Executive Summary – Proposed…

Executive Summary – Proposed Amendments

Several of the Proposed Amendments will have strong negative impacts on Ontario’s environment, ability to meet zero-waste goals, reduce greenhouse gases (GHGs), strengthen multiple segments of Ontario’s e-waste management industry, and to provide equitable access to affordable or free technology by economically marginalized individuals, non-profits, and small and medium sized businesses that cannot afford new technology. The amendments of concern are: (1) the recycling efficiency rate (RER) requirements (2) removal of the 2x multiplier for e-waste diversion via reuse, (3) removal waste reduction incentives, and (4) extension of management targets (push back). Below, and in the provided attachment, we analyze these proposed changes and provide alternative recommendations with rationale.

Summary Recommendations

1. Removal of the RER with full implementation of a rigorous Recovery Rate metric as the primary performance measure of system wide recycling efficiency. The Reuse multiplier is partly driven by the inverse of the Recovery Rate metric (last reported as 61.1% in 2022), while the Reuse multiplier can be more accurately derived from other metrics that provide rigorous assessment of recycling efficiency (without heroic assumptions) relative to amounts collected, any of these figures and their supporting data are essential to track in order to evaluate program benefits - we acknowledge that as the Recovery Rate or RER-like figures improve there is downward pressure on the Reuse multiplier.

2. A 2.5x Multiplier for Reuse given the incomplete effectiveness of recycling in terms of landfill
diversion, and given the substantial effluent, GHGs and solid-waste generated in the production of existing and new ITT devices.

3. Continuation of the ability of Producers to trade reduction results against diversion obligations.

4. Accelerate rather than maintain diversion targets.