Magazines Canada represents…

Magazines Canada represents small and local magazine publishers across Canada, including 112 Ontario member businesses. We appreciate the opportunity to respond to the proposed amendments to O. Reg. 391/21 under the Resource Recovery and Circular Economy Act, 2016 .

Our members produce high-quality Canadian cultural content, enriching local communities and contributing to media diversity. Yet, they are disproportionately burdened by Ontario’s current Blue Box framework, facing rising costs, opaque stewardship systems, and unfair treatment compared to other print media. We support the Ministry’s intent to curb system costs and provide flexibility, and we urge additional action to protect the economic viability of small magazine publishers.

Regarding the delay in recovery targets, we support the proposed five-year extension for the enforcement of recovery targets.

We believe that there should be added measures to advance fairness for magazine publishers who are already operating on narrow margins. Magazines are not packaging and cost savings through reducing tonnage means cutting page length and reducing circulation for a product that many readers will keep on their shelves for years and share with friends, family, and industry peers. We specifically recommend extending the newspaper exemption to include magazines.

The Ministry correctly identifies the need for better oversight of Producer Responsibility Organizations (PROs), as the current system still leaves small producers negotiating opaque and non-negotiable contracts with entities they cannot influence. Our members would like to see standardized contract disclosures, including cost formulas and service inclusions, as well as the establishment of a public registry of PRO performance metrics.

Appreciating that there may be amendments to the Blue Box Regulation (Ontario Regulation 391/21) which would make printed educational materials optional, we do want to urge caution. Shifting entirely to digital may marginalize non-digital readers and allowing producers to fulfill public education duties through existing and new content partnerships with local media (including magazines) would support both outreach goals and industry sustainability.

Finally, while the Ministry’s goal to control costs is clear, small businesses in the publishing sector would like to be better involved in these kinds of reviews in the future. If the Government of Ontario were to undertake a small publisher impact study and commit to a review of how EPR fees affect Canada’s cultural media sector going forward, that level of engagement would be deeply appreciated, as ongoing cost pressures risk accelerating the closure of many independent outlets across Ontario.

In conclusion, Ontario’s Resource Recovery and Circular Economy Act system should not penalize environmentally responsible producers of recyclable, non-packaging content. With targeted relief for magazine publishers, collaboration on public education, and administrative simplification, the province can ensure a more equitable and sustainable system—without compromising recycling outcomes.

We thank you for your leadership in reviewing the regulation and welcome the opportunity to collaborate further.

-Magazines Canada