The letter outline how Phase II may require individual farms to report the quantity of plastics used on their operations. Because similar data is already collected and can be more easily obtained from manufacturers and suppliers, this approach risks creating a duplicative and inefficient reporting system.
It could generate thousands of individual farm reports, increasing the administrative burden on both producers and government, and diverting time and resources away from core farm activities.
Rather than introducing new reporting obligations at the individual farm-level, we encourage the government to exempt farmers from these requirements and instead pursue more efficient data collection approaches for agricultural plastics. The current pause provides an important opportunity to refine the framework and avoid unintended burden on producers.
The letter recommends that:
- The government exempt farmers—both land-based and aquatic—from farm-level reporting requirements and collect the information upstream and downstream from agricultural operations.
- Leverage existing data collected from agricultural plastics manufacturers and suppliers already subject to registry reporting requirements.
- Work collaboratively with agricultural organizations and industry partners to identify alternative mechanisms for collecting any additional data that may be required.