Executive Director Paper & Paperboard Packaging Environmental Council (PPEC)
As the Paper and Paperboard Packaging Environmental Council (PPEC) continues to work on achieving its mission to promote the environmental sustainability of the Canadian paper packaging industry, we will also be closely monitoring the following key issues in 2023:
Executive Director Paper & Paperboard Packaging Environmental Council (PPEC)
The Paper and Paperboard Packaging Environmental Council (PPEC) sat down with its former and long-standing Executive Director, John Mullinder, who helped formed PPEC in 1990, and retired in February 2021.
John recently published his new book, Little Green Lies and Other BS, which focuses on environmental claims and advertising; it is a follow up to his first book, Deforestation in Canada and Other Fake News, published in 2018.
Little Green Lies is well researched and organized, covering about 40 different subjects in alphabetical order from “Ancient” Forests to “Zero” Waste.
PPEC chatted with John about his new book, and excerpts from our conversation follow, edited for length.
Hi John! Can you please give our readers a brief description of your new book and why you wrote it?
One of my reviewers described it as “an entertaining and informative dictionary of environmental buzzwords (and claims) that are widely used (or made) but often poorly understood.” The book examines those buzzwords, what they mean and whether the current use of these terms is accurate, misleading, confusing, deceptive or just plain wrong, and includes 38 pages of sources for the information (that’s the dictionary part).
I wrote it because there is so much misinformation, and sometimes deliberate greenwash, about these buzzwords and claims, and I want to set the record straight.
What can readers hope to learn from this book?
Not to accept all environmental claims as apple pie. To question the use of particular buzzwords. To understand and analyse the context in which claims are made, whether they are made by businesses, governments, or environmental groups. And to avoid making those same claims themselves.
The book doubles as an educational tool for staff, customers, journalists, policy advisers.
Or as one of my reviewers wrote: “This is a great reference book that will help you sort the facts from the fiction. If you’re a writer, editor, public relations professional, legislator, educator, work for an NGO, or are simply a consumer who wants to know the truth, this book should be on your shelf or Kindle list.”
How does this book differ from your first book, Deforestation in Canada and Other Fake News?
The focus of “Deforestation in Canada and Other Fake News” was to debunk two commonly-held myths: that Canada is running out of trees, and that massive deforestation is taking place in our own backyard. Both not true.
While “Little Green Lies” does cover these issues as well, it is far broader, examining a wide range of forestry and paper issues, packaging, recycling, and waste. It is also more international, incorporating as much global and US data and perspectives as possible, not just Canadian data.
There are a lot of misconceptions when it comes to forestry – particularly related to deforestation and “ancient” forests – where does the confusion come from, and how do we address it?
There is widespread confusion about each of these because people work to different definitions of them. And the media makes it worse by not explaining what the terms mean and/or misapplying the meaning of the words. We (and I mean collectively) need to develop broadly agreed-upon definitions that we can all work to, and to publicize them widely, especially to journalists. The United Nations, for example, has a very clear definition of deforestation.
With increased activity and attention on corporate greenwashing — the practice of making false or misleading environmental sustainability claims — and with the Competition Bureau of Canada archiving its Environmental Claims Guide, do you believe there are enough resources available to provide clarity on claims and misleading marketing practices?
Absolutely not. And even the advice that is out there (the archived guidelines you refer to) are inadequate. This is one of the reasons they were archived as a matter of fact. Greenwashing is a major issue and it needs sufficient resources allocated to it, urgently. Or nobody will believe anything. And that is a slippery slope.
PPEC has long called for disposal bans on paper-based packaging, considering such materials are recyclable and end markets exist; why do you think there is resistance to implementing such bans?
What really gets up my nose are provinces spouting off about how we should all move to a circular economy while they do little or nothing to change the economics that make it cheaper to send stuff to landfill rather than to recycle it.
The circular economy is all about reusing materials again and again, and the provinces have the power to do something about this. They need to demonstrate some political fortitude and be willing to take on the commercial interests of municipalities and waste haulers who happen to own landfills.
Do you have any comments on the state of Extended Producer Responsibility (EPR) policies and legislation in Canada as they relate to the paper-based packaging industry? And how does the consumer/resident – who ultimately decides how to dispose of their waste and recyclables – fit into the concept of EPR?
I think we have to be very careful in claiming EPR as the solution for materials ending up in landfill. Any costs that producers incur through EPR schemes will inevitably be passed on to consumers. What’s important for industry (including the paper industry) is that any fee structure be fair and evenly applied. Non-performers must be penalized for any scheme to work.
And a major education job is required to get the consumer in the loop. For example, about 40% of Ontario Blue Box recyclables go straight to the trash because householders are confused about whether certain materials are recyclable or not. Much (but not all) of this trashed material is perfectly recyclable.
Is there anything else you would like to share about your new book Little Green Lies?
I know this will sound a bit like a sales pitch (it is!), but I think the book provides a sound basis for critically examining many of the environmental claims we see and hear today (whether they are from industry, governments, or environmental groups). The sources for the information I provide are all there. Facts do matter.
Paper & Paperboard Packaging Environmental Council
Claims for 100% recyclable and 100% compostable seem to be proliferating. Are they accurate? Are they legal? Or are they just another form of greenwash?
It’s not surprising that North American consumers are confused. Because in common speech, the words “recyclable” and “compostable” can mean three different things:
Each of these meanings is significantly different. But in terms of environmental labelling, which is what we are talking about here, the Competition Bureau Canada will accept only one. And that is whether the consumer can actually send the product or material for recycling or composting. It does not matter whether the product or material is technically capable of being torn apart or composted. It does not matter what the actual recycling or recovery rate of that material might be (that’s a whole other issue). What does matter is how many Canadians have access (“reach” in the US) to the recycling (or composting) of that product or material.
And the Competition Bureau has guidelines on how that access is determined and when you can use the words: “It is recommended that if at least half the population has access to collection facilities, a claim of recyclable (or compostable) may be made without the use of any qualification.” If less than half the population has access, claims must be qualified: “the specific location of the recycling (or composting) programs or facilities should be identified whenever it is possible and practical to do so.” (10.1.3).
Recyclable and compostable claims, then, are based on whether and to what extent consumers have access to recycling or composting facilities. Putting 100% in front of these words, however, takes the issue to a whole new level. We are not lawyers, but to us the clear inference consumers would draw from a claim of “100% recyclable” or “100% compostable” is that 100% of Canadians have access to the recycling (or composting) of that product or material. And that is plainly not true.
While most Canadians now live in cities and towns that have access to recycling or composting facilities, there are a small but significant number of people who live in more remote locations who do not, and probably never will have “conveniently available” access to recycling or composting. Therefore, 100% access for Canadians will likely never be achieved. Which is why we in the paper packaging industry say that virtually all Canadians have access to the recycling of paper packaging. The actual number is 96% for corrugated boxes and paper bags, and 94% for boxboard cartons, determined through an independent third-party study.
Anybody putting the 100% in front of recyclable (or compostable) is therefore, in our view, failing to follow the Competition Bureau guidelines for using the words, and is leaving themselves open to prosecution for misleading advertising. They are compounding existing consumer confusion about what recyclable/compostable mean; or worse, deliberately indulging in what amounts to greenwash. Doesn’t labelling a product or material as 100% recyclable or 100% compostable just serve to dilute and undermine the whole access criteria on which the current use of the words is based? Are we wrong on this?
cc: Competition Bureau Canada
The good news is that the reported recovery rates for almost every single material category in Ontario’s Blue Box have improved over the last 13 years, some by as much as 20 percentage points. The bad news is that several categories have made very little progress and lag way behind the others, and that the real recovery rates are much lower than those reported.
Here is our Report Card by material group, based on the latest recovery numbers from Stewardship Ontario. Please note that this is not a judgement on the merits of individual materials but rather an assessment of how well they are being recovered in Ontario’s Blue Box system. There is clearly room for improvement.
Printed paper has been a consistent good performer, rising from 67% reported recovery back in 2003 to 82% today (2015). The recovery rate for old newspapers and old telephone books is in the 90s. Somewhat further back, and dragging the printed paper category down, is the recovery rate for printing and writing paper (Other Printed). This has ranged from 39% up to 59% and is currently at 55 per cent.
The reported recovery rate for clear and coloured glass is an impressive 80 per cent. Years ago, all we heard about was glass going to landfill or being used as road fill. Beyond talk of glass breaking in the collection process and contaminating loads of other materials, however, glass recovery is apparently in good shape. A lot of recovered glass these days goes into blast and filter media rather than higher end uses such as fibreglass and cullet which have more demanding quality requirements.
Old corrugated containers (OCC) or boxes have the highest reported recovery rate of all Blue Box materials (98%). From there it’s a drop back to paper-based gable top cartons which have surged from a 10% to a 61% recovery rate; boxboard at 43%; followed by aseptic cartons (made of paper, plastic and aluminum), and laminants. The relatively low recovery rate for old boxboard is a concern. It reached as high as 65% recovery in 2008 but has dropped back to 43% since. Stewardship Ontario did target boxboard toothpaste cartons, toilet paper roll tubes, tissue boxes and other toiletry packaging in an advertising campaign in 2015.
The latest reported recovery rate for steel food and beverage cans is a respectable 71 per cent. Other steel packaging such as aerosols and paint cans drag the overall steel category down 10 per cent. In fact, paint cans are the only category in the Blue Box whose recovery rate has declined over the last 13 years.
The low reported recovery rate for aluminum food and beverage cans in Ontario (42%) has always been a bit of a puzzler and is frequently compared unfavourably with its far higher recovery rates in Canada’s many deposit provinces where recovery ranges between 61% and 97 per cent. One reason offered for the difference is that the recovery rate for cans in Ontario is only for those that end up in the home. It doesn’t include those used at public events, in offices, or factories. The aluminum stewards also reported residential sales some 13% lower in 2015 than what various waste audits used to provide a provincial total suggested was in the home. But even if you allow for this difference, the reported recovery rate only rises to 48 per cent. We doubt that Blue Box scavengers are grabbing the other 52 per cent.
The reported recovery rate for plastics packaging reached 32% in 2015. The highest rate was for PET bottles (66%) and the biggest increase over the years was turned in by the “Other Plastics” category with one-third now being reported as recovered. Apart from PET and HDPE bottles, however, the plastic recovery rates are poor.
The far uglier truth about all reported Ontario Blue Box recovery rates, however, is that they don’t tell the real story. They are basically “sent for recycling numbers,” in most cases, what was sent to an end-market from a material recycling facility or MRF. These reported “recovery” rates don’t deduct the various yield losses that occur in remanufacturing that curbside material back into new products, or the contamination that must be removed (and is normally landfilled) before remanufacturing can actually take place.
For example, all reported paper numbers need to be shaved by at least 10% because paper fibres shrink in the re-pulping process. When a municipality sends 100 tonnes of paper to a paper recycling mill, only 90% of it will come out the other end. And with single-stream collection there is a lot more plastic, glass and metal contamination in the paper bales. This is usually sent to landfill. And you can chop maybe 30% off the reported PET bottle “recovery” rate since PET yields at the end-market range, at best, between 60 and 70 per cent.
A recent attempt by the Canadian Standards Association to grapple with this issue and come up with a definition of recycling, falls short in our view, and is one of the reasons why PPEC is developing a more accurate and real measurement of what paper materials are actually being recycled in this province.
P.S. In our last blog on the Blue Box, we claimed that “over 75%” of what the Ontario Blue Box collected in 2015 was paper of one kind or another. The “alternative fact” is 74.55%. Close but not correct. Sorry!
Source: PPEC Analysis of Stewardship Ontario Blue Box data between 2003 and 2015
The North American paper packaging industry has served notice that it will challenge (legally, if necessary) any false and misleading claims about its operations and environmental impact. Case in point: major plastic crate supplier, IFCO.
IFCO is lobbying North American grocery retailers to move away from the traditional corrugated box system of delivering fruit and vegetables. In the course of promoting its plastic crate alternative, IFCO has made various economic and environmental claims. This is its right. But IFCO (and others) also have a responsibility to be able to substantiate any such public claims when challenged.
Among the most pernicious of IFCO’s recent claims were that “most (corrugated) boxes” were disposed of in landfills, and that only “a small percentage of used boxes (were) recycled.” These claims were so patently false (certainly to the corrugated industry) that for a while they served as a great example of IFCO’s lack of credibility on this issue.
But now the kid gloves have come off. The US-based Fibre Box Association recently sent a “cease and desist” letter to IFCO demanding documentation to substantiate its claims, or removal of them from the IFCO website. Within 24 hours of IFCO receiving the letter, the untrue statements had been removed. “Let’s use this (example) as a reminder,” said FBA President/CEO Dennis Colley, “to be fact-based; to have data to back up our claims; and to challenge those who don’t.”(1)FBA Forces IFCO Website Change, Board Converting News, December 22, 2014
For the record, some 89% of US corrugated boxes were recovered for recycling in the most recent data year. (2)US EPA Municipal Waste Characterisation tables, 2013. PPEC estimates the Canadian rate at about 85 per cent.(3)The most recent national recycling statistics for packaging materials in Canada are now 18 years old! In 1996, Statistics Canada estimated corrugated recovery at 76%. PPEC estimates this has improved since then, partly because of increased residential recovery efforts. The recovery rate for corrugated in Ontario’s Blue Box program, for example, was 85% in 2012. In both countries, most grocery stores recover nearly all of their corrugated boxes in backroom balers. The baled material is then sold to generate revenue before being recycled back into new corrugated boxes.(4)“When we divert cardboard, not only do we reduce the cost and the environmental consequences of sending it to landfill, it’s all recycled and turned into revenue for us.” – Loblaw Green Team member quoted in Canadian Grocer magazine. PPEC estimates that Canadian retailers received over $50 million in revenue for their old corrugated boxes last year.
|↑1||FBA Forces IFCO Website Change, Board Converting News, December 22, 2014|
|↑2||US EPA Municipal Waste Characterisation tables, 2013.|
|↑3||The most recent national recycling statistics for packaging materials in Canada are now 18 years old! In 1996, Statistics Canada estimated corrugated recovery at 76%. PPEC estimates this has improved since then, partly because of increased residential recovery efforts. The recovery rate for corrugated in Ontario’s Blue Box program, for example, was 85% in 2012.|
|↑4||“When we divert cardboard, not only do we reduce the cost and the environmental consequences of sending it to landfill, it’s all recycled and turned into revenue for us.” – Loblaw Green Team member quoted in Canadian Grocer magazine. PPEC estimates that Canadian retailers received over $50 million in revenue for their old corrugated boxes last year.|
The US-based Sustainable Packaging Coalition (SPC) has transplanted a UK environmental labelling idea to a North American context and is encouraging Canadian companies to pilot it. While we commend the initiative, in our opinion there is a serious danger that companies adopting it could leave themselves open to claims of greenwashing.
The problem lies in the current use of the word “Recycled” or “Recycling” in the SPC logos. In Canada, as in the US, claims about the recyclability of packaging hinge on the access question: on whether the consumer has access to recycling for that material through curbside, depot, deposit or whatever. Claims for recyclability in both countries have nothing to do with whether that material is actually sent for recycling.
So here’s the problem. The words on the three category boxes SPC has chosen (Widely Recycled, Limited Recycling, and Not Yet Recycled) do not mention access at all. But they imply that recycling has taken, or is taking place, at the levels cited (at least 60%, between 20% and 60%, and less than 20%).
Some examples of where the results of this approach can be very misleading:
Example 1: In Canada, the Carton Council (according to a 2011 press release) claims “nearly 94%” access to the recycling of gabletop and aseptics (and therefore under the SPC model would be able to claim “Widely Recycled”). But in fact, at least in Ontario’s residential Blue Box program, the actual sent for recycling rate for gabletops and aseptics in 2010 was only 34% and 12% respectively. That’s not exactly “Widely Recycled”, although we recognise that one province’s numbers, while admittedly a major one, don’t tell the whole story.
Example 2: While access to polystyrene recycling in Canada is increasing (placing it in SPC’s between 20% and 60% “Limited Recycling” category), its actual sent for recycling rate (again using Ontario residential numbers only) was only 4% in 2010 (the latest year for which data is currently available).
Under the SPC model, both examples cited above would appear to be over-claiming, and in effect, blurring the crucial distinction between access and actual recycling. Indeed the media (and presumably consumers), would be totally misled by the recent treatment in Canadian Packaging and Canadian Manufacturing magazines of a CPIA press release on access to plastics recycling. CPIA was meticulous in qualifying its statements with the “access” word. Canadian Packaging, however, completely missed the qualifiers and stated the access numbers as recycling numbers in its headline and text. If the packaging trade press, which should know something about packaging issues, can’t get it right, what hope do consumers have?
A chart outlining the differences between claimed or assumed access to recycling and what was actually sent for recycling is attached for information.
The solution would appear to be simply changing the wording in the boxes and reference chart by including the word “access” as below:
This way it is very clear that we are not talking about actual recycling rates but rather whether consumers have access to recycling for that material. That’s supposed to be what claims for recyclability turn on (access). The last thing we want is for industry to be accused of greenwashing (yet again)!
British Columbia is the latest province in Canada to regulate extended producer responsibility (or EPR) for printed paper and packaging. Publishers, packaging brandowners and first importers (collectively known as stewards) have until November 19 to deliver a plan on how to do it. The big difference with BC is that industry will not only be paying the full cost, it will also be having a large say in program design and execution (a first for North America).
So the BC stewards have a golden opportunity to design a program that works for them and that is not encumbered or restricted by elements of the current system (for example, municipal control of contracts and program design). The stewards need to assert control from the start by clearly defining the program scope. What exactly does it cover? This is not the time to produce a “patch-up” job that sits somewhere between steward and municipal interests. This is the time to design something that works for the stewards while meeting all regulatory obligations. What happens in BC has implications for stewards far beyond that province and is a great opportunity to create a new EPR model.