by JONATHAN D. COCKER AND DENISA MERTIRI
Governments across the globe are grappling with the , which threatens wildlife, marine ecosystems and may negatively impact human health. To deal with this threat, the Government of Canada is demonstrating leadership by pledging to increase plastic waste diversion, reduce single-use plastic in its operations, meetings and events, and procure sustainable plastic products.
In September 2019, the federal government put out a Request for Information (RFI) on upcoming requirements on packaging in public services and Procurement Canada procurement to a variety of stakeholders, including industry, suppliers, and non-profit and environmental groups. The government requested input on how to reduce waste through more sustainable packaging requirements in federal procurement. It also sought to ascertain suppliers’ readiness for sustainable packaging requirements.
The RFI is one of a series of steps that Canada has taken to demonstrate leadership in the fight against single-use plastic. Over the past few years, Canada has spearheaded the international Ocean Plastics Charter, committed to a ban on harmful single-use plastics by 2021 and collaborated with the Canadian Council of Minister of the Environment (CCME), an organization comprised of 14 federal, provincial and territorial ministers of the environment, on a national Strategy on Zero Plastic Waste. This Strategy has so far resulted in a Phase 1 Action Plan, but the results of the CCME’s Phase 2 consultations are still outstanding.
Despite the COVID-19 pandemic, the federal government has reassured the public that it will continue with a plastics ban, even if a bit delayed. The government has also reiterated its commitment to designate plastics as toxic substances under theCanadian Environmental Protection Act (CEPA), which aims to protect the environment, human life and health from the risks associated with toxic substances. To date, the government has fulfilled one of the requirements for listing plastics as toxic substances under CEPA by releasing a Draft Science Assessment of Plastic Pollution in January 2020.
The government’s RFI process now examines the use of the federal government’s purchasing power to make smart and sustainable choices among its suppliers. Though valuable for the Government of Canada, the key lessons from industry responses obtained from this RFI process are useful for any level of government looking to demonstrate leadership and take action to reduce plastic waste in its own operations.
Key Findings of the RFI
The government reported six (6) key findings from the feedback solicited through the RFI:
This is no small task and one that the federal procurement process itself will not resolve.
At present, there is no concrete plan to mandate LCA or EPD documentation as a condition of supply to the federal government.
There is immediate requirement that the necessary recycling or composting facilities be available to complement supplied packaging.
Recycled content requirements remain unresolved, particularly in light of the current low prices for virgin material.
There is a lack of current infrastructure to make take-back obligations part of the federal government procurement standards.
The federal government intends to push forward with its procurement standards, recognizing that they may be imperfect when first introduced into the market.
The RFI strongly suggests that inter-governmental harmonization is necessary for Canada to move toward a zero-waste target and become a global leader in plastic waste and pollution reduction. The outcome of the RFI is likely to be congruent with the intentions of the CCME’s Strategy on Zero Plastic Waste and the results of Phase 2 of the CCME Action Plan expected to be released in the near term. In working to develop requirements for sustainable federal procurement, the RFI aligns with the federal government’s leadership on plastics to date and its actions on the CCME’s Strategy, which set the foundation to Canada’s approach to a circular economy for plastics. There are, however, many significant implementation issues to be resolved.