Articles Association News Business Intelligence Community
FGIA: Too broad, too vague

Recently, the federal government concluded a public consultation on the creation of a Federal Plastics Registry, which will be used to monitor and track plastic from the time it is produced to the end of its life.

The registry would require producers to report annually on the quantity and types of plastic they place on the Canadian market, how that plastic moves through the economy and how it is managed at end of life. This includes PVC and other resins involved in the manufacturing of plastics.

The government proposes to implement the Federal Plastics Registry in four phases, beginning in 2025. “Producers” are expected to submit the required information annually through an online portal. The construction sector would start reporting on the amount of plastics placed on the market in phase two, which is expected to launch in June 2026. The rest of the data reporting requirements for the construction industry will start in phase four, projected to start in June 2028.

There are many concerns with the proposed program. As it stands today, the program is simply too broad and too vague in its scope. The 2026 launch date doesn’t provide manufacturers and material importers sufficient time to comply with the proposed program. For example, windows, doors and skylights are durable products that last for decades. Most fenestration manufacturers do not yet have visibility into what happens to their products after they are sold and do not have the mechanisms in place to track products to end-of-life. Further, companies will need substantial resources and time to successfully design, test and implement traceability systems. The proposed timeline doesn’t take this into account.

There are grave concerns about the confidentiality of data that will be collected by the government. It’s not fully clear what safeguards will be implemented to protect trade secrets and proprietary information collected from manufacturers. Additionally, there are disparities between provincial/territorial interpretations of what constitutes a “producer,” and the federal definition, which creates ambiguity and conflict, especially across jurisdictions.

It will be essential to provide specific details on the minimum reportable amount for resins. The government must also determine whether various manufacturers along the value chain (window, profile and resin, as well as specialized products like painted or laminated profiles, weatherstripping and hardware) are all required to submit reports. If everyone is expected to report, one wonders how the program will streamline reporting, verify data and avoid redundant data collection.

It’s clear the industry requires more information and clarity. Therefore, it may be more beneficial for the government to concentrate on reducing the use of single-use disposable plastics with short lifespans. A pilot program focused on a specific type of single-use plastic should be launched initially to test and perfect processes and validate the effectiveness of the regulatory frameworks under consideration.

After the regulations are finalized, it is recommended the government defer mandatory reporting requirements for a minimum of three years so that manufacturers and others in the value chain have adequate time to prepare for compliance.

In my experience, adequate time along with clear communication and collaboration with all stakeholders across the entire value chain of plastics and waste disposal must take place for a program of this magnitude to be successful.

Amy Roberts is FGIA’s director of Canadian and technical glass operations.