We urge the province to…

ERO number

025-0009

Comment ID

150805

Commenting on behalf of

Environmental Defence Canada + 10 other environmental groups

Comment status

Comment approved More about comment statuses

Comment

We urge the province to ABANDON PROPOSED AMENDMENTS to:

- Delay recovery targets for paper, metal, glass, rigid plastic, and beverage containers by 5 years. If a delay due to supply chain disruptions resulting from the trade war with the U.S. are warranted, the timeline must be tighter. These targets should be enforced within 2 years (2028).

- Reduce the target for flexible packaging to 5 per cent from 25 per cent. This change effectively acknowledges that flexible packaging cannot be recycled or reused. We therefore need a transition away from flexible packaging for virtually all purposes, not a relief of regulation that will allow this wasteful material to continue to grow largely unimpeded.

- Allow “energy-recovery” to count towards diversion. This would represent a reversal of circular economy principles, which identify the burning of materials as unacceptable, and incentivize an increase in disposable packaging and a decrease in investments for collection, sorting, and recycling or reuse. Further, burning more packaging waste would lead to health and environmental harms in Ontario.

- Remove “away from home” collection of beverage containers. This proposal is an acknowledgement that the Province has failed to work with beverage producers and other stakeholders to implement deposit return, an effective program that all other provincial jurisdictions in Canada enjoy, save Manitoba. As a result, we estimate nearly 2 billion plastic beverage containers each year, and even more aluminum cans will continue to end up in landfills, incinerators or the natural environment as litter. This move would keep Ontario in last place when it comes to management of beverage containers.

- Remove the planned expansion for public space collection. We cannot fathom any reasonable justification for this change. Packaging put on the market by producers is a highly littered material. Why should municipalities—and the property tax base—continue to be on the hook for producers’ harmful packaging choices?

- Remove planned expansion for multi-residential buildings, schools and specified long-term care homes and retirement homes. This change would further undermine the principle of extended producer responsibility. Already, under the existing regulation, producers are only responsible for less than half of the material they put on the market. Together with the changes noted above for beverage containers consumed away from home and public space collection, producers would be responsible for much less of their wasteful material. Further, this proposed change is deeply unfair to residents of multi-residential buildings—including apartment and condominium buildings and retirement and long-term care homes. These residents would be forced to continue to cover the costs of packaging waste collection through their rents or fees, even as all other residents in the province get producer-paid collection.