Comment
My comments are centred around the “Management Requirements” section (section 6):
- Independent Life Cycle Analyses (https://www.flexpack.org/resources/sustainability-resources) show that flexible packaging generates 4x less GHG emissions than paperboard cartons, 5x less than rigid plastics, 8x less than metal cans, and 18x less than glass containers. Why don’t the Management Requirements reflect this fact, and require each material to have a recovery rate based on their relative GHG emissions? Wouldn’t this generate the greatest benefit to the environment?
- Under what material category will aseptic cartons (juice boxes, TetraPaks, etc.) go? These are multi-material laminations, consisting of varying amounts of plastic, paper and metal.
- What penalties will there be for Producers that don’t meet the Management Requirements or refuse to report on them?
- In order to ensure jobs in Ontario are not destroyed as a result of this new regulation, imported goods need to be on a level playing field with locally produced goods. What process will you have in place to monitor retailers and ensure they are accurately reporting imported goods sales?
Submitted November 11, 2020 9:44 AM
Comment on
A proposed regulation, and proposed regulatory amendments, to make producers responsible for operating blue box programs
ERO number
019-2579
Comment ID
49550
Commenting on behalf of
Comment status