July 4, 2025 The Honourable…

July 4, 2025

The Honourable Todd J. McCarthy, MPP
Minister of Environment, Conservation and Parks
5th Floor, 777 Bay Street
Toronto, ON M7A 2J3
minister.mecp@ontario.ca

Re: ERO 025-0009 - Amendments to the Blue Box Regulation

HelloFresh Canada appreciates the opportunity to provide feedback on the proposed amendments to the Blue Box Regulation. At HelloFresh Canada, we recognize the importance of improving environmental stewardship and support efforts to build a circular economy. We support the Ministry’s proposed changes to Blue Box regulations to address the growing cost pressures and system inefficiencies that threaten the sustainability of Ontario’s producer responsibility model.

About HelloFresh Canada
Founded in Germany and operating in 18 international markets, HelloFresh launched in Canada in 2016 and is now the #1 meal kit provider in the country. We offer Canadians convenient, cook-from-scratch meals with pre-portioned ingredients and easy-to-follow recipes, helping to reduce food waste and simplify meal planning and shopping.

Since 2018, HelloFresh Canada has expanded its portfolio with the acquisition of Chefs Plate, Canada’s most affordable meal kit, and the 2022 launch of Factor Canada, a ready-to-heat, chef-prepared meal solution designed for healthy, convenient eating.

We currently reach 97% of Canadians, with customers in all 10 provinces, delivering millions of fresh and nutritious meals annually, directly to Canadian’s dinner tables.

Ontario Operations & Economic Impact
-Headquartered in Toronto, with ~350 corporate staff across tech, culinary, R&D, and operations
-1,000+ employees work across our Ontario distribution and food production facilities
-We are expanding our Ontario footprint in 2025 with additional investment and capacity
-We spend $100M+ annually with Ontario-based suppliers across dairy, produce, protein, and packaging, deeply embedding ourselves in the province’s agri-food and innovation ecosystem
-We support local communities through partnerships with four Ontario food banks, donating over 550,000 meals in 2024, demonstrating our ongoing commitment to sustainability, affordability, and giving back

HelloFresh Canada business model
HelloFresh Canada operates on a direct-to-consumer, weekly subscription model, offering both pre-portioned meal kits with step-by-step recipes, as well as ready-to-eat options. Customers choose from a rotating menu based on their dietary preferences, and we handle sourcing, production, packaging, and doorstep delivery. By operating on a predictable recurring revenue model, we can efficiently manage inventory, reduce food waste, and optimize supply chain logistics.

Our flexible model allows users to skip weeks, modify, or cancel anytime with no fees, giving them full control over their weekly meal planning. Email and app reminders help customers select meals, track orders, and manage deliveries, making the experience convenient, customizable, and consumer-friendly by design.

Comments on the proposed amendments
As mentioned above, we are deeply committed to environmental stewardship, prioritizing food waste reduction and sustainability in everything we do. At the same time, as a continuously growing business in the food sector, we have concerns about the rising costs and system inefficiencies of Ontario’s extended producer responsibility model.

1. We support the proposed delay of recovery targets for key materials, including paper, glass, metals, and plastics, which allows producers time to adapt to infrastructure and supply chain limitations, as well as adapt packaging and manage compliance costs.
2. We support the proposals to remove the planned expansion for multi-residential buildings, schools, public spaces, and specified long-term care homes and retirement homes.
3. We support the inclusion of energy recovery within recovery calculations, up to a 15% cap per material.
4. We appreciate the Ministry’s efforts to clarify technical aspects of the regulation, including definitions like “multi-residential,” promotional material timelines, and French-language requirements. These changes reduce administrative burdens.
5. We encourage the government to strengthen these measures by simultaneously investing in recycling infrastructure - helping to stabilize the program, reduce costs, and improve the recovery and reuse of materials - particularly by supporting innovation in the design, collection, and processing of flexible plastics to ensure long-term system competitiveness and sustainability.
6. We encourage the government to disclose how fees are calculated and how they contribute to measurable environmental outcomes.
7. We encourage the government to strengthen the confidence in the system by providing better oversight to ensure that all producers are compliant. Processors who report accurately should not be penalized for doing so by subsidizing producers that do not comply with the program.
8. We support fee modulation strategies to reward more recyclable and circular packaging designs. We encourage the government to accelerate the adoption of eco-modulated fees to incentivize design-for-recycling and reduce costs for producers that prioritize sustainable materials.
9. Finally, we encourage the government to exempt compostable packaging from designated material lists, particularly in regions where municipal composting programs are in place. We would also welcome further guidance and a clear directive confirming that compostable paper- and fibre-based packaging will be exempt from EPR fees.

We thank you for bringing these amendments forward, which respond directly to many of our concerns. We support the direction of these changes and encourage the Ministry to continue consulting closely with industry to ensure long-term success.

Sincerely,

Ian Brooks
CEO, HelloFresh Canada
ian@hellofresh.ca

CC: Policy Branch, Ministry of the Environment, Conservation and Parks Marc.Peverini@ontario.ca