To: Ministry of the…

To: Ministry of the Environment, Conservation and Parks
Re: Amendments to the Blue Box Regulation (O. Reg. 391/21)

I am writing to express my strong opposition to the proposed amendments to Ontario’s Blue Box Regulation under the Resource Recovery and Circular Economy Act, 2016. These changes, if implemented, risk undermining the environmental integrity and effectiveness of Ontario’s recycling system.

My concerns are outlined below:

1. Weakening of Recovery Targets and Delays in Enforcement

The proposal to delay the enforcement of recovery targets for key materials (paper, metal, glass, rigid plastic, and beverage containers) by five years—from 2026 to 2031—represents a significant step backward for waste diversion in Ontario. This postponement reduces the urgency for producers to invest in recycling infrastructure and innovation, thereby threatening progress on waste reduction and circular economy goals. The reduction of the flexible plastics recovery target from 25% to a mere 5% further erodes environmental standards.

2. Permitting Incineration to Count Toward Recycling Targets

Allowing up to 15% of producers’ recovery targets to be met through the incineration of non-recyclable materials (energy recovery) is deeply concerning. Incineration produces harmful emissions that can negatively impact air quality and public health, contradicting the principles of a circular economy and undermining genuine recycling efforts. This change incentivizes burning waste rather than reducing, reusing, or recycling it.

3. Cancellation of Collection Expansion to Vulnerable and Underserved Communities

The removal of planned expansions for blue box collection in multi-residential buildings, schools, long-term care homes, and retirement homes will leave many Ontarians—especially those living in apartments and vulnerable populations—without equitable access to recycling services. This measure risks increasing landfill waste, litter, and environmental inequities, as these groups are often already underserved by current waste management systems.

4. Undermining Extended Producer Responsibility (EPR) Principles

The proposed amendments shift the focus away from holding producers fully accountable for the lifecycle of their products and packaging. By weakening obligations and delaying targets, the government is responding disproportionately to industry cost concerns at the expense of environmental protection and public interest. As noted by environmental advocates, this move risks shifting costs back onto taxpayers, increasing pollution, and harming human health.

5. Negative Precedent and Loss of Public Confidence

Ontario’s Blue Box program has long been recognized as a model for producer responsibility and recycling innovation. These amendments risk setting a negative precedent, signaling to industry that environmental standards are negotiable and undermining public confidence in the province’s commitment to sustainability and waste reduction.

Recommendations
• Maintain and enforce the original recovery targets and timelines to ensure continued progress toward waste diversion and circular economy objectives.
• Reject the proposal to count incineration toward recycling targets, and instead prioritize investments in genuine recycling and waste reduction solutions.
• Retain the planned expansion of collection services to ensure equitable access for all Ontarians, including those in multi-residential buildings, schools, and care facilities.
• Strengthen, rather than weaken, extended producer responsibility to ensure that those who profit from packaging and single-use items bear the full cost and responsibility for their end-of-life management.

Ontario must not compromise the environmental and public health gains achieved through the Blue Box program. I urge the Ministry to reconsider these amendments and prioritize a robust, equitable, and environmentally responsible recycling system.