1. Amendment Fails to…

1. Amendment Fails to Advance Circular Economy Goals
The amendment does not help achieve a true circular economy.
It relies on municipalities to provide waste collection for small businesses and organizations, subsidizing large corporate polluters.

2. 'Polluter Pays' Principle Undermined
The Act’s intent is to hold those responsible for product and packaging design accountable for end-of-life management (“polluter pays”).
The amendment creates a loophole: producers are only responsible for products used at home, not in non-eligible locations (NELs) like cafés, hairdressers, charities, etc.
This loophole lets producers avoid responsibility and charge high fees to NELs.

3. Municipalities and NELs Bear Unfair Costs
Municipalities or NELs must pay for collection at recycling centres now monopolized by producers, or through new municipal charges.
This shifts costs from producers to local communities and small organizations.

4. Producer Responsibility Organizations (PROs) Are Not Independent
PROs, such as Circular Materials Ontario (CMO), are owned by major producers (e.g., PepsiCo, Loblaws, McDonald’s).
Profits and cost savings flow back to these producers, not to the public or environment.

5. Simple Solution Proposed
Amend legislation so all materials are the producer’s responsibility to collect if requested, regardless of location.
Complaint-based enforcement: Any NEL needing collection can request it, minimizing administrative burden.

6. Counterarguments Addressed
Tracking NELs is not too hard: Locations can self-identify for service.
Small business exemption is not a major issue: Most packaging is produced by large companies.
Cost to producers is not prohibitive: Major producers make billions in profit; the estimated investment required is relatively small.