I am an Ontario resident and…

I am an Ontario resident and voter. I also promote recycling at my multi-residential building.
I hope that the government will consider these submitted comments and revise the June 4 regulations for Producer Responsibility Organizations to ensure recycling is maintained and PROs are held accountable for their responsibilities to the public.

I address my concerns with the June 4 regulations below:

Re: ITEM 7: Consider the best ways to ensure collected materials are sent for processing

If the government intends to delay enforceable targets for recycling for 5 years, as amended in ITEM 1 (Delay Recovery Targets for Select Material Categories) then, at a minimum, the government must add the requirement that ALL PROs to send ALL collected materials to a recycling processor. Failure to require PROs to take the collected material to a recycling processor means nothing stops them from taking the collected materials to a landfill, which would make this a government sponsored sham and a betrayal of taxpayers who work hard to collect items and put them out for recycling.

Re ITEM 2: Remove Planned Expansion for Multi Residential Buildings, Schools, and Specified Long-Term Care Homes and Retirement Homes

This amendment would remove the responsibility of PROs to collect materials from recycling from a wider array of settings, including NEW MULTI-RESIDENTIAL buildings. If the government delegates recycling to PROs, they MUST change this amendment to require that PROs provide recycling to ALL NEW multi-residential buildings. Failure to do so means the government has delegated a public service to PROs without requiring them to provide this free, public service to all residential buildings. Not only does this failure jeopardize recycling efforts but, in the best case where these buildings use a private contractor, they will incur a cost that is not borne by existing buildings that currently receive recycling at no cost.

Thus, this failure to provide PRO recycling to all multi-residential buildings is discriminatory and undermines public efforts to recycle.

Re ITEM 12: Provide More Flexibility on Printed Promotion and Education Materials

This amendment drops the requirement of PROs to promote and educate ALL residents using printed materials. Instead, the amendment only require PROS to provide printed materials only upon the request of individual residents or municipalities and preferentially relies on online access to recycling information.

One of the secondary benefits that the government used to promote the change to PROs, was that the move would standardize what is collected for recycling across the province and thus remove any confusion about what could be recycled in different areas of Ontario. However, standardizing what is accepted in the recycling stream in Ontario means this is CHANGING - some areas may recycle more products, while other areas may recycle less. To maximize the recycling collection and decrease contamination, this means residents must be TOLD what can/cannot be recycled in the new system.

Online education does not work for individuals who are not computer savvy or who lack easy access to a computer. Also, to decrease contamination in the recycling stream, it takes repeated efforts, by all means possible, including, but not limited, to easy access to printed materials for ALL.

This means PROs need to be required to provide printed materials to all individual households and municipalities, not just upon by request, and must do so repeatedly (at least annually).

Re ITEM 1: Delay Recovery Targets for Select Material Categories

This amendment proposes removing all targets on recycling materials for 5 years. I disagree with delaying the targets as this reduces PRO accountability and PROs were aware of this pending regulation as it has been under development for years. However, if the current targets are a stumbling block, another option that would maintain accountability but be responsive to PRO concerns would be to LOWER the 2026 targets in each category, effective Jan 1, 2026, but increase them each year, till they reach the previous Jan 1, 2026, targets by Jan 1, 2031. Further, regardless of when targets are set and enforced, PROs should be required to track and publicly report their actual recycling outcomes by category, on an annual basis, beginning Jan 1, 2027.

UNMENTIONED in the regulations

Contamination is a big barrier to recycling yet the word contamination does not occur in the amendments, nor does there seem to be any penalty for PROs who bring a highly contaminated stream to recycling facilities. This is a problem as a contaminated stream makes recycling more costly and in the worse case, not possible. Contamination occurs if items, that can’t be recycled, on a cost-effective basis, are included in the stream (e.g. black plastic, some other plastics) or if items that CAN be recycled are soiled by food waste (paper, comingled with food waste, is especially easily soiled and rendered unrecyclable).

Education can decrease contamination but ultimately contamination is a system problem that PROs need to be held accountable for and penalized for, if it exceeds a target that the government should set. Note: even categorical targets by 2031 or earlier, don’t address contamination by wrong items or soiling.