January 4, 2018…

January 4, 2018
Mr. Ian Drew
Senior Policy Advisor
Ministry of the Environment and Climate Change
Climate Change and Environmental Policy Branch
40 Ste. Clair Avenue West, 8th Floor
Toronto, Ontario
M4V 1M2

Re: EBR Registry Number 013-1814.
MOECC (proposed) Food and Organic Waste Framework – Clorox Canada Ltd. comments.
On behalf of the Clorox Company of Canada Ltd., we congratulate the Ontario government for taking the initiative to support a circular economy and fight climate change with the development of the proposed Food and Organic Waste Framework that includes the Proposed Food and Organic Waste Action Plan & Policy Statement under the Resource Recovery and Circular Economy Act of 2016.

Our Glad® brand is the category leader in the trash and composting space and Glad® is Clorox Canada’s largest revenue business, playing a critical role in supporting 377 direct and approximately 1,200 indirect Canadian jobs in Ontario (including 110 direct and 330 indirect jobs at our Glad plant in Orangeville where our bio-resin composting bags are made for both the Canadian and the U.S. markets). The composting space is an important driver of growth, as well as R&D and capital investments for the company. Indeed, we’ve just brought on additional manufacturing capacity for our bio-resin composting bags in Orangeville to support the growth of composting programs throughout the country and have actively partnered with communities ranging from Montreal, Quebec to Calgary, Alberta to the Region of Halton, ON to support the roll-out of their programs with great success. In Ontario, we provide ongoing support for organics programs in Waterloo, Guelph, Niagara, Barrie, Aurora, Peel, and Simcoe.
Based on a growing and diverse fact base, the ability of citizens to use bio-resin composting bags has been shown to be a key factor in the success or failure of organics programs to reach their diversion goals. Why? Because data shows that municipalities that allow for bio-resin composting bags divert almost three times as much organic waste. The Region of Halton, ON provides a perfect local example. In communities that gave residents an option to choose between a paper or bio-resin bags, over three out of four residents chose the bio-resin option. This in turn drove those same communities to capture on average 130 kg per household per year compared to an average of 46 kg per household per year in communities where paper was the only option. Our consumer research shows that the principle reasons are two-fold: ease of use or what we call the “ick factor” and the fact that paper bags are over double the price of certified compostable bags. Understanding these insights is critically important to the success of the program and leads us to make the following recommendations:
1.Mandate– not just “encourage” that all Provincially approved centralized composting processing facilities accept certified compostable liner bags that meet the ASTM D6400 International Standard (pg 41. Section 2.3)
While the vast majority of existing large municipal organics programs in Ontario accept bio-resin composting bags that meet this standard there are jurisdictions that have yet to make that choice and a lack of clarity around the position of those that will be implementing future programs as a result of the province’s initiative. Clorox Canada has invested substantial capital developing innovative compostable products that meet the American Society for Testing and Materials (ASTM) standards for compostable plastics, known as ASTM D6400 (which is a the basis for the both the Biodegradable Products Institute (BPI) and Bureau De Normalization Du Quebec (BNQ) certification requirements). Within North America, both the BPI and the BNQ have structured their compostable bag certification programs around these parameters. By mandating the acceptance of bio-resin composting bags that meet this international standard, companies like ours that provide critical tools for food and organics composting programs will be able to commit to making the capital investments necessary to support the successful ramp up and subsequent achievement of the province’s ambitious diversion goals. Certainty around acceptance of this standard will also allow Ontario to leverage the substantial marketing expertise and resources that producers like Clorox can bring to bear to better educate consumers, driving awareness, adoption and ultimately success in meeting its food and organics diversion objectives.

Finally, Ontario has an opportunity to establish itself not only as the manufacturing center for Canada but for North American for bio-resin bags that meet these standards, opening a substantial opportunity to generate economic activity from the export of these bags to the U.S. as it ramps up its organics programs. Clorox has already begun investigating the opportunity to supply bags using this standard from Orangeville, ON to support New York City’s organics program as it takes shape. Just this opportunity alone would be larger than the economic activity generated by supplying the entire existing Canadian market.

2.The Framework should include not only long range diversion and participation targets but interim targets to ensure consistent progress towards the goals set out and to provide a clearer road map for companies investing to support this initiative.

A target that is 8 years from now, in the case of many Ontario communities that will be developing organics programs can seem far away until it isn’t. Without intermediate goals and targets, municipalities may be tempted to push back or delay crucial decisions to the detriment of the environment, success of the action plan and the private sector investments in the organics ecosystems necessary to adequately support it.

We thank the MOECC for the opportunity to provide our input and welcome the opportunity for continued direct dialogue with Ministry officials.

Sincerely,
Mike Pilato
President and General Manager
The Clorox Company of Canada Ltd

[Original Comment ID: 211685]