As noted in Ontario’s…

As noted in Ontario’s Resource Recovery and Circular Economy (RRCEA), “It is in the provincial interest that Ontario have a system of resource recovery and waste reduction that aims to,
(a) protect the natural environment and human health;
(b) foster the continued growth and development of the circular economy;
(c) minimize greenhouse gas emissions resulting from resource recovery activities and waste reduction activities;
(d) minimize the generation of waste, including waste from products and packaging;
(e) increase the durability, reusability and recyclability of products and packaging;
(f) hold persons who are most responsible for the design of products and packaging responsible for the products and packaging at the end of life;
(g) decrease hazardous and toxic substances in products and packaging;
(h) minimize the need for waste disposal;
(i) minimize the environmental impacts that result from resource recovery activities and waste reduction activities, including from waste disposal;
(j) provide efficient, effective, convenient and reliable services related to resource recovery and waste reduction, including waste management services;
(k) increase the reuse and recycling of waste across all sectors of the economy;
(l) increase opportunities and markets for recovered resources;
(m) promote public education and awareness with respect to resource recovery and waste reduction;
(n) promote cooperation and coordination among various persons and entities involved in resource recovery activities and waste reduction activities;
(o) promote competition in the provision of resource recovery services and waste reduction services;
(p) foster fairness for consumers;
(q) do any other related thing that may be prescribed.”

INDUSTRY PRODUCERS and CORPORATE LOBBYISTS are among the stakeholders that have proposed changes to the RRCEA. These proposed changes are counterproductive to Ontario’s waste reduction efforts and are not in the best interests of human health and the environment.

These stakeholders have asked the province to delay their responsibilities to establish sustainable programs; have indicated that they will no longer provide services to the IC&I sector; and have asked for approval to incinerate their products to meet their diversion targets. These proposed changes are unacceptable and should be denied.

NO MORE DELAYS: Corporations and producers have long been aware of waste problems as a result of their choice of products/packaging. Yet, instead of taking pro-active measures to adopt best-use practices, closed-loop systems, and designs that prioritize 3R’s hierarchy to protect resources, they have continued with unsustainable models.

Corporations should not be allowed to choose the cycle of mine/produce/dispose, when sustainable alternatives have existed for decades.

Across Ontario, Canada, and around the world, successful examples of circular economy policies and programs exist. Corporations have the ability to reduce waste, and to provide durable products that can be refilled and products/packaging that can be reused, repaired, recycled, and/or composted.

Deposit-Return Systems (DRS) are one example of a sustainable program that can be introduced quickly for a variety of materials. DRS protect resources; reduce energy; divert cleaner materials for reprocessing; make producers and consumers responsible for costs; and can work alongside blue box programs.

DATA/DOCUMENTS/INFORMATION: Stakeholders claim they need more time, more data, more documents, and more information to ensure that changes to Blue Box Regulations will be “sustainable and effective for years to come”. Industry obviously has its own production data and has the ability to collaborate with other producers to collect information and adopt sustainable programs. Producers can choose to make durable products that can be refilled, and products/packaging that can be efficiently reused, repaired, recycled or composted.

There is no reason to delay sustainable programs because of lack of information.

CONTAMINATION OF BLUE BOX MATERIALS: Stakeholders say they want to maintain blue box services for residents. While this may be a good idea for some materials, they know that items collected in the blue box can become too contaminated, and end up being disposed of into landfill or incinerated.

Food and beverage containers account for a majority of material diverted in blue box programs. Alternative collection systems, especially DRS, are being used effectively in other jurisdictions to collect these containers with far less contamination and better results for reuse or recycling.

Ontario’s DRS for alcoholic beverage containers has been widely recognized for its high diversion rates. The Beer Store has been the primary location to return these containers and, until recently, one of the few places to purchase beer. The Ontario government’s decision to sell alcoholic beverages at convenience stores changed that. But unfortunately, the government failed to ensure that these stores would also be required to collect returns from customers.

Since the arrival of beer in convenience stores 83 Beer Stores have closed, with possibly 42 more to follow by the end of the year. This means there are fewer and fewer locations for customers to return containers. It also means that Ontario will lose all the benefits that are realized with effective DRS.

Industry stakeholders have opposed to DRS in Ontario for decades, as they quickly phased-out refillables, claiming consumers would rather buy single-use products. In fact, it was their marketing schemes that influenced wasteful purchasing habits, and their choice to eliminate refillables was to their financial advantage, since they were no longer responsible to collect and refill containers, and costs to collect/dispose/recycle single-use products were left to municipal taxpayers.

Corporations have had lots of time to make better choices. Now, as Ontario’s Blue Box Regulations soon shift program costs from municipal taxpayers to producers, lobbyists are pressuring government officials to make policy changes to suit their corporate interests (i.e. their bottom line).

Government officials must make protecting public and provincial interests a priority and need to hold corporations accountable and in check, and require them to adopt sustainable solutions now.

INCINERATION DAMAGES HEALTH AND THE ENVIRONMENT: Stakeholders have asked the province for permission to incinerate materials so they can meet their recovery targets, and have tried to justify incineration of their materials by saying it would produce energy in the process, even though more energy is saved by reusing resources.

Stakeholders say they want to maintain the blue box for residents, but they know that materials can be contaminated in the process, making those materials unfit for reprocessing and destined for disposal. Incineration is not a sustainable solution to this problem.

Incineration, and its many aliases, contaminates the air, land and water, and destroys resources that could otherwise be reused, when collected more efficiently.

The request, by stakeholders, to be permitted to incinerate materials to meet their diversion targets, or for any other reason, must be denied to protect natural resources, jobs, and human health.

MAINTAIN DIVERSION PROGRAMS FOR THE IC&I SECTOR: Apparently, industry “has decided to end small business collection once the blue box system has fully transitioned in 2026”, which would leave municipalities responsible for programs.

Extended Producer Responsibility was adopted to ensure that producers would be responsible to collect their products/packaging, when discarded by consumers.

Producers benefit from selling their products to/through small businesses and the IC&I sector. Producers must be responsible to provide efficient and sustainable programs to this sector, at their own expense. This must NOT be a municipal expense.

DON’T IGNORE THE GROWING PROBLEM OF DISPOSABLE DIAPERS: Disposable diapers must no longer be ignored when establishing policies to reduce waste. Disposable diapers and incontinent products represent a large volume of feces-laced waste, being disposed of into landfills or incinerators.

Manufactured primarily in the USA, the disposable diaper industry is another multi-national, multi-billion-dollar industry, which is expecting significant growth in the future. Now is a good time to develop solutions to this growing waste problem. Corporations have the ability to develop sustainable programs for these single-use products, and must be held accountable to do so.

Government officials must designate disposable diapers as a priority and require corporations to accept responsibility for sustainable solutions now.

It is important for government to be “responsive to the needs of business”, but protecting public and provincial interests must take priority over corporate agendas.

Please deny the proposed changes to the RRCEA and invite public stakeholders to participate in workshops to stimulate discussion and creative solutions.