1. Service to more multi…

1. Service to more multi-residential buildings: Since multi-res buildings are sources of residential blue box materials, the Province should not eliminate the requirement for producers to service buildings not currently serviced by municipalities. Instead, the Province should conduct a study to determine how many buildings and units are not currently serviced and why. There are usually only two reasons – the building owner refused to comply with municipal collection service standards, or a municipality decided not to service multi-res buildings to save costs. The study would identify buildings that are able to receive automated blue box collection service. The Province can then create a timeline for these buildings to be added to the producer-run blue box program. Any amendment to the Blue Box regulation should also stipulate that all newly built multi-res buildings that comply with collection standards must receive collection service as soon as they are occupied.

2. Public space recycling: The requirement for producers to provide public space recycling should not be removed unless producers implement an alternative system for recovering residential blue box materials discarded as litter in public spaces. A December 2024 report prepared by Eunomia Research & Consulting Inc. for the Continuous Improvement Fund entitled " Preliminary Municipal Litter Data Analysis" (see link to thecif.ca) estimated that Ontario municipalities are spending approximately $56 million per year to collect blue box material litter from park grounds, road allowances and litter bins. Furthermore, the report estimated that a deposit return system (DRS) for non-alcoholic beverage containers could reduce provincial and municipal litter management costs by an estimated $7M per year. See the alternative approach below.

3. Beverage container recovery target: Removing beverage containers sold into the ICI sector from the denominator of the recovery targets is counterproductive and unnecessary. It would eliminate the incentive for producers to collect beverage containers "away from home" and will continue the current situation where the majority of the beverage containers consumed in the ICI sector are sent to landfills or littered. The stated rationale that “Producers lack a cost-effective away from home collection network to meet regulated recovery targets in 2026” is inaccurate. See the alternative approach below.

4. Alternative approach: The only scenario under which removing the requirement for public space recycling should be considered is one requiring producers to implement a DRS for non-alcoholic beverage containers. This would provide a cost-effective approach to recovering beverage containers across both the residential and ICI sectors, reduce public space litter and eliminate the need to adjust the beverage container recovery target. A DRS could potentially double the non-alcoholic beverage container recovery rate currently achieved by the residential-only blue box collection system. The Province should reconvene the DRS working group it disbanded in 2024, work to overcome the objections raised by grocery retailers and implement a DRS for non-alcoholic beverage containers, as has been done successfully in eight other provinces and two territories.

5. Flexible plastics recovery target. The recovery target for flexible plastics should not be reduced to 5%. As this is the current recovery rate achieved by collecting polyethylene plastic bags in some municipal recycling programs, there would be no incentive for producers to expand plastic bag collection to all municipalities in Ontario. The Province should conduct an analysis to determine the quantity of plastic bags that could be recovered if they were collected in all municipalities, and increase the target to incorporate that potential tonnage.
The 5% target would also not provide an incentive for producers to collect other flexible plastics (e.g., stand-up pouches, snack bags, candy wrappers, tubes). It should be noted that non-recyclable plastic stand-up pouches are the fastest growing packaging format for food and beverages, and are filling up Ontario landfills at an increasing rate (see link to Global Market Insights report).
Since the Province is proposing to allow 15% of any one material category sent for energy recovery to count toward recovery targets, producers should be required to collect stand-up pouches in the blue box system starting in 2026 and ship them to existing energy recovery facilities in Ontario. Other flexible plastic packaging types can be added to the system once more sophisticated conversion technologies are proven to operate at scale. One potential solution the Province should track is the Pyrovac Inc. mixed plastics pyrolysis system planned for installation at the Sustane Technologies facility in Nova Scotia (see link to Sustane Technologies press release).