July 21, 2025 The Honourable…

July 21, 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 025-0536 - Amendments to the Resource Recovery and Circular Economy Act, 2016

HelloFresh Canada appreciates the opportunity to provide feedback on the proposed amendments to the Resource Recovery and Circular Economy Act, 2016 (RRCEA). 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 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 proposal to enhance government oversight of recycling program costs. Empowering the Minister to collect critical operational and financial data will address current information gaps. Access to contracts, cost breakdowns, and performance metrics - while respecting confidentiality - is essential for maintaining a fair, responsive, and evidence-based extended producer responsibility system.
2. We support improved cost transparency. The proposal to provide producers and RPRA with greater insight into system costs - particularly through more detailed invoicing - will enhance accountability and support better decision-making. This level of transparency is necessary for evaluating service value, comparing PRO offerings, and ultimately driving cost-efficiency across the system. We encourage the government to disclose how fees are calculated and how they contribute to measurable environmental outcomes.
3. Finally, 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.

We thank you for bringing these amendments forward, which respond directly to many of our concerns. We support the direction of these changes as they will strengthen program integrity, help producers meet their obligations with greater clarity, and promote a more efficient and accountable recycling system in Ontario. We 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