Creating a Single-Use Item Reduction Strategy Consultation Submission

Transcription

1 Creating a Single-Use Item Reduction Strategy Consultation Submission Presented to: The City of Vancouver Sent via to: singleuse.consultationpaper@vancouver.ca For more information please contact: Mark von Schellwitz Vice President, Western Canada Restaurants Canada mark@restaurantscanada.org

2 2 Restaurants Canada Restaurants Canada is a national, not-for-profit association representing Canada s diverse and dynamic restaurant and foodservice industry. With more than 1.2 million employees; 94,000 locations; and 18 million customers a day, Canada s restaurant industry is the number one source of first jobs for young people. We help build neighbourhoods, drive tourism, and fuel Canada s agri-food production. Restaurants Canada members comprise 30,000 businesses in every segment of the industry, including restaurants, bars, caterers, institutions and their suppliers. We work on their behalf with all levels of government in support of a strong restaurant industry that contributes jobs, investment, and a wide range of culinary choices to communities across the country. Founded in 1944, we were first known as the Canadian Restaurant Association, then the Canadian Restaurant and Foodservices Association. We celebrated our 70 th anniversary by unveiling a new logo, name and tagline: Restaurants Canada, The voice of foodservice. British Columbia s Restaurant Industry British Columbia s restaurant industry is a highly competitive, labour-intensive, low margin industry with average pre-tax profitability for full service restaurants of only 3.7%. The industry relies on consumer confidence and disposable income growth to be successful. While profitability remains low due to everincreasing lease, labour, food, and liquor costs, recent sales growth has been strong. British Columbia s restaurant industry generated a record $13 billion in foodservice sales in Healthy economic growth and consumer appetite for convenience and dining out helped British Columbia surpass Alberta with the highest sales per capita. The foodservice industry accounts for 5.0% of the province s gross domestic product, also the highest share in the country. As a result, the labour-intensive restaurant industry is now the third-largest private-sector employer, directly employing 174,200 people in British Columbia plus more than 40,000 indirect jobs. This represents more than 7% of the province's workforce. The restaurant industry is also the largest youth employer in the province employing nearly 80,000 young people between the ages of 15 and 24, representing nearly one in four youth jobs in British Columbia. Given the thin margins in the competitive foodservices industry, members tell us they are increasingly concerned that numerous unanticipated government imposed regulations and fees are like a death by a thousand cuts threatening their viability. Introduction Restaurants Canada appreciates the opportunity to participate in the City of Vancouver s Single-Use Item Reduction Strategy consultation. Both Restaurants Canada and a number of our members participated in stakeholder meetings in both Toronto and Vancouver. The following submission summarizes the input provided at those consultations and offers a few recommendations for the City of Vancouver to consider in moving forward with a single-use item reduction strategy.

3 3 In recent years Restaurant Canada members have shown environmental leadership in voluntarily implementing a number of measures to reduce, reuse, and recycle packaging materials. Our members are doing their part to help reduce packaging waste. However, the City of Vancouver needs to understand that our member businesses need to respond to growing consumer demand for convenience to meet the needs of their guests busy lifestyles and cannot be expected to simply no longer provide the take out convenience they demand. Restaurants Canada members are constantly innovating and trying to find environmental packaging solutions while at the same time meeting the needs of their customers. However, an incredibly diverse after-life market and infrastructure makes it very difficult for brands especially those that are global or national to address every issue. We acknowledge we have a role to play, but we re only one piece of the puzzle. Any initiative to reduce single-use item packaging must start with consumer education. To be effective strategies must focus on the end consumer and residents of the City of Vancouver as they are the ones who can make decisions around sorting packaging and decreasing litter. Simply adding fees to businesses that sell single-use packaging or banning single-use packaging in one municipality will not result in any meaningful reduction in single-use packaging ending up in landfills. Many single-use packaging items are already recyclable and are designed for food and consumer safety. However, in many cases consumers are not aware of how to recycle these materials once they leave restaurant establishments. Many members are already paying Recycle BC packaging stewardship fees to manage residential recycling programs on their behalf and rely on Recycle BC to implement policies and programs to improve packaging recycling in Vancouver and throughout British Columbia. For example, Recycle BC has worked with stewards and the City of Vancouver in implementing a Vancouver street scape pilot to help consumers more effectively recycle and sort their waste at street level. Our members support comprehensive consumer education on what they can do to increase single use packaging recycling. However, our members do not support additional single-use recycling packaging fees or single-use packaging bans or additional costly regulations isolated to one municipality that rob consumers of the convenience they demand and that reduce affordability. Restaurants Canada members are concerned that the majority of the potential approaches contained in the consultation document are directed at businesses instead of the end consumer. These proposals come at a significant cost to business at a time when they are already facing increasing operating and labour costs. It was also clear from the stakeholder meetings that more information and research is needed on the potential approaches outlined in the consultation document as well as some of the examples mentioned on what other jurisdictions are doing to address the issue to determine their effectiveness in meeting waste reduction targets. Restaurants Canada offers the following input on some of the potential approaches discussed in the consultation document for disposable cups, take-out containers, and plastic paper bags.

4 4 Proposed Approaches Polystyrene Foam Restrictions Restricting the use of polystyrene may work for some members but not others depending on the product they are selling and the food and temperature safety needs of the product sold. Businesses in the diverse extremely competitive low margin foodservice industry rely on a variety of packaging suited to the particular business and customer needs. Banning any particular packaging material will have little or no impact on meeting the City of Vancouver s goals as the banned product must be replaced with an alternative product which will not reduce the amount of packaging material. Forcing members to use a more expensive packaging material will increase business costs without reducing packaging waste. Restaurants Canada opposes polystyrene or any other material restrictions as it will not help achieve reduction targets as replacement packaging that meets all the food safety and operational requirements will still be required. Disposable Cups, Containers, and Bags Provided Only Upon Request This approach is once again focused on businesses rather than the consumer and ignores the fact that in many cases consumers demand the convenience of disposable take out cups and containers. The focus should be on educating consumers on how to best to reduce packaging waste. Once again members question the effectiveness of this approach to meet the City s reduction targets. Restaurants Canada cannot support this approach as it once again focuses on the businesses rather than end consumer education on reducing packaging waste. Require Reusable Cups, Dishware Cup/Container Exchange Programs While this approach may reduce waste, its overall impact on the environment is questionable as reusables will require increased energy and chemical use in cleaning reusable containers. Exchange programs would also be complex to implement and ineffective given the size and diversity of the industry. Members are also concerned about the food safety and operational implications of these approaches. It is also unclear to what extent consumers would embrace the use of reusables. Most members believe that this approach would not be embraced by their customers who will still demand disposable packaging. Restaurants Canada currently does not support this approach given food safety and operational concerns combined with current consumer demand for disposable packaging. More information is required on the effectiveness and practicality of these approaches. Proportional Billing for City Street Cleaning and Litter Collection Foodservice businesses already pay Recycle BC packaging stewardship fees to manage residential recycling and pay ever increasing municipal taxes. Members strongly oppose this approach as it amounts to yet another tax on businesses that will do nothing to reduce single use packaging waste. Once again this approach incorrectly targets businesses rather than addressing consumer behavior.

5 5 Restaurants Canada opposes this approach as it amounts to another cost to businesses that does not support the City of Vancouver s single-use item reduction targets. Foodservice businesses already pay stewardship packaging fees to Recycle BC and municipal taxes. Extended Producer Responsibility for Cups and Containers in the Industrial, Commercial & Institutional Sector As mentioned our members already pay stewardship fees to manage residential recycling and they pay private haulers to pick up their waste. If there s an issue with private haulage, perhaps the City should seek ways to ensure haulers have incentives to increase capture rates, increase sorting, etc. Furthermore, this approach is under provincial jurisdiction and is therefore beyond the City s control. Proposed approaches should focus on areas where the City of Vancouver has the ability to effect change. Restaurants Canada opposes this approach as it amounts to another cost to businesses that does not support the City of Vancouver s single-use item reduction targets. It is also an approach requiring provincial government approval and is beyond the City s control. Recyclable/Compostable Cups & Containers Enhance Compostability As pointed out at the stakeholder consultation sessions there is a great deal of confusion about which single-use cups and containers are recyclable and compostable. In many cases operators are being approached to purchase more expensive cups and containers promising they are more recyclable and compostable when in fact those products are no more recyclable and compostable than what they are currently using and do nothing towards reducing single-use packaging waste. Members want to maintain control of what packaging products work best for their businesses and customers. Enhancing compostability should focus on enhancing infrastructure which will in-turn encourage innovation by businesses. More information is also needed on how enhanced composability will help with reduction targets. Restaurants Canada opposes this approach as members should be able to choose the packaging that works best for their particular businesses and customers. Mandatory In-Store Recycling As was pointed out in stakeholder meetings many members already offer customers in-store recycling options. The single use item waste problem results from consumer behavior, and how consumers discard single-use packaging after they leave the establishment. Only a small percentage of waste stays in-store. Restaurants Canada does not support this mandatory in-store recycling approach. Expand On-Street Recycling Restaurants Canada supported the street scape pilot project undertaken by the City in collaboration with Recycle BC and would support expanding similar on-street recycling initiatives provided that the cost of expanded on-street recycling is paid for by the City and existing Recycle BC stewardship fee revenue. However, our members would not support expanded on-street recycling if it results in Recycle BC charging members additional stewardship fees on top of what they are already paying.

6 6 Restaurants Canada would support expanded on-street recycling initiatives like the street scape pilot undertaken by the City and Recycle BC, provided the cost of expanded on-street recycling is covered by the City and current Recycle BC fee revenue. Deposit Refund There is very little support for this approach from all stakeholders including Restaurants Canada members for a number of reasons including the complexity and expense of implementing and administering a deposit refund system for just one municipality. It would also disrupt blue box programs already in place resulting in less blue box material. Considerable consumer education would need to take place prior to implementing a single-use item deposit system. Restaurants Canada and most other stakeholders opposes this approach as something that would be costly to implement and administer, especially in a single municipality. Disposal Ban on Polycoat Cups Restaurants Canada opposes this approach for the same reasons we oppose polystyrene foam restrictions mentioned above. Education/Behavior Change Programs Restaurants Canada and its members along with most other stakeholders support this approach as the best way to achieve the City s single-use item reduction targets. The support for this approach was reinforced in the consultation sessions by most stakeholders. This approach and must be combined with consistent recycling infrastructure to ensure consumers are not confused about how best to recycle various single-use items. Changing consumer behavior through a comprehensive consumer education program is the only way to ensure a significant reduction in single-use packaging waste as consumers are the ones discarding single-use items after they leave the foodservice establishment. Restaurants Canada strongly recommends this approach as the best way the City can make progress towards its single-use item reduction goals. Conclusion Restaurants Canada and its members appreciate the opportunity to participate in the single-use item reduction consultation sessions and comment on the proposed approaches contained in the consultation paper. Please feel free to contact us should you have any questions on the above comments. We look forward to continuing the dialogue with the City on voluntary collaborative approaches that will be most effective in helping the City reach its reduction goals without adding additional cost and regulatory burden on Vancouver s restaurants. Restaurants Canada is prepared to work with the City and a formal group of impacted stakeholders on practical effective foodservice packaging solutions moving forward.