No Bad Questions: Can Canadians have plastic-free produce, and eat it too?

For me, it’s the cucumbers. The long, sweet, seedless ones. It’s the guilt I feel, unpeeling them from their plastic sheath, tossing it in the garbage.  That guilt re-doubled when, inevitably, a few days later, I’m mopping up the decomposed end—the last forgotten quarter of cuke— from the veggie crisper.  

Like so many of us, I want to do better. I definitely want to throw away less plastic, and I urgently want to waste less food.  What I’ve only just started to realize, however, is that these two goals have, not exactly an inverse relationship, but a complicated one. 

If I have learned anything from my time at Generate Canada, it’s that making progress on wicked challenges like plastic waste and food waste requires a patient and thoughtful reckoning with the complex systems that produce them.  One way to light up the messy threads of any problem is to try to solve it.  So this story starts with a set of hotly debated proposed regulations to reduce plastic waste from the produce we buy.  

Spoiler alert:  the happy ending here isn’t about how to design a perfect plastic waste policy (if such a thing is even possible).  Rather, it’s about what happens when we start to grapple, clear-eyed, with our imperfect systems and the imperfect choices they serve us. Namely, the opportunity for true innovation. 

Canada’s Proposed Pollution Prevention Plan 

In August 2023, in line with Canada’s zero plastic waste agenda, the Federal government proposed a new set of rules, targeting large grocery retailers, aimed to eliminate plastic waste from primary food plastic packaging. That’s packaging that comes in direct contact with food (e.g. a plastic cucumber wrapper).  For example, as part of these new rules, stores would need to develop and implement a plan to distribute 75% of fruits and vegetables plastic-free by 2026 and 95% by 2028.  They would also have to get rid of those little non-compostable plastic produce stickers (PLUs, they’re called), the kind I always forget to peel off my apples and end up pulling out of my mouth. 

There is a compelling rationale behind these proposed rules.  Namely that way too much of what we buy in the grocery store, including in the fresh produce section, is packaged in plastic that we use once and throw away. While it’s true that fresh produce packaging is both a small portion of packaging in general and an even smaller portion of overall plastic waste, it’s worth understanding its impact.  A recent audit conducted by the Federal Government found that roughly 48% of fresh produce in Canada is sold prepackaged in plastic.  According to the Canada Plastic Pact, an estimated three million tonnes of plastic end up in landfills, nature, or are burned every year, in this country alone. 

Since Canada’s big grocery stores are responsible for distributing roughly 80% of the plastic packaged food we buy, holding them accountable for reducing that packaging in this way makes sense. Right? 

Well, maybe not.  The Canadian Produce Marketing Association (CPMA) – a member of the Canada Plastics Pact – takes a different view. And here is where the complexities come to life. 

One Small Market in a Global Produce Supply Chain

“What we’re talking about here is fundamentally altering the supply chain configuration for all produce,” explains Daniel Duguay, sustainability specialist at the CPMA.  Duguay tells us that four out of every five dollars spent on fresh produce in Canada is spent on imported fruits and vegetables—think about your California strawberries, Mexican avocados, Costa Rican bananas, Chinese kale, and Peruvian grapes. Our produce section is a veritable “small world,” and Canada is just one, relatively small market at the end of these international supply chains. 

“When oranges leave South Africa, they aren’t packaged just for us,” says Duguay, “they’re packaged for Europe, Australia… So if you were to impose a ‘thou shall not use plastic packaging to ship produce to Canada,’ rule,  that would basically require a separate supply chain just for Canada.”  That just isn’t going to happen, says Duguay, and he isn’t guessing; he has the receipts. “We have that in writing from major suppliers saying they would not ship to Canada if we impose these rules that require a secondary supply chain.” 

Okay, so this isn’t a challenge that Canada, or our grocery retailers, can independently solve because of our dependency on imported produce. From this angle, plastic reduction isn’t rubbing up against food waste exactly, but rather food availability.  Following this thread opens up another worthwhile and tricky conversation about the virtues and barriers of the “eat local, eat seasonal” movement. But, I’m not sure if that discussion would get us closer to unraveling the plastic packaging problem. 

Case in point, my plastic-clad English cucumbers are grown in Ontario hothouses all year long. In fact, according to the Ontario Greenhouse Vegetable Growers association, Ontario is the largest producer of cucumbers, peppers, and tomatoes in North America. There’s a supply chain that Canada could impose some plastic reduction rules around.  Why not start there?  

Moving Water: The Packager’s Dilemma 

Duguay’s answer to that question is another question. “What is produce made of?”  Water. Life.  Produce supply chains are basically trying to move living, perishable things from the place they were grown to your plate, losing as little as possible along the way. The clock starts ticking the second those fruits and veggies are harvested. And, for packagers, minimizing packaging waste and pollution is just one piece of the puzzle. Their job is also to: minimize food waste and loss, ensure food safety, maximize food accessibility, manage food costs, and limit greenhouse gas emissions. 

“Every packaging decision is a sustainability decision,” Duguay explains.  And sometimes plastic is actually the most sustainable choice, when all of these things are equally considered, he suggests. Plastic is light-weight, so transporting it burns less GHGs. Plastics can perform complex functions like keeping the right gasses in and the wrong gasses out, which preserves delicate lettuce leaves and thin-skinned English cucumbers.    

In response to the government’s proposed plastic rules for primary food packaging, the CMPA worked with its members and partner associations at home and abroad to conduct their own analysis. Their goal was to quantify the potential cascading consequences of an all out plastic ban on produce packaging.  The findings include some harrowing predictions.  Fresh food waste and greenhouse gas emissions could both rise by more than 50%. Canadians in rural and remote regions could see produce prices go up and availability of fresh food go down.  These are outcomes nobody wants. 

That includes the Federal Government.  In April 2024, Canada released its own study aiming to “identify limiting factors for selling fresh produce loose or in non-plastic packaging.” What they found was that comparing packaging requirements for different types of fruits and vegetables was, quite literally, like comparing apples and oranges.  In other words, what you are packaging—the physical and biological characteristics of a given type of produce—determines the relative importance that packaging (plastic or otherwise) plays in getting that fruit or vegetable safely and in edible condition to your table. “A direct correlation exists between the importance of packaging functions related to product protection and a product’s perishability,” the report reads.  

This seems, well, obvious – doesn’t it?  But the value of this analysis is that it can guide smarter and more nuanced policy efforts. It can help parse out where eliminating plastic packaging would cause more harm than good and, subsequently, where we can make some real plastic reduction inroads. Namely, that would involve targeting plastic that is being used primarily for cost and efficiency purposes rather than for protection (think: a bunch of onions sold in a plastic mesh bag vs individually in a bin).  

The report concludes with an optimistic projection, that it would be possible  (not fast, not easy, but possible) to cut plastic packaging for produce in half, without increasing food loss and waste. 

Not everyone shares this optimism.  One thing the report’s scenarios did not take into account was the impact on food price, reminds Duguay. “If cost was no object, then maybe these scenarios would be possible, but food affordability is a complex equation,” he says. Clearly there is more to unpack on this question (pun intended). 

From Either-Or to Both-And

This approach, getting granular on the trade-offs between packaging waste and food loss waste as a foundation for problem-solving, isn’t new.  In fact, back in 2020, the National Zero Waste Council (also a Canada Plastics Pact member) teamed up with Vancity, Recyc-Quebec, and Eco Enterprises Quebec (EEQ) to examine how we can do “both-and.”  The final report, Less Food Loss and Waste, Less Packaging Waste, starts from the premise that – if we care about achieving climate goals, if we care about sustainable development and the growth of inclusive economies – we have no choice but to tackle both of these challenges together. 

“Yes, there is a tension,” says Denise Philippe, senior policy advisor of the NZWC, “but it is sometimes presented as a larger tension than it should be.   We know from this report that there is a way to reduce both food waste and plastic waste.  We don’t have to have this trade-off where we’re going to say ‘no plastic packaging.’ That would be a problem.”  

Like Duguay, Phillipe emphasizes that packaging can be critical to ensuring shelf life, keeping food safe, and communicating critical information to consumers. “But it’s a false dichotomy to say that we’re going to lose all of our food and have all this food waste if we have no plastic or that if we have all this plastic, then we have no food waste.” 

Her example:  cucumbers!  While wrapping a single English cucumber in plastic may be a necessity, taking three of those individually wrapped cucumbers and wrapping them together in a second layer of plastic probably isn’t.  “My mom is 81,” says Phillipe, “she can’t eat three English cucumbers in a week, but because of how they are packaged, she can’t buy just one.  The other two end up in the compost. And that’s an example of packaging actually creating food waste.”  

Her bigger point is that we need to start by asking how much packaging we can  feasibly reduce upstream, before food gets to the customer. Where packaging is necessary, we need to be very deliberate about how we package food (e.g. in what quantities), and what materials we choose (including and beyond plastic). 

“There are emerging packaging innovations that may, in some cases, be excellent alternatives to plastic,” says Philippe. Apeel, for example, offers an invisible and edible produce coating that extends the shelf life of certain types of produce, such as avocados. Philippe also points out that while fresh produce presents specific plastic packaging challenges, there are other food products such as pasta that can be sold in bulk and require less packaging, and less plastic, in general. Again, being nuanced on the type of food and the packaging it requires – both type and quantity – is an important part of this discussion. “Thinking about the plastic waste and food waste trade-offs means we need to be thinking about waste prevention, not just recycling,” Philippe emphasizes. 

Genevieve Dionne, an eco-industrial designer with EEQ, agrees.  “The first question everyone asks is about recyclability. But we have to start upstream. We should be thinking about source reduction and re-use. We should be thinking about the whole system.”  

“End of life” considerations do matter, of course,  and we need innovation on that front too.  For example, flexible plastics (like  my cucumber wrapper) pose a major recycling challenge.  Light, easy to use, and flexible, as the name suggests, these plastics were a “disruptive innovation in the packaging industry,” explains Dionne, and the recycling industry just didn’t keep up.  “But we’re not going backwards,” she says, “they are here and we have to deal with them.”  In Dionne’s view, that means starting at the source and choosing flexible packaging that checks at least two boxes:  (1) it protects food well and (2) it can be collected, sorted, and recycled effectively at the end of its useful life. 

Imperfect choices drive innovation

The thing about complex problems is that they don’t have simple, silver-bullet solutions. There is no one policy, no technological innovation, and no best practice that will eliminate all the trade-offs and the tensions between food waste and plastic waste.  What there is, however, is a tremendous amount of space for creativity and innovation that will result in, not perfect choices, but much better ones. 

“There are so many other questions that need to be asked beyond do we wrap this in plastic?” says Phillipe. “Can we shorten our supply chain so food doesn’t have to travel as far? Can we create reverse logistics to lower the impact of food transportation? Can we look at reusable systems or plastic alternatives? There are all these interventions that can happen, and we need to think of everything at once.”  

Change is happening. In June, in response to increasing consumer demand as well as pressure from governments, including Canada’s, the CPMA and the Western Growers association (based in California) officially joined forces to develop a set of North American packaging guidelines aimed to synchronize and optimize fresh produce packaging to address the challenges of food waste and material waste. 

Even more recently, in October, international leaders from the fresh produce and compost industries agreed to develop a global standard for certified compostable PLU stickers. If you’re wondering why that’s a big deal, remember that one of Canada’s new proposed rules is the elimination of non-compostable plastic PLUs.  Here’s the thing: what’s compostable in one country (say, South Africa where your oranges are grown and packaged), may not be compostable in another (say, Canada).  One little sticker can contaminate an entire industrial pile of food scraps—sending it to the landfill (where it rots, producing harmful GHG emissions) instead of to the composter, where it would be recycled into soil.  Having a single global standard for compostable stickers is not just a waste solution, it’s a climate solution. 

Just eat the darn cucumber

Given everything I learned writing this article, I feel a little less guilty when peeling the plastic off my cucumbers. But I still don’t like it.  There’s a realistic future where maybe I won’t have to do it anymore.  A Sweden-based company called Saveggy is pioneering a plant-based packaging alternative, made with canola and oats, that coats fragile produce in a thin, invisible, edible layer that prevents moisture loss and slows down oxidation.  Is it a perfect solution?  Probably not.  But, like Apeel, it shows what’s possible. 

When I ask Cher Mereweather, Managing Director of the Canada Plastics Pact (CPP), for cucumber advice – she points to a much simpler, low-tech answer.  Just eat the darn cucumber.  

“The first order of business is getting rid of unnecessary and problematic plastics,” she says. “And we definitely have to deal with the problem of flexible plastics – moving away from the complex, multi-layer materials to what we call ‘mono-materials,’ which are easier to recycle.”  In 2023, CPP launched a 5-year road map to create a circular economy for flexible plastics in collaboration with players across the plastics value chain, as well as non-profit, academia and public sector experts.  

But for me, a regular old cucumber buyer, the most important step I can take is just to finish the whole cucumber. “The whole point of that plastic packaging was to ensure that you could have fresh, healthy produce in your fridge. So my advice:  do everything you can to fully enjoy that food, and leave as little waste as possible.”  

Cucumber sandwiches, anyone?

__________________________________________________________________________________________________________________________________________________

No Bad Questions is a Generate Canada series that explores the tensions and conflicts that are inherent to our work of solving wicked problems. In bringing our tough internal conversations out into the open, our hope is to show that it is not only possible to grapple with messy issues in a non-polarizing way, it is actually necessary to make progress.