Waste Connections of Canada…

Waste Connections of Canada’s Response to Amendments to the Blue Box Regulation

Ministry of Environment, Conservation and Parks - ERO number: 025-0009

Introduction

Waste Connections of Canada (WCC) is pleased to respond to the Amendments to the Blue Box Regulation. Overall, Waste Connections’ is supportive of the proposed amendments whose goal is to curb higher than expected costs borne by Ontarians. The Blue Box Regulation required amending in order to streamline the regulation and bring it back in line with 2019 policy recommendations made by then, MECP Special Advisor David Lindsay's, report on the Blue Box Program.

In recent years, the Blue Box regulation has evolved away from the goals of the province’s initial 2019 review. This amendment process, in addition to curbing cost increases, would be bring the Blue Box regulation back in line with the province’s initial consultations with municipal and industry stakeholders and the subsequent recommendations that were meant to improve recycling by increasing the number or products that can be recycled, while making sure the program continues to be accessible and convenient.

Waste Connections knows our sector is key to supporting the goal of strengthening Ontario’s economy while protecting the environment. We believe that extended producer responsibility can play a role in Ontario’s recycling system but only if it is applied strategically, otherwise it could have several unintended consequences, including increased costs. Our response focuses on the amendments that seek to achieve these goals, and some further amendment suggestions that could be made to achieve the province’s goals

Waste Connections of Canada and its Role

Waste Connections is the premier provider of solid waste collection, transfer, recycling and disposal services in primary and secondary markets across Ontario, Canada and the US, serving millions of customers. Whether it is single or multi-family residences, commercial institutions, industrial locations, construction sites or special events, Waste Connections provides service to meet customer’s needs.
Waste Connections of Canada is an affiliated company of Waste Connections Inc., which is traded on both the TSX and NYSE, and is the 3rd largest industrial traded company in Canada. We operate in 46 states and 6 provinces across North America and operate over 20 facilities waste and recycling facilities in Ontario employing over 1200 people across the Province.

Waste Connections Commentary

As a company actively engaged in Ontario’s waste management and recycling sector, Waste Connections is pleased to express strong support for the proposed amendments to the Blue Box Regulation and the Resource Recovery and Circular Economy Act, 2016 as outlined in ERO # 025-0009.
We commend the Ministry for taking steps to address the unanticipated cost increases associated with the Blue Box program. The proposed amendments reflect a thoughtful and balanced approach to maintaining service continuity while ensuring long-term financial sustainability.

In particular, we strongly support the removal of multi-residential buildings from the expanded collection requirements and the renewed focus on single-family households. This adjustment acknowledges the significant logistical and cost-related challenges of servicing multi-residential properties under a uniform regulatory framework. By concentrating efforts on single-family homes—where participation rates are higher and contamination rates are typically lower—the province is facilitating and enabling a more efficient and effective recycling system.

By narrowing the scope, the province is also enabling service providers like us to deliver more consistent, efficient, and high-quality collection to both single-family and multi-residential homes. Multi-residential whose collection falls into the industrial commercial and institutional sector, which has its own separate set of goals and operational structure. It also opens the door for alternative, customized solutions for multi-residential buildings, which can be developed through partnerships between producers, municipalities, and private service providers like us.

This amendment aligns with the 2019 recommendations made by MECP special advisor David Lindsay that “offices, institutions and other commercial sectors should not be included in a producer responsibility framework”. This allows for more tailored and innovative solutions to be developed for multi-residential settings outside the regulatory framework, through partnerships with property managers and municipalities.

Additionally, we support the proposal’s commitment to enhanced transparency and cost reporting. These measures will help ensure that producers and service providers are aligned on performance expectations and cost structures, fostering a more accountable and collaborative circular economy.
We also appreciate the Ministry’s openness to technical amendments that improve clarity and implementation. These refinements will help ensure smoother transitions and better compliance across the sector.

Opportunities for Further Efficiency: Transportation Logistics

In addition to the proposed changes, we encourage the Ministry to consider conducting a comprehensive analysis of the transportation logistics within the Blue Box system. The transformation from local sorting and baling operations to a loose material Transfer system with centralized sorting and baling has significantly increased overall handling and processing costs. Transportation remains one of the most significant cost drivers in the collection and processing chain. By identifying inefficiencies in routing, depot locations, and material flow, the province could unlock substantial cost savings and reduce greenhouse gas emissions. Leveraging data-driven logistics planning and regional coordination could further enhance the environmental and economic performance of the system.
Conclusion

Overall, these amendments demonstrate the Ministry’s commitment to refining the Blue Box program in a way that is both environmentally responsible, operationally feasible and fiscally responsible. We look forward to continuing our work in support of Ontario’s waste diversion goals and to contributing to a more efficient and effective resource recovery system.