Toronto Environmental Alliance

The following responses were submitted by the Toronto Environmental Alliance (TEA) to the Canadian Council of Ministers of the Environment (CCME) as part of a public consultation to review the proposed sustainable packaging guidelines prepared by Five Winds International.

Submitted: March 3, 2008

1. The consultation document recommends that CCME adopt the Sustainable Packaging Alliances’ definition of Sustainable Packaging. Please provide your thoughts on this recommendation.

The SPA definition has a fundamental problem: it fails to recognize the part packaging plays in a much larger, more complex product system.  The Toronto Environmental Alliance (TEA) strongly suggests that the CCME adopt a definition that acknowledges how products and packaging go hand-in-hand and affect one another. Put simply, any definition of sustainable packaging must be viewed as part of a larger EPR discussion which acknowledges that a product system drives packaging.

As the Five Winds International report points out, defining what is the 'best material' for packaging will depend entirely on the product system and application.  There are many more examples of how the product system dictates the necessity, design, and use of packaging; such as the quantity of products, the transportation system that is used, how the products are stored, what type of consumer information is needed, etc.

By acknowledging the role packaging plays in the product system, we can encourage collaborative efforts between all players.  For example, this may provide opportunities for certain products to be re-designed in a way that directly reduces environmental impact, and subsequently re-structures the design, or even the need, for packaging.

Also, the SPA definition assumes that packaging has a ‘value to society’ because packaging provides the ‘important function’ of protecting products and informing consumers. This is highly problematic and should be reworded. While packaging can sometimes serve to protect products throughout the supply chain, or ensure safe and/or informed consumption of the product, more often packaging can be a nuisance, an additional cost for municipalities and tax payers, and a burden on the environment.

True sustainable packaging approaches should be part of an entire product system that strives to reduce environmental harm, in particular limiting the necessity of packaging, where possible.

2. The consultation document recommends that CCME refrain from developing new guidelines and consider formally reviewing and subsequently endorsing the Sustainable Packaging Coalition’s guidelines. Please provide your thoughts on this recommendation.

While the SPC Design Guideline may have some clear targets, based on its definition and performance parameters, TEA does not think that CCME should endorse them as their own.   

We do not share Five Winds’ opinion that “writing a new set of guidelines will do little to advance sustainable packaging in Canada.”  Rather, TEA believes that the EPRTG should create a guideline which ensures that producer’s are responsible for their packaging at all life-stages, including the external costs faced by municipalities and taxpayers in the post-consumer phase. This principle is not articulated in the SPC Design Guideline.

As suggested above, if the EPRTG is serious about reducing environmental harm, it must look at packaging as part of the overall product system.  Otherwise, this initiative will do very little to contribute to sustainability.

3. Please identify any key areas that you think the guidelines provided by the Sustainable Packaging Coalition do not address.

The SPC guidelines are lacking in the following areas which TEA believes are important:

1.    It’s unclear how well these guidelines will promote a true EPR system in Canada. The performance parameters for packaging clearly set targets to design for reuse, recycling, or composting; but these guidelines do not address the need for producer’s to take full responsibility for their packaging and products.  Also, the parameters do not address the producer’s responsibility to manage any post-consumer costs associated with their packaging and/or products.  Accordingly, the SPC’s Design Guidelines should be approached with caution.

2.    The guidelines are intended to be used primarily by packaging designers and therefore cannot be used by designers throughout the entire product system.  While we expect the SPC’s Design Guidelines to focus on packaging, the EPRTG should be considering a more system-wide approach that motivates all stakeholders to become involved in EPR.

3.    The SPC Design Guidelines are voluntary, intended to provide best practice only.  The EPRTG should be considering other approaches such as a scorecard, regulation, or decision-making tool that can be made mandatory.  Looking beyond domestic products and packaging, how can we expect imported goods to have standardized packaging requirements without regulation?
 

4. The consultation document recommends that CCME consider an additional set of 7 ideas and actions to support its mandate. Please provide your thoughts on this recommendation and on the ideas presented.

The Toronto Environmental Alliance (TEA) is very concerned that none of the 7 ideas and actions outlined in this report set any specific target or goal towards environmental improvement or reducing environmental harm.  Furthermore, all of the ‘next steps’ focus on ‘soft’ policy approaches and we believe that ‘hard’ policy approaches such as regulations and codes of practice should be researched and reviewed.