wide EPR requirements forpackaging

Provincesterritories develop necessary policies legislation andregulations to implement EPR requirements for packaging andwhen reviewing existing requirements consider the CAP for EPR

Negotiate an agreement with industry to improve packagingsustainability

X X X X

Initiate development of Canada-wide standards for packaging X XInitiate development of sustainability criteria X X XInitiate development of an education andor recognition initiativethat promotes sustainable packaging design and best practices

X X X X

Initiate process to establish ombudsman to engage consumers andaddress excessive packaging

Evaluate method for baseline data collection XEPR Requirements and Supporting Measures (Note this timing is in line with CAPEPR but early action by provinces and territories is possible) - Year 4-6Implementation of Canada-wide EPR requirements for packaging X X X XIntroduce Canada-wide standards for packaging X XIntegrate the use of sustainable packaging criteria (considerrequiring reporting on sustainability criteria by industry and wherepossible use in EPR program fee-setting methodology)

Data collection and baseline performance measurement of the statusof sustainable packaging

Long-term - at 5-year intervalsReview the performance of the overall strategy Reassess objectivesand revise strategy approach as necessary to ensure continualprogress toward sustainable packaging in Canada

X X X X

Appendix A ndash Executive Summary of the Discussion PaperTowards a Canada-wide Action Plan for EPR

IntroductionIn 2006 Statistics Canada data showed Canadians generated almost 1100 kg ofmunicipal solid waste per person up 8 per cent from 2004 This represents about 35million tonnes of which just over 27 million tonnes was sent for disposal in landfills andincinerators and another 77 million tonnes was diverted as recyclables or organicsNationally the rate of diversion from landfill and incineration was 22 per cent with thehighest rate of diversion for a provincial jurisdiction being 41 per cent Since the rate in2004 was also 22 per cent this suggests little or no progress in enhancing the extent oreffectiveness of waste recycling and organics programs over that period Despite effortsby all levels of governments over the last three decades Canadarsquos performance lagsbehind other G8 and Organization for Economic Cooperation and Development (OECD)countries when it comes to municipal solid waste diversion and disposal

Extended Producer ResponsibilityA waste management approach that has developed in response to these issues is theconcept of the producers of products being responsible for their end-of-life managementExtended Producer Responsibility (EPR) is an environmental policy approach in which aproducerrsquos responsibility for a product is extended to the post-consumer stage of its lifecycle Through a Canada-wide Action Plan (CAP) for EPR the Canadian Council ofMinisters of the Environment (CCME) is seeking to provide guidance on thedevelopment and implementation of EPR programs to strengthen the use of EPR as anenvironmental risk-management tool and to contribute to the harmonization andconsistency of programs across the country

ObjectivesA CCME CAP for EPR would seek the adoption by producers of full life-cycle costaccounting for their products This would see the costs of the end-of-life management ofproducts treated similarly to other factors of production and incorporated into wholesaleand retail product prices Successful EPR shifts the expenses associated with productend-of-life management from taxpayers to producers and consumers and reduces theamount of waste generated and going to disposal In addition the Action Plan seeks toreduce the toxicity and environmental risks from products and product waste and improvethe overall life-cycle performance of products including reducing associated greenhousegas emissions

Implementation of the Canada-wide Action Plan for Extended ProducerResponsibility

Canadian jurisdictions would agree to consider developing EPR framework legislationandor to allow for action on the identified priority products and materials

The plan seeks to have the following products and materials incorporated into operationalprograms within a set time frame (eg six years) of the adoption of the CAP (Phase 1)

Packaging Printed materials Compact fluorescents and other lamps containing mercury Electronics and electrical products Household hazardous and special wastes Automotive products

The following products and materials could be incorporated into operational programswithin a set time frame (eg eight years) of the adoption of the CAP (Phase 2)

Construction and Demolition materials Furniture Textiles and carpet Appliances including ozone-depleting substances (ODS)

Key Performance IndicatorsA number of key performance indicators have been identified to produce a nationalannual status report on the performance of the priority EPR programs These includekilograms per capita captured or recovered dollars per kilogram captured or recoveredper cent of waste captured per cent of waste recovered and avoided greenhouse gasemissions

Model EPR ProgramIn order to facilitate the creation of consistent and harmonious EPR regulations andprograms the discussion paper outlines a number of common elements that set outrecommendations for all EPR programs to ensure common interpretation and applicationThese elements include consideration of the responsibilities of designated producers andproducer responsibility organizations relationship to stewardship plans the establishmentof targets and reporting mechanisms the creation of fees and design for environmentThe EPR program elements are designed so that through a successful EPR program andthe regulations which mandate it cost and management signals are given to producers toimprove the life-cycle performance of their products knowing that at some point in thefuture they will be responsible for the collection recycling and the environmentallysound management of products that would otherwise be discarded

Supportive Policies and RegulationsIn a complex and competitive national and global business market signals to producersfrom a relatively small market like Canada may not be strong enough alone to influencenew environmentally conscious product design and supply chain management Theenvironmental objectives of EPR may therefore need to be supported and reinforced byother measures such as eco-labelling restrictions on toxic substances recycled contentstandards and regulations green procurement policies environmentalperformancevoluntary agreements and a variety of other potential standards bansguidelines and educational tools

A National Harmonized ApproachThe purpose of a CAP for EPR would be to extend the principle of producerresponsibility across the country in a consistent and harmonized way and maximizedacross the national marketplace By shifting the responsibility for the end-of-lifemanagement of products to the manufacturer andor importer of that product effects willbe felt throughout the product life cycle This provides incentives to producers andimporters to design their products with less environmental risk reduced use of toxic andhazardous substances enhanced ease of product disassembly and other factors reducingtheir productsrsquo overall environmental footprint

Appendix B ndash Overview of Packaging Management Programs inCanada

This appendix sets out a variety of provincial and territorial packaging managementprograms across Canada

Beverage Container Refund Programs

Regulations for beverage-related packaging are the most prevalent packagingmanagement programs in the country Various forms of a deposit-refund programcurrently exist in each province or territory in Canada except Nunavut For exampleNova Scotia New Brunswick and Prince Edward Island operate a harmonized beveragecontainer deposit-return program that returns half the fees to consumers with the restbeing used to fund the program An additional example is the Beer Storersquos managementof beer packaging in Ontario which operates an extensive refillable packaging programthat recaptures approximately 98 per cent of glass beer bottles used

Extended Producer ResponsibilityProduct Stewardship InitiativesBritish Columbiarsquos recycling regulation makes the producers (manufacturer distributorimporter) responsible for the life-cycle management of their products includingfinancing the collection and recycling of discarded products Packaging addressedincludes paint oil and beverage containers In Quebec and Ontario the governmentrequires producers to compensate municipalities for up to 50 per cent of the net costs ofmunicipal packaging recovery and reclamation programs Manitoba enacted a regulationin December 2008 to establish an EPR framework for packaging and printed paperwhich will allow for a similar program

Other Provincial InitiativesOther regulatory examples include packaging audit and reduction work-planrequirements for certain Ontario manufacturers packagers and importers of packagedfood beverage paper or chemical products In Nova Scotia there is a disposal ban onbeverage containers corrugated cardboard and steeltinglass food containers

Voluntary plastic bag reduction initiatives are also becoming more prevalent Quebec hasa voluntary code of good practices to promote reduction reuse and recycling of shoppingbags promoted through education and awareness campaigns In Ontario a plastic bagreduction task group was created in 2007 to engage industry leaders to reduce the numberof plastic bags distributed in that province by 50 per cent over the next five years In2008 British Columbia industry leaders followed suit committing to reducing thedistribution of plastic bags by 50 per cent over five years Other jurisdictions areconsidering placing fees or bans on the sale of plastic bags

Federal InitiativesFederal government packaging initiatives are primarily for the purposes of consumerprotection For example federal legislation establishes labelling requirements andrestrictions in terms of environmental claims as well as nutritional content and language

use In addition the federal government is taking action to assess the potential impact ofapproximately 23000 substances of potential concern that may be used in productmanufacturing including packaging on human health and the environment Thisprogram asks industry to provide information on 15 to 30 high-priority substances everysix months Using this information the federal government assesses the toxicity of thechemicals and recommends appropriate risk-management measures

Municipal Efforts

A number of municipalities have undertaken innovative initiatives to encourage moresustainable packaging and reduce packaging waste The City of Ottawa has beenoperating an extensive return-to-vendor product-stewardship program known as Take itBack for more than 10 years In 2008 more than 500 retailers and charities voluntarilyparticipated in the program accepting 131 specific products including a wide range ofpackaging materials for proper disposal reuse or recycling More recently the cities ofLondon and Waterloo have established procurement policies to restrict the purchase andsale of bottled water at municipal functions and facilities in an effort to reduceenvironmental impacts and waste management costs associated with bottled water Othercities such as Metro Vancouver have launched campaigns to encourage the consumptionof tap water in place of bottled water The City of St Johnrsquos Newfoundland has acommercial corrugated cardboard landfill ban The City of Toronto has also put forward aproposed plan to address in-store packaging such as plastic bags and hot drink cups Theplan proposes requirements for retailers to provide a 10-cent discount to consumers whouse a reusable bag and to ban the sale of bottled water in municipal facilities

Voluntary Industry Initiatives

In recent years many voluntary initiatives to reduce packaging have been undertakenOne initiative recognized for promoting change throughout the packaging industry isWal-Martrsquos Packaging Scorecard The Scorecard evaluates the sustainability of productpackaging used by Wal-Mart suppliers based on factors such as product-to-packagingratio the amount of renewable energy used to manufacture the packaging and therecovery value of the raw materials Wal-Mart also developed software to help suppliersunderstand how improvements can be made to redesign packaging for sustainability Thisinitiative is one of several Wal-Mart will be introducing to reach is goals of 5 per centreduction over five years

The Packaging Association of Canada (PAC) has a number of initiatives aimed atincreasing the sustainability of packaging on behalf of its members The association hasdeveloped a course on sustainable packaging design and is in the process of developingS-PAC a sustainability rating system for packaging PAC has also introducedSustainable Packaging Leadership Awards and has formed a strategic partnership withWal-Mart to train Wal-Mart executives and buyers as well as manage the Wal-MartSustainable Packaging Exposition

A variety of businesses have established deposit-return programs to support refillsystems particularly for beverages For example in Ontario the Beer Store operates ahighly effective system in which bottles are reused 12 to15 times on average The 185-

litre bottles of water produced by Canadian Springs are reused approximately 55 timesthanks to a $10 per bottle deposit In 2009 the company will also be introducing depositson smaller-format bottles to ensure recycling if not reuse

Businesses also support consumers in other ways who wish to make changes to reducepackaging For example major coffee chains across the country offer a discount forcustomers who provide refillable mugs National grocery stores have also promotedreusable grocery bags charging a fee for the use of a bag andor providing incentives forpeople who bring their own

A number of businesses particularly SMEs are also very innovative when it comes towaste reduction and source separation of waste For example Corporation ServiceCompany (Yarmouth NS) was recently recognized by RRFB Nova Scotiarsquos MobiusEnvironmental Awards as ldquoSmall Business of the Yearrdquo in part because it sends 80 percent of its waste to recycling

Appendix C ndash Key Packaging Issues

The EPRTG has identified eight key issues or concerns related to packaging that need tobe considered when developing a Canada-wide Sustainable Packaging Strategy Theseare outlined below

1 Information on Packaging Generation and ManagementThe production (type and quality) use and management of packaging in Canada is notcurrently reported and made public in a consistent manner In order to better understandthe nature of packaging in Canada and set meaningful targets additional data is neededFor example the following data is required amount of packaging materials generated and disposed nationally and within specific

product categories the qualities of the packaging such as recycled content and potential for reduction

reuse and recycling

This type of data on packaging would help both government and industry decisionmakers to focus actions It would also facilitate the setting of meaningful targetsbenchmarking and measuring progress and inform future steps to be taken towardspackaging sustainability

Data collection and analysis however can be a time-consuming and costly exerciseMillions of dollars were spent to measure and track progress on the CCMErsquos NationalPackaging Protocol (NaPP) in the 1990s Progress was tracked through a national surveythat examined the quantity of packaging generated reused recycled and the quantity ofpackaging wastes going to disposal facilities A cost-effective approach to gathering thedata necessary to support the strategy is required

2 Low Packaging Recovery Rates

Life-cycle sustainability for packaging requires that packaging is created to the greatestextent possible using secondary resources such as reused or recycled packaging ratherthan virgin materials such as fossil fuels However current recovery rates for packagingare very low Statistics Canada (2006) data indicates the national recycling rate is 22 percent The household recycling rate of all materials in Canada is 29 per cent14 This isdespite the fact 93 per cent of Canadian households in 2006 had access to recyclingprograms for at least one recyclable material glass paper plastics and metal NovaScotia and Ontario have the greatest access to recycling programs for these typicalpackaging materials15 Other communities particularly remote and Northern ones havesignificant challenges in implementing recycling programs and therefore recovery ofpackaging is very low to non-existent in those areas Some ICampI-sector organizationshave been very successful in reducing and diverting waste but overall non-residentialrecovery is lower than residential

14 Statistics Canada 2006 Waste Management Industry Survey Business and Government Sectors Catalogue no16F0023XIE15 Statistics Canada 2007 Envirostats Recycling In Canada The Daily (13 July)

Recovery rates are particularly low for plastics packaging Not all types of plasticspackaging are recyclable and those that are may require additional investments in wastemanagement facilities to be effectively recycled16 According to Stewardship Ontario in2006 the plastics recovery rate was 22 per cent significantly lower than rates for paper-based metal and glass packaging17

3 Communication of Proper Management Methods

Consumers are an integral part of the resource recovery process Clear labels or othervisual identifiers are needed to help consumers determine how to properly manage (iedispose recycle or compost) the packaging Without clear labels it can be difficult forconsumers to choose reusable recyclable and compostable packaging when purchasing aproduct

Clear identifiers are important for all packaging products to increase diversion rates andreduce contamination of the recycling stream with inappropriate materials This isparticularly important for biodegradable and compostable plastic packaging which hasbecome more common in recent years Degradable plastics appear to be identical tostandard plastics but they are chemically distinct and non-recyclable Some but not allare compostable Degradable plastics can contaminate recycling programs and result inlarge quantities of otherwise recyclable plastics going to landfill Even if compostableplastics are disposed of appropriately through municipal composting programscompostables may be screened out and sent to landfill since it is difficult for compostingfacility managers to distinguish compostable from non-compostable plastics Clear visualidentifiers directed at both waste managers and consumers are therefore essential ifcompostable packaging is to become a sustainable alternative

4 Appropriate End Markets

Different packaging materials are handled in a variety of ways after the packaging hasbeen used Some can be reused or cost-effectively recycled into new products andpackaging while others cannot be recycled at all or may only be ldquodowncycledrdquo (recycledinto lower-value uses) Other materials while technically recyclable may actually end upin landfill because there is no market for the material As a result packaging made ofvirgin materials continues to enter the market and ultimately end up in landfill Strategiesare needed to encourage the use of materials with higher potential for reuse andrecycling

5 Excessive Packaging

Consumers consistently express frustrations with excessive packaging such as packagingthat is difficult to open is used only once andor is non-recyclable Currently there is noaccountability by producers to ensure these issues are considered and no effective avenueexists for consumers to question packaging choices Industry is leading some work onthis issue For example the Concentrate on the Future campaign promotes concentrated

16 Environment and Plastics Industry Council 2008 ldquoOntario recycling of household plastic packaging needs toincreaserdquo Briefly Speaking(httpwwwcpiacaadminnewslettertemplatesepic_brieflyspeakingphpID=412ampWB=Y)17 Stewardship Ontario Annual Report 2007

detergents to reduce packaging18 and Amazoncomrsquos Frustration-Free Packaginginitiative features recycleable boxes that are easy to open and free of excess materialssuch as plastic bindings19 However more progress is possible through improvedcommunication and education to link consumer concerns with industry decisions aboutpackaging choices

6 Designing Sustainable Packaging

Packaging producers rarely consider end-of-life management during the design phaseThis can result in packaging that is difficult to manage such as that which includesmultiple materials (like boxboard with plastic windows or multiple plastic resins used toproduce plastic bottles and lids) andor packaging that is made of virgin rather thanrecycled materials

Policies aimed at influencing design need to consider that packaging producers operate innational or global markets A significant share of Canadarsquos packaging is designed andmanufactured internationally Stewardship Ontario indicates about 62 per cent ofstewards that report as part of the Blue Box program are located outside of Ontario20

7 External Constraints in Packaging Decisions

Designing more sustainable packaging is challenging and can require difficult trade-offsbetween material energy and waste management costs Efforts to reduce packaging mayresult in other increased costs Decisions about packaging are generally made on anational or global level and depend on a number of factors in addition to environmentalimpacts such as product protection health and safety standards and shipment costs

Legislative constraints in particular may run contrary to sustainable packagingmeasures By law certain product information such as directions for use ingredientsand safety considerations must be provided to consumers Producers must comply withfederal legislation and regulations which set out rules for labelling food and productsafety (in terms of dangerous goods as well as human health) environmental claims andimport requirements At times these may conflict with sustainable-packaging goals Forexample a new technology called radio-frequency identification (RFID) is now beingused in the packaging of food products to ensure traceability of product to source andenhance the safety of the food system however this technology may result in reducedrecyclability and compostability of packaging21

8 Toxicity Concerns

Packaging toxicity is a significant concern The federal governmentrsquos April 2008 draftassessment of bisphenol-A (BPA) highlights this issue BPA is a compound found inplastics and plastic coatings and in the 2008 draft assessment it was found to be toxicunder the Canadian Environmental Protection Act (CEPA) Continued assessment and

18 Concentrate on the Future (httpwwwconcentrateonthefutureca)19 Amazoncom Frustration-Free Packaging (httpwwwamazoncom)20 Stewardship Ontario 2006 Assessment of Stewards Actions in Response to Stewardship Ontario Fees(httpwwwstewardshipontariocablueboxpdfbbpp_docswaste_minimizationpdf ) 2721 Packaging Association of Canada presentation to National Extended Producer Responsibility WorkshopCharlottetown September 27-28 2006 as reported by Marbek Resources Consultants

regulation is necessary to respond to advances in the science of toxics and theirrelationship to human and environmental health Environment Canada is currentlyengaged in an extensive process under CEPA to review and where necessary restrict theuse of substances of potential concern used in product manufacturing includingpackaging on human health and the environment Given that this process is in place thestrategy has not proposed further measures to address the potential toxicity of packaging

Appendix D ndash Overview of Best Practices

In support of the development of the strategy CCME investigated best practices toaddress packaging sustainability This was done through a variety of means A multi-stakeholder workshop was held to identify the key packaging issues and challengesacross the country that should be addressed by a national packaging strategy Consultantcontracts were used to complete an inventory of national and international sustainablepackaging initiatives and to recommend a sustainable packaging definition andguidelines Expert meetings were also conducted with representatives of government andnon-profit organizations across Canada and internationally to complete gaps and ensure acomprehensive strategy The following is an overview of some of the best practicesinvestigated

Defining Sustainability

In the development of the strategy two leading definitions of sustainable packaging wereidentified One was developed by the Sustainable Packaging Alliance (SPA) in Australiaand the other by the Sustainable Packaging Coalition (SPC) based in the United StatesThe SPA definition defines sustainable packaging in terms of how it performs across thelife cycle and also addresses the function and purpose of packaging The SPC definitionsimilarly defines sustainable packaging in terms of how it performs across the life cycleand is in wider use in North America

Sustainable Packaging Definition - Sustainable Packaging Coalition

The Sustainable Packaging Coalition (SPC) is a not-for-profit organization with morethan 100 member organizations ranging from small businesses to large corporations TheSPC developed its definition of sustainable packaging as a vision to strive for andtherefore it is directional rather than a prescriptive This definition was created for theNorth American context and has gained some profile among industry in the United Statesand Canada In Canada the Packaging Association of Canada signed a partnershipagreement with SPC this past year to develop a training curriculum based in part on thedefinition

The SPC definition states sustainable packaging1 Is beneficial safe and healthy for individuals and communities throughout its life

cycle2 Meets market criteria for performance and cost3 Is sourced manufactured transported and recycled using renewable energy4 Maximizes the use of renewable or recycled source materials5 Is manufactured using clean production technologies and best practices6 Is made from materials healthy in all probable end-of-life scenarios7 Is physically designed to optimize materials and energy8 Is effectively recovered and utilized in biological andor industrial cradle-to-

cradle cycles

Sustainable Packaging Guidelines and Other Tools

A number of sustainable packaging guidelines have been developed to provide guidanceand sustainable solutions to packaging designers The SPC has published guidelinesbased on its definition of sustainable packaging In the United Kingdom guidelinesdeveloped include the Waste amp Resources Action Program (WRAP) Guide to EvolvingPackaging Design and Industry Council on Packaging and the Environment (INCPEN)Packguide A Guide to Packaging Eco-Design

Metrics and packaging rating tools are also available or under development SPA inAustralia has developed a tool called PIQUET that uses life-cycle assessment to evaluatepackaging PIQUET is already used by some brand owners in Australia SPC plans tointroduce COMPASS in early 2009 a comparative packaging assessment tool that wouldcompare packaging options based on the human and environmental impacts of theirdesigns Here in Canada the Packaging Association of Canada is developing S-PAC asustainable packaging rating tool for packaging professionals

Sustainable Packaging Design Guidelines - Sustainable Packaging Coalition

The SPC guidelines for sustainable packaging were developed based on input frommultiple stakeholders These guidelines are intended to be used in the design stage andaddress reduction at source among other aspects of sustainability The use of theguidelines has been gaining support in the US and has been endorsed by the PackagingAssociation of Canada

The SPC guidelines are intended to be used in the design stage and address reduction atsource among other aspects of sustainability The SPC Sustainable Packaging DesignGuidelines

Provide an overview of full product life-cycle design for sustainable packaging Include various design-strategy sections

Sustainability (in terms of life-cycle impacts health impacts of materialsource reduction recycled content)

Transport Environmental best practices Fair labour and trade practices Renewable virgin materials Design for reuse recycling or composting

Are flexible and adaptable to the various needs of designers and requirements ofindustry

Extended Producer Responsibility

The stewardship of packaging waste was first legislated in Germany and was lateradopted by the European Union in the Directive on Packaging Waste The directiverequires member states to adopt specific targets for packaging recovery recycling andpackaging material content The directive also commits the commission to promoting thestandardization of criteria and methods for life-cycle analysis recycling and recycled

material content among others Additionally each member state must maintain a databaseto monitor and report on progress in reaching the requirements In recent years manyother jurisdictions have introduced EPR-based programs and requirements to managepackaging waste including Japan Korea and California

EPR requirements for packaging also exist in Canada In Ontario and Quebec the EPR-based Blue Box programs capture a wide array of packaging materials and have beensuccessful in diverting significant proportions of packaging waste Manitoba is currentlyin the process of developing regulations for a similar program

Ontariorsquos Blue Box Program

The Waste Diversion Act established Waste Diversion Ontario (WDO) to developimplement and operate waste diversion programs Industry funding is coordinated by theproducer-responsibility organization Stewardship Ontario Stewards are brand ownersand first importers of packaging and printed paper They report annually on the amountof packaging by material type introduced into the Ontario marketplace Fees arecalculated using a complex funding formula that includes consideration of program costsand the costs to manage different materials in the system and are paid by stewardsrelative to the amount of material introduced into the marketplace Fees are regularlyreviewed and factors are used to penalize materials that are more difficult to manage orachieve low recovery rates Targets are set for recovery and recycling of collectedmaterials and achievements are measured through reports submitted by municipalitiesSteward fees are also used for related activities such as education and promotion of theprogram and research and development on materials-management issues

The Waste Diversion Act and Blue Box Program are currently under review Possibleapproaches and issues being considered are

1 Full Extended Producer Responsibility2 Defining extended producer responsibility to benefit the environment3 Fee visibility4 Improving and extending stewardship5 Incorporating greater flexibility for industry in meeting extended producer

responsibility requirements

British Columbia Beverage Container Deposit-Refund System

The British Columbia Recycling Regulation establishes a requirement that beverageproducers take responsibility for end-of-life management of their containers within aprovince-wide deposit-refund system Two organizations collectively deliver theresponsibilities of beverage producers Brewers Distributor Ltd for refillable domesticbeer containers and imported and domestic beer cans and Encorp Pacific (Canada) forcontainers of all other beverage types

Demonstrating a commitment to environmental excellence beer brands under theBrewers Distributor Ltd stewardship program maximize the use of refillable industrystandard bottles which are reused more than a dozen times prior to recycling Under theEncorp Pacific stewardship plan differentiated fees are charged to beverage producers toreflect the true cost of collecting and managing the containers thus providing directfinancial incentives to select beverage packaging that can be cost effectively managed atthe end of its life Encorprsquos fees are revised periodically as market conditions change toensure that costs paid by producers reflect as closely as possible the actual the cost ofend-of-life container management

Germanyrsquos Packaging Ordinance

The German Packaging Ordinance (amended in 1998) legislates extended producerresponsibility assigning legal and financial responsibility for packaging waste materialsto producers distributors and retailers The legislation requires producers to take backand reuse or recycle all primary and secondary packaging

Duale System Deutschland (DSD) was established by industry in response to theserequirements Companies that manufacture and import products into Germany paylicensing fees to DSD to cover the costs of collection sorting and recycling of theirpackaging materials Failing to meet DSD requirements or reporting incorrectinformation can result in a fine

Germany has achieved significant packaging waste diversion as a result of the PackagingOrdinance in addition to other initiatives such as disposal charges and design forenvironment requirements In 2006 more than 80 per cent of packaging waste from bothmunicipal and production waste sources was recycled

Standards and Labels to Encourage Sustainable Design

Standards are often used to ensure the safety and performance of products Standardsoften have associated certification programs or labels to verify that a product or packagestandard has been met For example compostable plastics have inspired standards tocertify their compostability There is an American Society of Testing and Materials(ASTM) standard along with a Canadian standard developed by the Composting Councilof Canada related to the compostability of plastics

One of the most common labels associated with packaging sustainability is the Society ofthe Plastics Industry (SPI) resin-coding system SPI resins codes were designed tofacilitate recycling of post-consumer plastics by plastic recyclers in the United StatesThe SPI resin code standardized a mobius loop with assigned numbers 1 to 7 to identifythe resin content of plastic packaging This industry-led voluntary standard has becomemandatory in many states in the US More recently WRAP and the British RetailConsortium have developed and introduced a recyclability label to assist consumers inidentifying recycleable packaging

BNQ Compostability Standard for Plastic Bags

The Composting Council of Canada and the Bureau du normalisation de Quebec (BNQ)have developed a Canadian standard and certification program for compostable plasticbags The standard was developed through a multi-stakeholder process that includedplastics grocery and environmental organization representatives Recyc-Queacutebec initiatedthe process to determine which plastic bags were compostable in municipal compostsystems and to make it easier to distinguish those bags from others on the market Thethird-party certified standard was released in 2007 through the BNQ

Recyclability Label

The British Retail Consortium (BRC) and the Waste amp Resources Action Programme(WRAP) recyclability label was developed in consultation with representatives fromgovernment manufacturing and retail Through the use of a consistent label the BRC andWRAP hope to make it easier for consumers to manage packaging waste and increaseawareness of which types of packaging are recycleable in Britain

The label categorizes each of the materials used in a productrsquos packaging as Widely recycled ndash more than 65 per cent of local authorities recycle the material Check locally ndash recycled by between 20 and 65 per cent of local authorities Not currently recycled ndash recycled by fewer than 20 per cent Material designations

are updated annually

Industry Education and Promotion of Innovation

There are many examples of education and award programs dedicated to packagingreduction and improving packaging sustainability In the UK WRAP has developednumerous tools and resources to promote innovation across the retail-sector supply chainAs mentioned earlier two not-for-profit industry member organizations SPC andINCPEN have both developed sustainable packaging design guides to educate andpromote sustainable packaging approaches The Packaging Association of Canada (PAC)has introduced in collaboration with the SPC a curriculum for packaging professionalson The Essentials of Sustainable Packaging The two-day course is structured around theSPC definition of sustainable packaging providing design considerations and innovativeexamples from the packaging industry In addition PAC has an awards program for

leaders in sustainable packaging design Awards have also been introduced bygovernment agencies such as Recyc-Quebecrsquos recognition program for the IndustrialCommercial and Institutional (ICampI) sector to promote responsible management ofresidual materials with a view to sustainable development

WRAPrsquos Retail Innovation ProgrammeThe WRAP Retail Innovation Programme provides retailers an opportunity to collaborateon the reduction of food and packaging waste that is sent to landfill The programprovides expertise tools and resources including The Guide to Evolving PackagingDesign case studies technical and research reports a Best in Class database theInternational Packaging Study and The Concept Room to stimulate change

The Best in Class database the International Packaging Study and the Concept Room areresources for packaging designers that demonstrate real examples of innovative andreduced packaging design Particularly unique is the Best in Class database that providesdesigners with benchmark indicators of the lightest-weight packaging used for food anddrink products on UK supermarket shelves

Quebecrsquos ICI on Recycle Recognition Program

Recyc-Quebec has established a recognition program for the Industrial Commercial andInstitutional (ICampI) sector to promote responsible management of residual materials witha view to sustainable development

The program is voluntary with three levels of participation To qualify for level oneEngagement organizations must be actively working to improve their material-management processes Level two Implementation requires changes to have beenimplemented in their organizational processes Level three or Performance-levelrecognition requires that organizations achieve at least 80 per cent waste diversion Todate 102 Quebec organizations have been recognized through the program as level-threeperformers and over 500 more are engaged or are implementing changes through theprogram

Partnerships

In Australia and the UK partnerships with industry have been used to achievepackaging-reduction results and increase the recovery of packaging materials Thesepartnerships with industry allowed for a flexible approach to the complex issue ofpackaging sustainability and resulted in early action and efficiency in meeting targets

In Ontario voluntary agreements have been used to reduce plastic bags by 50 per centover a five-year period The agreement includes consideration of in-store and blue boxrecycling programs for retail stores and consumer education initiatives to promote thereduction use and recycling of bags in circulation

Australiarsquos National Packaging Covenant (NPC)

The Environment Protection and Heritage Council a body comparable to CCMEnegotiated Australiarsquos packaging covenant in 1999 As of 2008 the NPC has 706signatories including brand owners industry associations raw material suppliers andpackaging manufacturers Signatories must produce action plans and report annually onspecified performance indicators Industry must also pay an annual fee matched bygovernment which funds the National Packaging Covenant This includes the funding ofan independent body dedicated to administration and communications as well as supportfor research projects

The Covenant aims to achieve with the help of all participants a recycling target of 65per cent for packaging and no further increases in packaging waste disposed to landfill bythe end of 2010 State and territory governments contribute data funds and ensure thatwaste management systems facilitate achieving the targets The Covenant is mandatoryNon-compliant brand owners are subject to enforcement which is decided on byindividual jurisdictions

The United Kingdomrsquos Courtauld Commitment

The Courtauld Commitment is a voluntary agreement between the United Kingdomrsquosthird-party waste agency Waste amp Resources Action Programme (WRAP) and majorUK grocery organizations The Commitment established in 2005 aims to reducehousehold packaging and food waste More than 30 major retailers brands and suppliershave joined Courtauld since it was launched which represents 92 per cent of the UKgrocery sector The Commitment has made progress towards its objectives in 2008 itachieved zero growth in packaging despite increases in sales and populationTo deliver on their objectives retailers brand owners and suppliers are workingin partnership with WRAP to develop new packaging solutions and technologies acrossthe whole supply chain This includes collaborating on packaging design and promotingthe use of innovative packaging formats to reduce the weight of packaging and increasethe use of refillable containers

Engagement of Consumers

Engaging consumers in moving towards the sustainability of packaging has often beenachieved through education campaigns such as the advertising campaign developed byLoblaws to promote the use of reusable shopping bags An innovative alternate approachhas been used by the UKrsquos Industry Council for Packaging and the Environment(INCPEN) with the creation of a packaging watchdog organization to address customerfrustrations with perceived excess packaging

INCPENrsquos Packaging ldquoWatchdogrdquo

The UKrsquos Industry Council for Packaging and the Environment (INCPEN) is a researchorganization made up of companies who ldquoshare a vision of the future where allproduction distribution and consumption are sustainablerdquo

Between 1992 and 1996 INCPEN established and funded an independent multi-stakeholder council to encourage and promote good packaging called the PackagingStandards Council The council developed a code of practice and was mandated toencourage its implementation and to act as a consumer watchdog on packaging Thewatchdog took consumer complaints and investigated their validity Companies werechallenged to provide rationales for the packaging design and were asked to change basedon justified complaints

Appendix E - Sustainable Packaging Resources

Government Agencies and Affiliated OrganizationsCanadian Council of Ministers of the Environment Canadahttpwwwccmeca

Bureau du normalisation de Quebec Quebechttpwwwbnqqcca

Environment Protection and Heritage Council (EPHC) Australia and New Zealandhttpwwwephcgovau

Recyc-Quebec Quebechttpwwwrecyc-quebecgouvqccaclientfraccueilasp

Resource Recovery Fund Board (RRFB) Nova Scotiahttpwwwrrfbcom

Standards Council of Canada Canadahttpwwwsccca

Take it back Ottawahttpwwwottawacatakeitback

Waste Diversion Ontario Ontariohttpwwwwdoca

Waste amp Resources Action Programme (WRAP) United Kingdomhttpwwwwraporguk

Stewardship Program Organizations

Duale System Deutschland Germanyhttpwwwgruener-punktdeL=1

National Packaging Covenant Australiahttpwwwpackagingcovenantorgau

Stewardship Ontario Ontario Canadahttpwwwstewardshipontarioca

Industry Associations and Other Non-Governmental Organizations

American Society of Testing and Materials (ASTM) United Stateshttpwwwastmorg

British Retail Consortium United Kingdomhttpwwwbrcorguk

Compost Council of Canada Canadahttpwwwcompostorg

Packaging Association of Canada Canadahttpwwwpacca`

Packaging Council of Australia Australiahttpwwwpcaorgau

Society of the Plastics Industry (SPI) United Stateshttpwwwplasticsindustryorg

Sustainable Packaging Alliance Australiahttpwwwsustainablepackorgdefaultaspx

Sustainable Packaging Coalition (SPC) United Stateshttpwwwsustainablepackagingorg

The Industry Council for Packaging and the Environment (INCPEN) UnitedKingdomhttpwwwincpenorg

DISCUSSION DOCUMENTTOWARDS A PROPOSED CANADA-WIDE STRATEGY FOR SUSTAINABLE PACKAGING13

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

2 THE NEED FOR A NATIONAL SUSTAINABLE PACKAGING STRATEGY

3 KEY ISSUES

4 PROPOSED CANADA-WIDE STRATEGY FOR SUSTAINABLE PACKAGING13

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

Appendix B ndash Overview of Packaging Management Programs in Canada

PREFACE

Packaging is necessary to preserve and transport products but the materials are oftenused just once and making them consumes significant quantities of energy and resourcesIn recent years governments across Canada have become increasingly concerned aboutpackaging waste and resource use Consumer demand for greener products and reducedpackaging has also increased At the same time retailers have begun to push for moresustainable packaging both to reduce supply chain costs and to meet consumer demandfor green products and packaging Across the supply chain businesses are increasinglyembracing sustainability as a strategic objective and business imperative

Responding to these concerns the Canadian Council of Ministers of the Environment(CCME) Extended Producer Responsibility Task Group (EPRTG) has created thisdiscussion document to aid in the development of a strategy to reduce packaging inCanada and promote more sustainable packaging choices This strategy would form partof a larger proposed Canada-wide Action Plan making producers responsible for end-of-life management of products This document addresses the need for a strategic approachto packaging and proposes potential key elements for a Canada-wide approach onsustainable packaging

How can you contribute

We need your help to build an effective and meaningful strategy For this strategy to besuccessful input from you as producers importers brand owners retailers non-government organisations stewardship organizations consumers and governments isimportant

Your feedback is welcome and can be submitted electronically using the response formattached We would appreciate your response by May 29 2009

After this consultation all feedback will be considered in completing a strategy topropose to CCME

EXECUTIVE SUMMARY

Packaging

Table of Contents

PREFACEi

1 INTRODUCTION 1

3 KEY ISSUES 8

PACKAGING10

1 INTRODUCTION

What is packaging

The Problem

3 KEY ISSUES

Vision

progress

retailers

5 PROPOSED ACTIONS

reduction

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

EXECUTIVE SUMMARY

Packaging

Table of Contents

PREFACEi

1 INTRODUCTION 1

3 KEY ISSUES 8

PACKAGING10

1 INTRODUCTION

What is packaging

The Problem

3 KEY ISSUES

Vision

progress

retailers

5 PROPOSED ACTIONS

reduction

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

Table of Contents

PREFACEi

1 INTRODUCTION 1

3 KEY ISSUES 8

PACKAGING10

1 INTRODUCTION

What is packaging

The Problem

3 KEY ISSUES

Vision

progress

retailers

5 PROPOSED ACTIONS

reduction

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

Table of Contents

PREFACEi

1 INTRODUCTION 1

3 KEY ISSUES 8

PACKAGING10

1 INTRODUCTION

What is packaging

The Problem

3 KEY ISSUES

Vision

progress

retailers

5 PROPOSED ACTIONS

reduction

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

1 INTRODUCTION

What is packaging

The Problem

3 KEY ISSUES

Vision

progress

retailers

5 PROPOSED ACTIONS

reduction

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

The Problem

3 KEY ISSUES

Vision

progress

retailers

5 PROPOSED ACTIONS

reduction

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

The Problem

3 KEY ISSUES

Vision

progress

retailers

5 PROPOSED ACTIONS

reduction

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

3 KEY ISSUES

Vision

progress

retailers

5 PROPOSED ACTIONS

reduction

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

3 KEY ISSUES

Vision

progress

retailers

5 PROPOSED ACTIONS

reduction

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

3 KEY ISSUES

Vision

progress

retailers

5 PROPOSED ACTIONS

reduction

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

3 KEY ISSUES

Vision

progress

retailers

5 PROPOSED ACTIONS

reduction

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

3 KEY ISSUES

Vision

progress

retailers

5 PROPOSED ACTIONS

reduction

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

Vision

progress

retailers

5 PROPOSED ACTIONS

reduction

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

Vision

progress

retailers

5 PROPOSED ACTIONS

reduction

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

progress

retailers

5 PROPOSED ACTIONS

reduction

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

progress

retailers

5 PROPOSED ACTIONS

reduction

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

5 PROPOSED ACTIONS

reduction

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

5 PROPOSED ACTIONS

reduction

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

appropriate

packaging design

5 Engage Consumers

regulatory measures

ombudsman

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

levelofexte

ization

gdesig

Reduction

ackagin

ggenera

isposed

packagin

X X X X

Municipal Efforts

reuse and recycling

8 Toxicity Concerns

cradle cycles

Recyclability Label

Partnerships

PREFACE

EXECUTIVE SUMMARY

Table of Contents

1 INTRODUCTION

3 KEY ISSUES

5 PROPOSED ACTIONS

6 MEASURING SUCCESS

7 POSSIBLE TIMELINE

Documents

Discussion Document: Towards a Proposed Canada-wide