I'd like to address 2 points…

I'd like to address 2 points re: the proposed recycling legislation... 1) A consideration on the minimum sales/tonnage for participation, and 2) A request for a process that promotes more sustainable materials in recycling.

1) With regards to the minimum sales / tonnage for participation in the program...
I understand (and agree with), the need to limit the financial and administrative burden for smaller producer/importers. The downside to ignoring small producers is that it effectively allows them to put any type of material on the market (both good and bad). Individually this creates a small impact, cumulatively it's a problem.

Could small scale producers become participants in a voluntary program with benefits / incentives? Design a simple program that gets smaller producers & importing distributors reporting and thinking about the circular economy of their materials in the marketplace.

Why incentivize (spend money) on this?

i) More data would allow policy makers to see the range of companies willing to self report and with what materials.

ii) The process would educate on circular economy. If easy and positive in experience, it would help Canadian companies ask material questions to their suppliers and drive circularity in the supply chain.

iii) Incentivized small producer engagement would also raise the level overall business intelligence on our current material processing capacity and gaps. Right now it's all too easy for a smaller company to stay stupid on their products' fit with today's recycling systems. It's also too convenient to leave recycling priorities to the agenda of the big brands.

2) We need pathways for the adoption of a new materials into today's recycling systems...
New and more sustainable materials are caught in a "catch-22" position. A new material doesn't have enough volume to warrant formal addition to a recycling program, and when not accepted in a recycling program, a new material is less likely to be used. This "minimum viability" system design effectively suppresses new materials and supports established materials, with no consideration to the long term environmental impact of a material. Case in point... Polystyrene.

Materials that can go beyond performance in use and also demonstrate recycling potential with adherence to the twelve principles of green chemistry, should be provided with a clear pathway to acceptance in our recycling systems. A clearly defined pathway for material acceptance could even become a program through which the recycling industry supports a future with more sustainable materials.