Paper & Paperboard Packaging Environment Council (PPEC)

Environmental Labeling

Re: Environmental claims: A guide for industry and advertisers (draft)

PPEC was a member of the National Packaging Task Force for 10 years and part of the group of Task Force members that produced the original Industry Canada environmental claims document. Please find our comments on your revised draft below.

4.6 Claims of Sustainability

This draft says a preferred claim is "This wood comes from a forest that has a registered sustainable forest management system."

We support this but assume the claim is not limited to wood. If the paper or paper used to make a package comes "from a forest that has a registered sustainable forest management system" then we would assume that this is also acceptable. We would appreciate your comment on this.

5.7 Self-Declared Claims

We agree that it is inappropriate to imply multiple benefits for a single environmental change but we see nothing wrong with the following:

"By using 65% recycled content, we are reducing waste at the production phase. Trees are being saved by the use of recycled woodfibres. "

We would appreciate your comment on this.

10.1 Claims of "where facilities exist."

As we see it, there are two major reasons for advancing this claim: (1) to indicate that something is recyclable as opposed to non-recyclable and (2) to give some direction to consumers as to where and how they might actually recycle it.

Originally, through the National Packaging Task Force, you could only claim "where facilities exist' if one-third of the consumers in the marketplace where the product was sold had access to recycling. This was designed to limit misleading claims, and the benchmark level of access was reasonably easy to establish and monitor (i.e, if the product was sold nationwide then 10 million Canadians had to have access to recycling).

We appreciate that some companies may have abused this benchmarking process. However, we think there are better options to addressing this problem than the one proposed in your draft.

One is to take companies to court for misleading claims. Set a precedent over what can and cannot be said.

A second option is to increase the benchmark threshold (to 40 or 50%) and take anybody who misleads to court, We recognize that a balance needs to be struck here between encouraging people to recycle and them giving up (they may assume something is not recyclable if the benchmark is too high and nothing is printed on the package).

While we understand the intent of your proposed option (to more clearly define the facilities) it has several major drawbacks. It imposes an administrative information burden on companies that is unreasonable, especially when many governments themselves do not even have some of this basic facility information.

To expect individual companies to track the constant changes that municipalities make to their programs (materials collected, bags/carts, boxes, curbside/depot, exactly how they compost, for example) on an ongoing basis, not just in one province (Ontario alone has 200 different Blue Box programs) but also in other provinces and even other countries when the product is exported, is just too much.

It is also counterproductive to promoting further recycling if companies faced with this additional tracking burden simply choose not to make any recyclable claims for fear of public backlash through prosecution. As a result, consumers may simply trash perfectly recyclable materials.

Another problem is space on the box to print all of this detailed information. At a time when packaging is under attack for being "excessive", you are asking that more space be devoted to listing municipalities by name (potentially in many provinces, and perhaps in other countries).

This information in Canada must be of a suitable size to be read (growing number of seniors in the population) and by law be in two different languages (more space). The inevitable result is a box that is bigger than the current one (sabotaging industry efforts to reduce at source, the first of the 3Rs).

The pendulum seems to have swung so far to the "specific" side of the ledger as to be impractical. There is a clear need to develop general statements (or access percentages) that can be more easily verified for accuracy which at the same time encourage greater recycling. PPEC is willing to work with you on this if you wish.

Yours sincerely

John Mulllinder

PPEC (416-626-0350)