PPEC has two major concerns…

PPEC has two major concerns with the draft regulations.

(1) The waste diversion targets. There are too many unknowns about how the waste diversion targets have been derived; there are missing numbers on what and how much new material the province wants to add; and some materials have little room to grow (corrugated boxes, for example, are already at 98% recycling). Paper generation is levelling off making the most likely scenario one where the paper group as a whole will only achieve about 65% diversion by 2030, nowhere near the 90% target.

(2) While the proposed recycled content credit does have some benefits, it is administratively challenging at best, impossible at worst. Complete accuracy is not achievable and the current proposal leaves itself open to fraud and gaming of the system. PPEC proposes instead a tax credit or rebate that focusses on supporting Ontario recycling businesses, that creates Ontario green jobs, that rewards those who use Ontario Blue Box material as feedstock, and that enhances Ontario’s circular economy.

PPEC has attached a link to a submission document with more details.