On behalf of the Ontario…

On behalf of the Ontario Business Improvement Area Association (OBIAA), which represents over 300 Business Improvement Areas (BIAs) and thousands of small businesses across Ontario, we write to express concern about the impacts of Ontario Regulation 391/21 on commercial areas and small businesses, particularly as it pertains to recycling collection.

Small businesses are the backbone of Ontario’s economy and serve as vital anchors of our Main Streets and downtown communities. They play a critical role in fostering local employment, tourism, and cultural vibrancy. However, the current Blue Box Regulation, as it stands, poses serious logistical, environmental, and financial challenges for these businesses and their surrounding communities.

Specifically, we urge the Province to require producers and producer responsibility organizations, including Circular Materials, to permit the co-mingling of eligible (residential) and non-eligible (commercial and institutional) recyclable materials in collection systems where it is feasible and currently functioning successfully.

This single adjustment would:
• Maintain operational efficiency in waste collection systems already optimized for shared service delivery.
• Reduce financial pressures on small businesses, who may otherwise be required to contract private haulers or face significant cost increases.
• Prevent recyclable materials from being sent to landfill, preserving the environmental intent of the Blue Box program.
• Support municipalities, that have successfully managed integrated collection systems for years.

As we move toward the full transition of the Blue Box Program in 2026, this recommendation offers a practical and proven solution that balances the needs of small businesses, municipalities, and producers alike.

We respectfully request your support in ensuring the success and fairness of Ontario’s recycling system for all stakeholders. OBIAA would welcome the opportunity to meet with your office to further discuss this issue and explore workable solutions.

Thank you for your time and consideration.