9th February, 2024
Federal Plastics Registry
Plastics Regulatory Affairs Division
Environment and Climate Change Canada
351 Saint-Joseph Boulevard
Gatineau, Quebec K1A 0H3

Dear Sirs,

JMC comments on “ Notice of intent to issue a notice under section 46 of the Act with respect
to reporting of certain plastic products for 2024, 2025 and 2026 ”
The Japan Machinery Center for Trade and Investment (“JMC”) is a non-profit organization.
It was established in December 1952 in accordance with the Japanese Export and Import Trade Law
under the authorization of the Minister of Economy, Trade and Industry of Japan. The objective of
the JMC is to engage in activities that enhance the common benefit of member companies andpromote the sound development of international trade and investment by the machinery industry.
JMC comprises member companies engaged in machinery and systems-related exports and foreign
investments such as machinery manufacturers, trading houses and engineering companies. At
present, the total number of JMC member companies is about 240.
Our committee handles environmental and product safety issues regarding products for trade and isstrongly concerned with overseas environment and product safety-related regulations on products.
From this standpoint, we would like to comment on Notice of intent to issue a notice under section
46 of the Act with respect to reporting of certain plastic products for 2024, 2025 and 2026.

Rm. 401, Kikai Shinko Bldg., 3-5-8 Shiba-koen Minato-ku, Tokyo 105-0011, Japan
Tel : 81-3-3431-9230 , Fax : 81-3-3436-6455
E-mail : morikawa@jmcti.or.jp
URL : https://www.jmcti.or.jp

If you have any questions, please feel free to contact our secretariat (Mr. Chiaki Morikawa, E-mail:morikawa@jmcti.or.jp)).

Sincerely yours,

KANNO Yasuhiko
Chairman
Environment Law Committee

2Comment on Notice of intent to issue a notice under section 46 of the Act with respect to reportingof certain plastic products for 2024, 2025 and 2026
We, the Japan Machinery Center for Trade and Investment, would like to express our gratitude to theGovernment of Canada for inviting public comment regarding consultation on Notice of intent to issue
a notice under section 46 of the Act with respect to reporting of certain plastic products for 2024, 2025and 2026.
NoticePlastic pollution - Canada.caWe support the initiative of the Government of Canada aimed at the elimination of plastic waste.
We are vigorously committed to voluntarily promoting assessment activities that take into accountthe entire life cycle in order to protect human health and the environment and to reduce plastic waste
worldwide, and to complying with national regulations on plastic waste by a number of countries. In
particular, we have been active in complying with those in Europe and North America.
After diligent consideration of the published notice, we are concerned about several provisions thatmake it difficult for producers to comply with this notice in practical terms, and we would like tosubmit the following comments.
1. Data provision should not be required for EEE/machinery products and the packaging.
(1) Currently, there is no country or region that requires provision of data for EEE and machinery
products, such as the plastic resin used in EEE/machinery products and the weight of plastic used,
as required in the proposed Plastic Registry.
(2) It is very difficult or impossible to provide detailed information about the resins that make up
EEE/machinery products for the following reasons.
-Each EEE/machinery product is complexly composed of hundreds of parts and thousands ofmaterials. It is practically impossible to investigate, and accurately report detailed information oneach material, such as its raw material, weight, and whether it is virgin material.

-The components or units that make up EEE/machinery products involve multiple suppliers andprocesses in a complex supply chain, which requires a significant amount of time to trace.
Furthermore, material information is often not available owing to supplier trade secrets orcontractual reasons.

3- Provision of such data retroactively for products which have already been designed is especiallychallenging.
(3) At the provincial level, Canada enforces EEE and packaging collection and recycling laws, as well
as appropriate collection and recycling through stewardship and blue box programs.
(4) There are no major issues under the current laws and regulations, and requiring each importer toprovide information on each type of plastic and each product with new legislation that goes beyond
the current standards would be unduly burdensome.
(5) We therefore propose that data provision not be required for EEE/machinery products and thepackaging, so as to avoid it becoming a trade barrier for placing EEEs on the Canadian market.
Instead, we would suggest that the federal government establish a mechanism to obtain the data incoordination with the existing reporting systems of the provincial level regulations.
2. First, the discussion on how to utilize plastic data should be deepened.
Since there is insufficient consideration of how to utilize the data obtained, and the information
required will vary depending on how it is utilized, discussions on how to utilize the data should firstbe deepened, and then the information that is really needed should be collected by means which is notexcessively burdensome to manufacturers.

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