General Comments
The beverage sector is an accountable leader in the circular economy, with CBA members reporting details in multiple jurisdictions responsible for waste in Canada. We support any national based tools that support harmonization, reduce administrative burden and eliminate duplication of reporting streams. Furthermore, we support efforts that contribute to transparency and promote positive environmental outcomes. Overall, we are concerned by the lack of precision in the registry and guidance document as has been presented to industry. The registry duplicates reporting systems that are currently in place and as such represents significant regulatory and administrative burden without demonstrated utility as a mechanism to support positive environmental outcomes.
It is also extremely difficult to provide fulsome comments on a guidance document for a reporting scheme that is not available for preview or analysis. This speaks to the lack of precision and consultation in this process—it simply is not ready to go live at this time. We reserve the right to expand, adjust or amend our comments when the technical tool is available to those obligated to report. A sector-by-sector FAQ would be helpful to support the proper determination of reporting responsibilities.
We also strongly endorse that all care should be taken to maintain confidentiality in the process, and the only publicly available data is shared in an aggregated/anonymized manner.