At this stage, progressive adoption of sustainable diets (see Goal 2, Demand Supply Coordination), the progression of alternative food retailing and shortening of supply chains (see Goal 1, Access to Alternative food retail), and continuing shifts in household demographics and work routines (see Goal 9), are producing changes in shopping habits, reductions in processed food consumption, and increasing demand for smaller packaging units. Cooking skills and wider-angle food literacy are increasing (see Goal 3, Public Education). With all this comes reduced demand for convenience foods (pre-cut produce, ready to eat meals, etc). While important, all these shifts are insufficient to advance fully packaging change.
Make resource minimization a key feature of food packaging approvals
Taxes / penalties on virgin plastic and its applications
Limit packaging unit sizes for consumer goods (primary packaging)
Redesign stores and food service for food packaging minimization
Implement full EPR within a circular economy framework
Create more plastics mitigation plans associated with CEPA toxic designation
Design competitions to integrate universal design for accessibility with sustainability
Continue to support and implement a global Convention on Plastics Pollution
Make resource minimization a key feature of food packaging approvals
Under current approval processes, the focus is on food safety, and as discussed under Jurisdiction, there is little regulation of resource consumption to produce packaging materials. There are several elements to the implementation of environment assessment, related to both materials and use. The federal proposed integrated management approach to plastic products suggests that the government is moving in this direction but will likely use CEPA to regulate environmental performance of plastics. This is feasible because some, if not ultimately all, plastics will be designated CEPA-toxic, and therefore require a mitigation strategy. Other packaging materials, however, would not likely receive such a designation, although there are regulations under CEPA and other acts that attempt to manage pollution from the mining, oil and gas and forestry sectors. Although I'm generally in favour of using existing instruments where feasible, given the wide range of environment resource consumption issues beyond plastics, CEPA is too limited as currently constructed, so new legislation is required that addresses food packaging issues beyond their role as pollutants and toxic substances, both of which can still be addressed through CEPA. Although there are promises from the Trudeau government to modernize CEPA, and the Standing Committee on Environment and Sustainable Development (2017) made extensive recommendations on how the Act should be modernized, there is not much in the report that focuses on resource use efficiency.
The federal government should pass a new Food Packaging Resource Minimization Act., designed after the Energy Efficiency Act. The Act would allow the Minister to do several things:
- Create technical standards for environmental performance and certification that specify the conditions under which materials will be approved and certified as sustainable. The federal proposed integrated management approach to plastic products, released as part of the details on the single use plastics ban, states the federal government will look at environmental standards because of the proliferation of plastics, but provides no details at this point. Most packaging materials are derived from wood, petrochemicals and mined minerals and these would be the focus of the technical standards. There would also be sections on the most common biomaterial alternatives, e.g., soy inks, bamboo paper wrap, cornstarch plastics. For Forestry products, existing standards can be referenced. The technical document would specify degree of compliance with existing standards, e.g., do all paper/cardboard products have to be from certified wood, or 100% post-consumer recycled material. But it would also have to facilitate or create standards in areas that are poorly developed at present. This might take advantage of the experiences of developing organic food standards in association with the Canadian Standards Association and the Canadian General Standards Board (see also Goal 5, Sustainable Food).
- Align packaging choices with foods and beverages to optimize safety and environmental impacts (a different form of fit for purpose) and reduce our use of plastics. Often packaging decisions are based on safety, convenience, sales volumes, unit pricing and marketing (NZWC, 2020). Instead, packaging choices must be aligned with safety and environmental performance (see, for example, a review of the pros and cons of different materials by Marsh and Bugusu, 2007). Taking this approach may result in some cases in reduced consumer convenience and appeal, but by setting national standards for environmental performance to complement what exists on the food safety side, all companies will have to comply. Combining optimized packaging and a circular economy, the core idea is to use and then keep materials circulating at levels of high utility and value for as long as possible and then reallocate them to lower priority uses at the end of their life. For example, dry pasta is a prime opportunity for bulk / loose sales, without packaging (NZWC, 2020). Root vegetables and skinned fruit that are typically peeled and / or cooked are also often sold in bulk and can readily be bagged in consumer-brought reusable produce bags without food safety worries. Glass bottles work well for high temperature processing and sterilization, and are environmentally beneficial when local distribution and recycling systems are in place to reduce transport expenditures and assure multiple uses. Once it's lifespan is over for a specific use, the glass can be sorted, crushed and melted and used again in other container. Virgin aluminum is very energy expensive, but the recycled aluminum is only 5% of the energy cost. Recycled aluminum is very suitable for beverage cans so this is likely a priority use. The Industry says the average has been about 68% recycled aluminum in cans, but some have argued that it could be 90%, since at least one company can manufacture cans to that requirement. The industry appears to be reluctant to attach itself to a limited number of suppliers who can deliver (Gunther, 2014). In this approach to aligning containers with highest value uses, plastics are reserved for the packaging uses where other packaging doesn't make sense, for example in fragile produce.
- Related then to the previous point, governments need to mandate recycled content. Many companies are moving in this direction, but regulation will be required to accelerate and broader the uptake. Glass and metals are more impervious than plastics, so using recycled plastic can be more problematic, with more potential contamination problems. The federal proposed integrated management approach to plastic products has set a 50% recycled content target in plastic products by 2030, but this is aspirational at this point because the measures to make this mandatory and logistically feasible, and to also apply it to other packaging, are not yet in place (hence the need for this new legislation). The federal document also recognizes the many definitional, monitoring and delivery challenges of doing this for plastics. Provisions here would also have to build upon the environmental certification provisions of the Competition Act (see Efficiency).
- The technical document associated with the legislation (or there could be several on different themes) would specify what has to be made from biomaterials, not fossil fuels, and what those permitted biomaterials are. The Environmental Labels and Declarations document of CAN/CSA, once augmented as discussed under Efficiency, could be the reference document for regulations. Biodegradable plastics that are not completely biomaterials must be banned. Priority packaging materials made from biomaterial include:
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- Kitchen garbage bags.
- Takeout containers.
- Produce stickers on the skins of fruit and vegetables
- Multimaterial packaging, liners and inks would have to be readily compostable. Many are in development (cf. Foodprint).
But a key requirement of this process is not using primary biomaterials, but instead biomaterial waste or bio-byproducts. This is because we need to avoid overexploiting industrial applications of food lands, given that arable land for food products is in increasingly short supply, and there are already many examples of industrial and non-edible uses superceding production of food for local communities (see Goal 5, Bioproducts). Biomaterial production must not be competing with food producing resources. Equally important, given the capitalist tendencies to surplus accumulation (see Goal 5, Food Waste Reduction), these biomaterial wastes must not generate higher levels of food waste to meet biomaterial needs, in other words, they must be worthless except for biomaterial application. All this speaks to the need for Demand Supply Coordination (see Goal 2). As an example of what's required, bioplastics from food waste and seafood shells are already in development (e.g., Rukavina, 2018), which is encouaging, and hopefully less expensive than using virgin biomaterials, but existing R&D industrial incentives and prizes for innovation in this field may be required because it is currently a very small part of the packaging market place (Guillard et al., 2018). An additional key requirement, informed by LCA, is that waste management infrastructure has to be in place, otherwise it's a waste of resources (Leigh, 2019). However, these types of packaging will likely need to be composted in an industrial facility because of their complexity (Pauer et al., 2019). Edible films are a very specific dimension of biodegradable packaging materials and there may be specified circumstances in which they must be used because their food safety value is significant and there is no feasible possibility of reuse or recycling. Such films are typically derived from corn protein, whey, collagen (constituent of skin, tendon, and connective tissue), and gelatin (product of partial hydrolysis of collagen) (Marsh and Buguru, 2007).
There remains an open question about whether this Act would also aggregate food packaging related dimensions of other legislation, such as the Safe Food for Canadians Act and the Food and Drugs Act to create an integrated approach to food packaging approvals.
Taxes / penalties on virgin plastic and its applications
In part because of subsidies to the fossil fuel industry, recent low market prices, and the failure to internalize externalized costs, virgin plastic is very cheap and this, among other factors, discourages use of recycled plastic. Removal of fossil fuel subsidies is likely a very long term agenda, and in the absence of such initiatives, taxing virgin plastic should be implemented. Discussisons of taxes on virgin materials have been around for some time (cf. Pearce and Turner, 1993). Denmark first introduced taxes on raw packaging materials in 1978 (Voulvoulis and Kirkman, 2019). Such actions would likely move the industry towards plastics that are easily reused and recycled (e.g., PET, Polyethylene terephthalate, and HDPE), potentially reducing the tens of thousands of types in use today. It might also relatively favour certain sectors, such as the produce industry, given that PET is the most commonly used plastic in the Canadian produce industry (Gooch et al., 2019).
However, a tax on virgin plastic only works if there is sufficient recyclable material to allow companies to shift, and at an affordable price. That's why improving plastic recycling rates, especially in key materials, beyond Canada's current 9% is a critical precursor to a tax.The significant reduction in Chinese purchase of recyclable materials and manufacturing has reduced supply and driven up the costs of recycled materials, so there needs to be a robust domestic plastics recycling industry with the appropriate plants for this to be effective and Alberta has recently announced that it wants to develop such a vibrant sector. Peake et al. (2018) identified the need for infrastructure to help identify food contact material fohttps://foodpolicyforcanada.info.yorku.ca/citations/r recycling as this is critical to an effective recycled primary packaging. In addition, they highlight the California case whereby the state government has significantly improved the state plastic reprocessing industry by paying up to $150 per tonne to plastics reprocessors and manufacturers using recycled plastics (Plastic Market Development programme). Clearly, government infrastructure support is required to help this happen.
Voulvoulis and Kirkman (2019) proposed an approach for the UK that involves a tax on plastics that were not at least 30% recycled content (already about 25% of the market). A flexible tax that made up the difference between virgin and recycled material would amount at the time of their estimates to £150 per tonne. They estimated it, along with current trends, would drive recycled content to 75% of the market within 5 years and create thousands of jobs in the recycling sector. If the costs of the tax were passed on to consumers, it would amount to less than 16p / household / week. An alternative approach, named by Peake et al., (2018) for the UK, would be to reduce value added taxes for materials with recycled content. In Canada, the equivalent action might be to provide a zero rating on HST for such products. At the moment, based on some tax cases, it does not appear that CRA has a coherent approach to recycled goods or recycled content, though for the most part they appear to be taxable, so this would require significant changes. A third approach, based on the French system of modulating fees (bonus/penalty) could be applied at the packaging approval stage (cf. Watkins et al., 2017). If a firm wanted to continue with a packaging product that was difficult to reuse/recycle (e.g., opaque PET bottles), a penalty would be applied prior to approval. If they agreed to put forward instead a product that was easy to reuse/recycle, a bonus would be provided.
Such an approach might also Inspire a plastics repair sector for secondary and tertiary packaging with relatively minor damage, although this does not appear to have been well studied.
Limit packaging unit sizes for consumer goods (primary packaging)
Unit sizes for consumer food goods are regulated under Schedule 3 of the Safe Food for Canadians Regulations (SFCR), but there are too many shapes and sizes permitted, given the need for resource minimization. The schedule should be modified to reduce the number of unit sizes permitted, based partly on an analysis of what was done in WWII, and the resource minimization requirements of the new Food Packaging Resource Minimization Act (see above). A key consideration, however, is retaining some smaller sizes to help with food waste minimization. This is important given shifting demographic and household circumstances, particularly the number of aging Canadians and also those living alone.
Redesign stores and food service for food packaging minimization
Many independent health and eco-stores and food service operations have redesigned to reduce food packaging (see Zero Waste Canada's directory of low waste retailers and food service). This means different layouts, equipment and checkout processes. It requires different procurement strategies and back of store / back of restaurant handling. Some core changes could include:
- Expanding bulk dry goods, with consumers bringing their own containers or paper bags available. Pasta is the best according to NZWC as it shows the greatest promise for significant relative GHG emission reductions with prepackaging elimination. However, breakage would be an issue with some pastas like spaghetti. Others might work with very simplified low resource packaging, such as rice, pulses, quinoa, barley, flaked grains, some cereals. Many health food stores use pouring tubes for dry goods.
- The deli counter and in store bakery, working more from bulk delivered supplies rather than prepared or semi-prepared items. This also likely means more chef training for staff (see Goal 8 Labour Force Development).
- Similarly, the meat department needs to be redesigned. In large supermarkets, most meat arrives from central warehousing, prepackaged and with few trained butchers to work from whole animals or sides. Changing this is complex because butcher demand and training has dropped off precipitously (see Goal 8 Labour Force Development), meat departments aren't necessarily designed for butchery, and the weekly stock up approach to shopping and the focus on fresh rather than frozen means food safety issues can be problematic if meat is wrapped in paper as it used to be and sits in the fridge all week before being consumer. Multiple variables need shifting here, but always with an eye to minimizing food safety issues (see also Goal 4). Smaller shops and local butcher stores are more amenable to such changes. This is also an issue in restaurants (see Goal 5 Food Waste Reduction).
- Consumers bring their own produce bags for bulk produce that is durable (root vegetables, squashes, thick skinned fruits and vegetables. brassicas, citrus. Display labels and shelf talkers replace the information displayed on the bags no longer in use, however, stickers are retained for PLU codes but the stickers must be made from biomaterials (see above).
- Restaurants: drinks are a strong opportunity for self-serve in glasses and mugs, though this requires some adjustments to spaces which restaurants do not typically want to do it if means losing table space. In many workplace cafeterias, it will be possible for employees to be given reusable takeout containers that they are responsible to manage.
- Self-check out lends itself to weighing your own goods and a sticker that goes with them.
- Training consumers.
Some Canadian cities have now instituted green standards for residential and non-residential building siting, commissioning, design and construction. These municipal green design standards are the most promising instrument to use for implementation (see Goal 5, Food Waste Reduction). This approach works for new builds, but existing store and restaurant conversion is more challenging. When ownership changes and new inspections are required, these could be moments for the municipality to encourage changes. A provincial infrastructure renovation fund would need to be established to add to the encouragement. It could be modelled on grant programs such as the Ontario150 Community Capital Program that operated in 2016/17. Most provinces have an infrastructure unit and northern communities and territories often have infrastructure funds and administration operated by the Federal government (e.g., FedNor).
Implement full EPR within a circular economy framework
The essential difference between EPR and product stewardship approaches are that the former forces firms to internalize costs that are borne by governments and consumers or externalized to the environment. Although companies can still pass on costs to consumers in their product / service pricing under an EPR approach, they must also typically redesign products to improve environmental performance otherwise the back-end costs price their goods / services out of the market. In product stewardship programs, like Ontario's blue box program, there is no significant incentive for product redesign to improve environmental performance (Arnold, 2019).
The federal government acknowledges that a more consistent, comprehensive and transparent approach to EPR is required across the country in its proposed integrated management approach to plastic products. The following changes (adapted from Arnold, 2019) are required to fully implement the CCME intentions associated with their Canada wide Action Plan (CAP) for Extended Producer Responsibility (EPR).
- packaging was identified as a first priority item in the operation of EPR programs (CCME 2014), however, not all packaging materials are being addressed in provincial programs. A full treatment of food and agriculture packaging materials is required
- The focus is on recycling more than refillables / reuseables, so the programs must be amended to respect the 5R framework
- All provinces should move programs to full EPR. Product stewardship and hybrid stewardship / EPR programs should be fully transformed to EPR
- Fees should be high enough to encourage reuse and product redesign. The European experience suggests that fee modulation, and individual responsibility for fees (rather than collective ones) are more likely to lead to product redesign, Specific charges can be applied to problematic packaging materials and additives to plastics (e.g., opaque PET and carbon black plastic that makes plastic recycling more difficult). Manufacturers would have to demonstrate that the technology and logists exist to reuse / recycle certain challenging materials. It is also possible to modulate fees based on biomaterial content and compostabililty, but this is dependent on other proposals in this section being implemented (Watkins et al, 2017).
- Similarly, although sectors may create 3rd party Producer Responsibility Organizations to deal with end of life products, it should be clear from the legislation that producers are individually responsible (as now exists in Ontario with the Waste-free Ontario Act) in order to prevent liability being shifted to third parties if targets aren't met. This also allows innovators to be rewarded without being weighed down by laggards (Watkins et al., 2017).
- Clear enforceable targets with progressive increases on a timetable, with significant penalties for non-realization, should be established. The targets must include all sectors, not primarily residential on which many programs are currently based. Given the widely variable current rates of reuse and recycling at the municipal and provincial levels (see for example Bottle Bill Resource Guide), and the different methods for calculating them, it will take some time to determine these targets and they will likely have to be regionalized to account for different current baseline activity.
- As part of this, ban plastics from landfill as in many European countries, including, Austria, Belgium, Denmark, Germany,Luxembourg, Netherlands, Norway, Sweden, Switzerland, Finland, and Poland. Countries without such a ban report significant volumes of plastic waste entering landfills (Worm et al., 2017).
Create more plastics mitigation plans associated with CEPA toxic designation
The broad category "Plastic manufactured items" has now been added to the list of CEPA toxic materials, in addition to microbeads already on the Priority Substances List under the Canadian Environmental Protection Act. Presumably, then, any plastic requires a mitigation plan to bring the designation to life. Some SUP macroplastics are already proposed for banning, and several other plastics should be priorities for mitigation plans, in part based on developments in Europe: oxo-degradable plastics that break down into micro-plastics, PVC, Polystyrene, black and dark coloured plastics, PLA, rigid water soluble plastic, Polycarbonate, and Acrylic (Gooch et al., 2019; Cocker and Hargreave, 2020).
Design competitions to integrate universal design for accessibility with sustainability
An important consideration in the change process is universal design for accessibility. This is one part of a larger question regarding the intersection between food justice and disability justice (cf. Stiegman, 2022). The grocery store can be a challenge to navigate for people of different abilities, and food choices can be affected by the ease of opening and using packaging. For many unable to cook, good packaging for ready-to-eat foods has been essential. For people with visual impairment, the packaging can't necessarily serve as a source of usable information. Although there are an increasing number of tools available to help with food choices and acquisition (e.g., on-line shopping with screen readers, delivery and meal services, Google Lookout for those visually impaired to access food labels, live "my eyes" web sites), the cost of these supports is usually borne by the individual. The federal government, ON, MB, and NS have accessibility legislation, and BC and Nfld are considering them. Some provinces, such as NS, also have disability support programs to help pay for additional tools and supports. Understandably, given the slow progress on universal access, the legislation and programs focus on fundamental issues of access and equity, but hopefully by this stage of transition, there will be more time and space to examine how such programs can help with food choices and access, including packaging.
On the packaging design front, some designers are developing universal food packaging. There has been some basic progress with improving the ease of opening and closing, the ability to handle the package based on considerations such as grip strength, and changes to label information to make it more readable. There is debate in the field, however, about whether universal is achievable and what kind of trade-offs might be required. Given the current state of sustainable packaging, it is understandable that universal design has yet to be well integrated with sustainability considerations. There are some conceptual frameworks in the literature that attempts an integration (cf. Goodman-Deane et al., 2016), but these have not been substantially used yet in actual packaging designs. For example, plastic containers and packaging can be molded in helpful ways that are more challenging (and likely expensive) to create for metal, glass and paperboard, suggesting that universal design could potentially contribute to the plastic load on the environment.
Design competitions are a regular part of packaging innovation processes and what is needed is one that attempts to integrate sustainability and universal design.
Continue to support and implement a global Convention on Plastics Pollution (Worm et al., 2017)
Given the global scale of the plastic pollution problem, and the uneven nature of both pollution and resources to reduce it, a global convention, in line with similar efforts on CFCs and POPs will be required. This would represent a step up from the Oceans Plastics Charter which is voluntary and only has a limited number of signatories (Canada, France, Germany, Italy, the United Kingdom, and the European Union). The first meetings of such a process under the UNEP INC (see Government Actions) too place in late 2022.
