The Ministry posted…

The Ministry posted amendments to the Blue Box Regulation (O.Reg 391/21) made under the Resource Recovery and Circular Economy Act, 2016 (RRCEA) that also included a request for feedback with regards to efficiencies for small businesses located on residential routes.

The Council for the Township of McNab/Braeside is in favour and supports future amendments to the Blue Box Regulation (O.Reg 391/21) that would permit Producer Responsible Organizations (PRO's) to work with Municipalities to continue the collection of all non-eligible sources (small businesses, daycares, places of worship, etc.) that are located along residential routes. (RESOLUTION - 311-2025)

Within our rural municipality there are currently 52 collection stops that would be classified as non-eligible which represents 1.5% of all collection stops (eligible and non-eligible). These non-eligible stops are located on residential routes and are spread throughout the Township which is serviced over 4 collection days each week.

Since the Township of McNab/Braeside transitioned to a full producer responsible program in July 2023, the Township has worked with the PRO's and their collection contractor to continue servicing the non-eligible stops that are located on residential routes.

The Township has been advised by the PRO's that as of January 1, 2026 the mixing of eligible and non-eligible stops that are along the same residential route will no longer be permitted under the Blue Box Regulation (O.Reg 391/21). It is also our understanding that when the materials reach the Materials Recovery Facility (MRF) the materials are to be kept separate based on the source.

Given the rural nature of our municipality and the small number of non-eligible properties these restrictions on collection and processing have created significant hurdles for our municipality to continue to offer recycling services to these properties under the newly classified non-eligible sources.

To implement a separate collection system (either municipally or privately operated) will come at a significant increased cost as it will create a duplicate service for a small number of properties. A new service will also create environmental impacts of having duplicate vehicles on the road performing similar work. To run a separate collection service will also need a MRF to accept the collected materials which for our rural municipality is over a 2 hour round trip if they will accept the material.

As a result of the current Blue Box Regulation, small businesses, daycares, places of workship, etc. will be disproportionally impacted financially or will have to be subsidized by the general tax base if recycling collection services are to continue beyond January 1, 2026.

By permitting the PRO's to collect non-eligible sources on a residential route will continue to be the most efficient and financially viable model for non-eligible sources ( small businesses, daycares, places of worship, etc) to continue with blue box recycling and to keep these products out of municipal landfills.

It is recommended that the Ministry implement this change as quickly as possible given the January 1, 2026 deadline and the lead time required to implement appropriate recycling collection services.