CleanBC Single-use Plastics Submission

The B.C. Ministry of Environment and Climate Change Strategy (MOECCS) recently issued a policy paper proposing a number of actions to address single use plastics in the environment and asking for feedback. In response Recycle BC submitted its comments.

The Ministry’s Action Plan, found here, is divided into four key areas:

1) Bans on Single-Use Packaging: Proposes sale and use bans, as well as disposal bans.

2) Dramatically Reduce Single-Use Plastic in Landfills & Waterways: Proposes adding packaging-like products and single-use items to the Recycling Regulation.

3) Expanding Plastic Bottle and Beverage Container Returns: Proposes expanding the deposit-refund system to cover all beverage containers, including milk and milk-substitutes; increase the deposit to 10 cents; and allow refunds to be electronic and paid in alternative form of cash (e.g., e-transfer, cheque, charitable donation).

4) Reducing Plastics Overall: Proposes working with federal government to develop recycled content performance standards and requirements.

Recycle BC has prepared a submission that:

  • Supports expanding the scope of the Recycling Regulation to include packaging-like products and select single-use plastic items in place of potentially banning these items from use and sale.
  • Provides recommended criteria to determine which packaging-like products should be included and exempted as follows:
    • The product is similar to an already legally obligated (aka designated) item under Schedule 5 of the Recycling Regulation. The more similar a product is to an obligated item, the more likely it is to be included.
    • It is indistinguishable from packaging when discarded by BC resident householders.
    • It has a function similar to packaging.
    • It is intended to have a relatively short lifespan.
    • It is sold as a product.
    • It is ultimately purchased by consumers, as distinct from institution, commercial or industrial purchasers.
  • Supports the use of disposal bans as a complementary policy to EPR because placing disposal bans on items legally designated under EPR has been proven to increase recycling rates and help overcome the economic disparity between linear and circular economies for plastics. We support provincially-mandated disposal bans rather than bans at local government level because we do not want to encourage a patchwork of policies.
  • Supports the B.C. government working with the federal government on recycled content standards, and suggests that if the BC government moves ahead with policies that producers be allowed to report performance via their EPR programs and that this performance be aggregated and included in each program’s annual report.

Supports national standards and definitions on compostable products and packaging.