Submission to the Ontario…

Submission to the Ontario Ministry of the Environment, Conservation and Parks Re: Proposed Amendments to the Blue Box Regulation

We are writing to express our strong objections to the proposed amendments to Ontario’s Blue Box Regulation under the Resource Recovery and Circular Economy Act, 2016.

The proposed changes—including delaying mandatory recovery targets by five years, removing planned expansions of service to multi-residential buildings, schools, and long-term care homes, and allowing energy recovery (incineration) to count toward diversion targets—represent a significant step backward for waste reduction and recycling in Ontario.

1. Delaying and Reducing Recovery Targets Weakens Environmental Progress

By postponing the enforcement of recovery targets for paper, rigid plastic, glass, metal, and beverage containers until 2031, and reducing the target for flexible plastics from 25% to just 5%, the government is giving producers a pass on urgent action to improve recycling rates. The current “best efforts” approach has already proven insufficient, and further delays will only entrench low diversion rates for years to come. Ontario needs to accelerate, not slow, progress toward a circular economy.

2. Eliminating Service Expansion Undermines Equity and Accessibility

The proposed removal of requirements to expand blue box collection to more multi-residential buildings, schools, and long-term care homes will leave many Ontarians without access to convenient recycling services. This decision disproportionately affects vulnerable populations, including seniors and low-income families, who are more likely to live in multi-residential settings. It also undermines the principle of producer responsibility, as it allows producers to avoid collecting waste from all the communities they serve.

3. Allowing Incineration to Count Toward Diversion Targets Is Counterproductive

Permitting non-recyclable materials sent to incineration for energy recovery to count toward up to 15% of producers’ diversion targets is not in line with the intent of a circular economy. Burning materials for energy is not recycling and should not be equated with true material recovery. This change will discourage investment in genuine recycling infrastructure and innovation.

4. The Need for Stronger, Not Weaker, Producer Responsibility

The original intent of the Blue Box Regulation was to shift the financial and operational burden of waste management from municipalities and taxpayers to the producers who create packaging waste. Rolling back these requirements sends the wrong signal and risks reversing more than a decade of progress on waste reduction. Instead of weakening regulations, the government should focus on supporting producers in meeting ambitious targets, improving transparency, and fostering innovation in recycling technologies.

Conclusion

We urge the Ministry to reconsider these proposed amendments and instead strengthen the Blue Box Regulation by maintaining and enforcing robust recovery targets, expanding services to all Ontarians, and ensuring that only true recycling counts toward diversion goals. The circular economy cannot be achieved by lowering standards and shifting costs back onto municipalities and the public.

Thank you for considering our submission.