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Earlier this week, HRAI joined forces with AHRI to submit comments to Environment and Climate Change Canada’s Plastics and Waste Management Directorate concerning their proposed “Integrated Management Approach to Plastic Products to Prevent Waste and Pollution.”

The associations applauded the government’s efforts to eliminate plastic pollution in Canada by potentially banning or restricting certain harmful single-use plastic products, and noted that members have played an active role in designing products that minimize waste and maximize recyclability.  AHRI and HRAI acknowledged that the proposed “integrated management approach” described in the discussion paper is a good step forward in achieving the Government of Canada’s goal of zero plastic waste by 2030.  At the same time, the submission strongly encouraged the government to exercise care to avoid adverse economic, public health, or social impacts.

HRAI and AHRI encouraged ECCC to consider the “distributional impacts on the HVACR and water heating industry and request that the Government of Canada avoid creating an unsustainable and unfulfillable mandate on manufacturers.”  The submission encouraged the government to consider the costs of any action proposed to achieve their objectives. The associations also requested that any proposed actions avoid placing the entirety of the cost solely on the manufacturing industry; responsibilities should be jointly shared by the producers of plastic products and packaging material.

AHRI and HRAI also supported special consideration (and possible exemption) for single-use plastics that perform an essential function and for which no viable alternative exists. For example, AHRI and HRAI support exemptions for non-consumer oriented, transport or tertiary packaging used for storage and transport of manufacturers’ products both domestically and across borders.

The Government of Canada is considering the use of product performance standards for plastic products and packaging to assist in generating a sufficient, stable and predictable supply of materials.  AHRI and HRAI expressed support for establishing and expanding viable infrastructure programs to reduce and reuse single-use packaging and waste.  Industry members manufacture highly complex and technologically sophisticated products that require safe transportation throughout the supply chain and it is imperative that this equipment reach its destination without damage. AHRI and HRAI therefore encouraged the Government of Canada to consider distinguishing between non-consumer oriented packaging (i.e., transport or tertiary packaging) and point-of-purchase packaging (i.e., primary, sales or secondary packaging).

Non-consumer facing packaging and point-of-purchase packaging will require different recycling and waste management processes, creating different opportunities to reduce and recycle plastics. AHRI and HRAI encourage the Government of Canada to recognize these differences as well as the need for the flexibility to package highly specialized HVACR and water heating equipment to prevent damage. This may require some consideration of exemptions based on the intended use of the packaging or plastic materials.

The associations also supported establishing recycled content targets by product type, assuming a distinction is made between consumer-oriented and non-consumer-oriented (i.e., transport or tertiary) packaging.   AHRI and HRAI supported the government’s target of at least 50% recycled content in plastic products by 2030 as a reasonable and realistic target, while balancing source reduction with the need to ensure that society’s needs are met, especially while recycling options are limited.

The submission discouraged the Government of Canada from putting forth an economy-wide option that would establish recycled content target/requirements for plastic products without differentiating between sectors, products or resin types and opposed a requirement for 100% recyclable content in non-consumer-oriented packaging, as some single-use plastics and packaging materials are necessary to prevent damage to equipment and recycling options are currently limited.

As the Government of Canada considers the approach for measuring and reporting on recycled content in products, AHRI and HRAI agree that the key issues listed (i.e., definitions of recycled content, method of tracking chain-of-custody, and flexibility) in the discussion paper are central to developing successful performance standards. 

Finally, AHRI and HRAI and members urged the government to utilize the industry’s technical feedback and expertise to find the most effective approaches to ensure accountability and compliance.

AHRI and HRAI recommended that the government consider creating a readily available website resource that identifies recognized and accessible recyclers around Canada that would satisfy the end-of-life provisions.  This added resource would assist industry in meeting the proposed provisions around end-of-life responsibility.

AHRI and HRAI requested that the Government of Canada continue to collaborate with industry to achieve Canada’s goals to eliminate waste and plastic pollution.  The associations offered to provide feedback and technical expertise to identify areas where reducing waste and plastic pollution will be feasible from an environmental and economic standpoint while still delivering critical products to meet society’s needs.

To see a copy of the full submission, click HERE.

For further information, contact Martin Luymes at mluymes@hrai.ca.