Canada – Cost-benefit Analysis Survey for Plastic Packaging

The approach outlined in the regulatory proposal and information received during consultations and from this survey will be used to draft proposed regulations. The proposed regulations would be targeted for publication in Canada Gazette, Part I, as early as fall 2023 for public consultation.

Cost-benefit analysis survey for industry

As part of the regulatory development process, ECCC needs to identify and assess potential costs that could be incurred by industry, Canadians and the Government. We are seeking information from industry on potential impacts and costs that could be incurred from this regulatory proposal.

Please fill out this survey to the best of your knowledge and share any other costing considerations that this survey did not identify. Your participation and input will inform regulatory analysis and a cost-benefit analysis (CBA).

Please share this survey with other Canadian stakeholders who may have input.

Survey responses will be accepted until February 10, 2023 using the link provided.

Connect with us

ECCC will be offering a webinar to provide more information and respond to questions about the survey. If you are interested in attending, please e-mail and indicate your preferred date for attendance.

English: January 11, 2023 from 2-3pm EST
French: January 12, 2023 from 2-3pm EST

The Regulatory Proposal

Please note the information below may not represent the proposed regulation that will be published in Canada Gazette I or II and is subject to change. This is simply a summary of the proposed approach to develop the regulations to help guide respondents on the purpose and intent of this survey.

The regulatory proposal would be comprised of two parts. Part I would establish rules for minimum recycled content in certain plastic items, while Part II would establish rules for recyclability and compostability labelling of plastic packaging and single-use plastics.

The desired outcome of the regulations would be to improve the performance of recycling systems to divert more plastics from landfills and the environment, and to drive a more circular economy.

Part I (Recycled Content)

Part I would seek to achieve this outcome by requiring a minimum percentage of recycled content in certain plastic packaging and certain plastic manufactured items in commerce in Canada, thereby inducing greater market demand for post-consumer resin. ECCC published a Notice of Intent and Technical Issues Paper for public comment in winter 2022, which described key elements of the proposed recycled content requirements. From this consultation process, industry and stakeholders provided valuable feedback that helped ECCC to develop the regulatory proposal.

To capture the majority of plastic packaging in Canada, the Technical Issues Paper proposed covering the following plastic packaging categories:

Beverage containers. ​For containing carbonated and non-carbonated beverages including, but not limited to, water, soft drinks and juice.
Bottles (other than those in direct contact with food). For containing products such as motor oil, laundry detergent, cleaning products, shampoo and other personal care products.
Non-bottle rigid containers and trays (other than those in direct contact with food). Items such as clamshells, jars, pots, trays, pails. For containing products such as paints, plants, cleaning products, cosmetics, housewares, electronics, appliances, sports equipment and toys.
Foam packaging (other than those in direct contact with food). Items such as trays, containers, and protective packaging. For containing products such as housewares, furniture, electronics and appliances.
Film and flexible plastic packaging (other than those in direct contact with food). Items such as film bags, woven and net bags, stretch wrap, shrink wrap, stand-up pouches, and bubble wrap. For containing or protecting products such as clothing, flyers, housewares, cosmetics, furniture, electronics, appliances, sports equipment and toys.
Garbage bags. Bags of various sizes intended for storage and disposal of waste, excluding organic bin liners.
Waste bins. Garbage, organics, and recycling bins and containers.

The following product categories are being considered for exclusion:

Drugs and devices as defined in the Food and Drugs Act
Dangerous goods and waste as defined in the Transportation of Dangerous Goods Act, 1992

ECCC is also considering excluding product applications from the scope of the regulations in cases where:

other legal requirements do not allow for the use of recycled content in the product
use of recycled content in the product could create risks for human health or the environment

Part II (Recyclability and Compostability Labelling)

Part II would seek to reduce contamination in the recycling stream by improving the accuracy of recyclability and compostability information on plastic packaging and single-use plastics, as well as incentivize producers to re-design their packaging to make them more recyclable. The Government of Canada has committed to introducing labelling rules that prohibit the use of the chasing-arrows symbol on plastic products unless 80 per cent of Canada’s recycling facilities accept, and have reliable end markets for these products.

Based on available information, the plastic products most commonly accepted by recycling facilities are bottles and non-bottle rigid (includes plastic tubs and containers for packaging dog and cat food, margarine and cooking oils, and other food). These products are often made of the most commonly recycled resins: polyethylene terephthalate (PET), polyethylene (PE) and polypropylene (PP). The least commonly accepted plastic product is film. This information serves as ECCC’s starting point for further engagement to define what is included in the 80 per cent acceptability threshold.

In addition, the Government is seeking to address inaccurate compostability, biodegradability, and degradability labelling for plastic products. The Government is proposing to prohibit the labelling of plastic products as degradable or biodegradable and require plastic products labelled as compostable to be certified by a third party to a specified standard or standards.

Part II of the regulatory proposal may apply to consumer-facing single-use plastic packaging and single-use plastic products in Canada. This would include plastic packaging and single-use products that are intended to be used by the public and where recycling outcomes depend on the public’s knowledge of recycling and their behavior (e.g., sorting, rinsing, and separating material before collection).

The proposed approach for recyclability labelling rules would require that a plastic item be assessed for recyclability, according to criteria that would be specified in the proposed regulations, before it could be labelled as recyclable. The criteria would be based on the following principle steps in the recycling process:

acceptance in public collection systems (e.g., accessible to 80% of the population)
sorting, cleaning and baling
re-processing (turning sorted plastics into feedstocks for new plastic products)

On July 25, 2022 the Consultation paper: Towards Canada-wide rules to strengthen recycling and composting of plastics through accurate labelling was published for a public comment period that ended on October 7, 2022. In addition, the Government organized both general and technical webinars to share information on the proposed approach and solicit information. Feedback provided by industry and stakeholders during the consultation process is being considered in the development of Part II of the proposed regulations.