Board Converting News, January 26, 2026

PPEC Outlook (CONT’D FROM PAGE 10)

and unintentional, or legacy, PFAS, and how recycled con- tent may be affected. As regulatory approaches continue to develop in Canada and globally, understanding how PFAS move through supply chains and recycling systems, and how they can be managed and mitigated, remains an evolving area of research. While there is still much to learn, one thing is clear: addressing PFAS will require coordinat- ed action, as it is not an issue any single sector can solve in isolation. Environmental Claims PPEC continues to monitor developments related to making environmental claims in Canada, including Budget 2025’s proposal to amend certain greenwashing provi- sions under the federal Competition Act. Proposed changes include removing the requirement that environmental claims be substantiated using inter- nationally recognized methodologies. This comes on the

packaging. In Canada, the federal government is advancing its PFAS approach under the Canadian Environmental Pro- tection Act (CEPA). This includes a proposed class-based approach that would add PFAS, excluding fluoropolymers, to the List of Toxic Substances, enabling future regulatory controls. The first phase of this framework has begun with the Prohibition of Certain Toxic Substances Regulations, 2025, published on December 31, 2025, and coming into force on June 30, 2026. While this initial phase does not focus on packaging, Phase 2 is expected to target food packag- ing materials. Key issues for the paper packaging industry include the need to distinguish between intentionally added PFAS

heels of a recent leadership change at the Competition Bureau, as Commissioner Mat- thew Boswell ended his term early. Under his leadership, the Competition Act was amended to strengthen provisions aimed at addressing greenwashing. Taken together, these developments in- troduce uncertainty about how environmen- tal claims will be interpreted and enforced going forward. As this evolves, businesses should be mindful of a shifting environmen- tal claims legal and regulatory landscape in Canada and review company and product sustainability disclosures to assess risk and ensure appropriate substantiation. The Bottom Line These issues reflect a common theme: environmental policy affecting packaging and recycling is becoming more complex and the impacts are adding up. In 2026, the industry will be dealing with several policies at the same time, many of which are still evolving. This is less about any one regulation and more about their combined effect. EPR is becoming more expensive and more vis- ible, PFAS presents new challenges with many unanswered questions, and other pol- icies continue to shift. The result is a policy environment where expectations are increasing, and where de- cisions made to address one requirement can have effects elsewhere, both within organizations and

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across the broader packaging and recy- cling landscape. Rachel Kagan is the Executive Direc- tor of PPEC .

50 East Court Mandeville, La 70471

Ph: 985-875-7777 Fx: 985-875-7778

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email: sales@airsystemsdesign.com • www.airsystemsdesign.com

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January 26, 2026

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