Canada Management Framework for Single-use Plastics: Provides an evidence-based process for deciding how problematic single-use plastics should be managed

What’s Required

Unlike the SUPPR, the Management Framework does not directly impose compliance duties on companies.

Instead, it establishes the analytical process the federal government uses.

Step 1. Categorize the single-use plastic

Products are assessed against two principal categories.

Environmentally problematic

Relevant criteria include whether a product is:

1. Prevalent in natural or urban environments.

2. Known or suspected to cause environmental harm.

3. Associated with wildlife ingestion.

4. Associated with wildlife entanglement.

Value-recovery problematic

Relevant criteria include whether a product:

1. Interferes with recycling or wastewater treatment.

2. Is incompatible with recycling technology because of material, size, or shape.

3. Has a low or very low recycling rate.

4. Faces substantial barriers to increasing its recycling rate.

The government has used 0% to 22% as the relevant low-to-very-low recycling-rate range in this analysis.

Step 2. Establish management objectives

For products considered problematic, the government determines what outcome should be pursued.

Potential objectives include:

1. Eliminating or significantly reducing plastics entering the environment.

2. Reducing the overall environmental impacts of plastic products.

3. Increasing recovery of material resources.

4. Eliminating or reducing certain products from the Canadian market.

5. Increasing recycling or recovery rates.

Step 3. Select the policy instrument

Government then determines what instrument is most appropriate.

Potential measures can include:

1. Prohibitions.

2. Restrictions.

3. Product performance standards.

4. Recycling requirements.

5. Extended producer responsibility.

6. Other regulatory or non-regulatory instruments.

The selection is informed by the Instrument Choice Framework under CEPA.

Considerations for Exceptions

The framework recognizes that management measures may need exceptions where a plastic product:

1. Performs an essential function.

2. Is needed for accessibility.

3. Has a health or safety function.

4. Has a security-related function.

5. Has no viable alternative capable of performing the same function.

This approach contributed to the accessibility provisions for flexible drinking straws under the eventual regulations.

Selecting Alternatives

ECCC advises businesses not to interpret plastic replacement as simply switching from plastic to another disposable material.

When selecting alternatives, organizations should consider:

1. Reuse potential.

2. Environmental impact.

3. Recyclability.

4. Waste-management infrastructure.

5. Lifecycle impacts.

6. Resource recovery.

The government guidance notes that reusable systems generally rank more favorably than replacement with another single-use product where reuse is practical.

Important Deadlines

• 2020: The federal government published its proposed integrated management approach to plastic products, including the Management Framework.

• 2022: The framework's analysis contributed to the adoption of the Single-use Plastics Prohibition Regulations.

• 2023 onward: The framework continued to appear in federal guidance for businesses selecting alternatives to regulated single-use plastic products.

Current Status

The Management Framework remains part of the federal policy and guidance architecture for addressing single-use plastic waste.

It is particularly relevant as the analytical foundation explaining why certain products were selected for regulation, rather than as a separate compliance regime.

Penalties for Non-Compliance

None directly under the Framework.

It is an analytical policy framework rather than an enforceable regulation.

Penalties can arise only under laws and regulations subsequently adopted or applied, such as CEPA regulations.

Examples of Known Violations / Failure Modes

Because this is not a compliance regime, the more appropriate concept is misapplication or failure modes:

1. Assessing recyclability without considering actual recycling rates.

2. Ignoring litter prevalence.

3. Ignoring effects on recycling machinery.

4. Replacing one single-use product with another without lifecycle assessment.

5. Assuming paper automatically has a lower environmental impact than plastic.

6. Ignoring reuse options.

7. Ignoring accessibility needs.

8. Ignoring health or safety functions.

9. Treating technical recyclability as equivalent to effective recovery.

10. Treating the Framework itself as a legal prohibition.

Resources

• https://www.canada.ca/en/environment-climate-change/services/canadian-environmental-protection-act-registry/plastics-proposed-integrated-management-approach.html

• https://www.canada.ca/en/environment-climate-change/services/managing-reducing-waste/reduce-plastic-waste/single-use-plastic-overview.html