Submitted by WasteLess to the consultation on the amendment to the Single-Use Plastics Prohibition Regulations.

WasteLess is a committee of Environment Lethbridge comprised of individuals from a variety of interests who for over a decade have worked to inspire waste reduction in our community. A recent focus has been on reducing single-use plastics and informing ourselves and others about their harmful effects including microplastics (https://wasteless.ca/wasteless-plastic). We appreciate the lead of the federal government in developing legislation to ban single use plastics.

Please accept our comments against the proposal to amend the Single-Use Plastics Prohibition Regulations that were to be put in effect on December 20, 2025. The consultation focus noted on the website is: “to amend the Regulations to allow the export of the six categories of single-use plastics. This will prevent the loss of Canadian manufacturing jobs and preserve important facility investments made by Canadian companies, while ensuring the Regulations continue to effectively protect the environment from the harms of plastic pollution. It aligns Canada’s approach with major trading partners, such as the European Union, who also have single-use plastics bans in effect.”

We are pleased that the Federal Court of Appeal has recently upheld the decision of the Government of Canada that plastics are toxic. In addition to plastic toxicity (in the byproducts of manufacturing, leached during product use, and as waste in the environment), plastic pollution is deleterious to aquatic life, wildlife, and humans as microplastics in food and drinking water. A majority of plastics introduced to waste streams is in the form of single-use plastic products.

The impact of plastic pollution on human health and the environment is well documented by the science, and has lead to the introduction of legislation in many countries (including Canada) prohibiting the manufacture of plastic products, particularly if derived from polystyrene, polyethylene and PVC. As such, it is clear that the decision to amend this legislation to allow the export of these products is economic, not science-based.

To rephrase this amendment: the Government of Canada will maintain its domestic prohibition of six categories of Single-use Plastics based on the scientific consensus of their negative impact on human health and the environment, but will sustain their export to protect Canadian jobs. Said this way, the decision is both unethical and unjust. Furthermore, that this decision ‘aligns with major trading partners’ does not relieve Canada of its responsibility to act ethically.

We suppose that this decision aligns with the economic philosophy of Lawrence Summers who, as Chief Economist for the World Bank, infamously wrote that some regions were ‘vastly under-polluted’ and goes on to say that rising health risks would be less evident in populations with higher mortality (i.e., shorter life-spans). This might have been the same perspective dominating the years Canada continued to export asbestos after banning it domestically, or the current efforts to reduce greenhouse-gas emissions while building pipelines and LNG facilities to increase the export of fossil fuels.

The unfortunate but fundamental truth of the natural environment is that it knows no borders. The pollution we export impacts natural systems that we all rely on for health and prosperity, and even survival. Furthermore, exporting single-use plastics, destined to be pollution, raises concerns of environmental justice.

We understand the importance of economy and jobs within that economy. We also understand that there is always a threat and urgency that seems to create a false prioritization of jobs over the health of the environment. We believe that the proposed amendment is a response to some alarm in the plastics industry related to current trade tensions. Is this response an over-reaction? The current legislation identifies and prohibits three plastics used in the manufacture of single-use products. Extended Producer Responsibility programs, that have been adopted across Canada, encourage manufacturers to design for the life-cycle of the product. In the case of plastics, this effectively means designing-for-recycling (and avoiding less recyclable plastics like polystyrene, low-density polyethylene and polyvinyl-chlorides). Simply, the industry is already moving in the direction of producing their products more responsibly. There is no conceivable reason to maintain inferior production processes for export. Canada should be a leader in advancing a sustainable and circular economy.

To summarize, toxic plastics must be prohibited both domestically and globally; single-use plastics represents a waste of resources and the main source of pollution that degrades to microplastics, which is becoming a serious global concern; choosing to prohibit single-use plastics domestically while allowing it to be exported is unethical and raises concerns of environmental justice.

We recommend:

1. Maintaining the legislation as it stands.

2. Supporting the Canadian plastics industry in the transition away from producing low-grade (non-recyclable) single-use products.

3. Educating to discourage the usage of single-use plastics.

4. Continuing to work with organizations like the Intergovernmental Negotiating Committee on Plastic Pollution (UNEP), the Ocean Plastics Charter, and the International Pollutants Elimination Network to transition away from harmful plastics and in reducing plastics in global waste streams.

In the words of Prime Minister Mark Carney: “In my view, that is a life of moral, not market, sentiments. A life that seeks to advance the trinity of distributive justice, equality of opportunity and fairness across generations. And even if those efforts fail, it is a life which recognises that in pursuing virtue we help build it in ourselves and in others. We expand its practice and give it life” (Carney, Value(s): Building a better world for all, 2021).