These are the following five…

These are the following five recommendations, further explained in the text, aim to achieve these goals:

1. Do not allow Producers any further delays to fulfill their responsibilities to meet targets.
2. Require Industry to adopt Deposit-Return Systems promptly, starting with a program for all containers.
3. Ensure that Producers provide prompt and efficient diversion services to the IC&I sector.
4. Do not allow Industry to incinerate its materials to meet its recovery targets or manage its waste.
5. Hold Producers responsible to quickly adopt sustainable products/packaging and Deposit-Return programs that benefit all participants.

Municipal taxpayers have subsidized Industry’s choice of packaging for decades. Municipal leaders had no ability to influence packaging changes, but recognized that the cycle of producing and destroying materials was a waste of resources. Municipal programs collected a wide range of “recyclable” materials with the hope of finding markets, which Industry promised were out there. Too often, no markets were found and collected “recyclables” were eventually disposed of.

Finally, in 2021, Extended Producer Responsibility (EPR) was approved to shift costs to divert materials from taxpayers to companies that make the products/packaging. Industry was given a 2-year transition period, with final implementation by December 31, 2025.

As this date nears, a concerted effort has been made by Industry lobbyists to encourage the province to provide a further 5-year delay for Producers to meet their responsibilities. Producers insist that it is too costly and challenging to recycle their products, due to a lack of technology and infrastructure.

Of course, Producers have long been aware of the costs and challenges to recycle their products. Yet, as long as municipal taxpayers were subsidizing their products, Producers made no effort to adopt sustainable changes.

IT IS NOT IN THE BEST INTEREST OF THE PUBLIC FOR THE PROVINCE TO ALLOW PRODUCERS ANY FURTHER DELAYS TO FULFIL THEIR RESPONSIBILITY TO MEET TARGETS.

Producers have had lots of time to be proactive to introduce eco-friendly products and adopt sustainable programs that focus on protecting resources, instead of destroying them.

Producers have the ability to quickly adopt Deposit-Return Systems (DRS), which are popular and successful in many jurisdictions. DRS are a WIN/WIN for everyone. Benefits include: return customers for retailers, convenient return options for consumers, less litter and reduced municipal clean-up costs because a reward is offered to return items, higher diversion rates, and cleaner materials for Industry to reuse/recycle.

DRS are most successful when convenience and high deposits are made a priority. DRS can offer cash back or instore credits, and can be applied to a variety of items, which can be returned at Reverse Vending Machines (RVM), depots, or store outlets.

DRS can easily be expanded in Ontario, can work alongside Blue Box programs, and can achieve diversion rates of over 90%, with far less contamination.

IT IS IN THE BEST INTERESTS OF EVERYONE THAT THE PROVINCE REQUIRE INDUSTRY TO ADOPT DRS PROMPTLY, BEGINNING WITH A PROGRAM FOR ALL CONTAINERS.

Industry has asked that the province remove its obligation to provide services to the IC&I sector (i.e. public places, businesses, schools, malls, care centres, etc.). Industry profits from selling products to the IC&I sector and most certainly should not be allowed to withdraw from its responsibility to provide efficient diversion services there.

In fact, EPR was introduced to “make Producers fully accountable and financially responsible to collect and recycle their materials, which consumers discard”. Therefore, it makes sense that Producers be required to provide convenient and efficient diversion programs to all sectors so consumers can discard of their products in a sustainable manner.

DRS are flexible enough that programs can be quickly introduced, allowing a wide range of materials to be diverted easily at work and at play - anytime, anywhere. Ensuring a fair financial reward for return items and convenient systems like RVM helps to increase participation rates, and reduce litter and contaminated waste problems.

There is NO reason to deny or delay diversion programs to the IC&I sector.

THE PROVINCE MUST ENSURE THAT INDUSTRY PROVIDE PROMPT AND EFFICIENT DRS TO THE IC&I SECTOR.

Industry has requested that the province give Producers authorization to incinerate their materials to meet recovery targets.

Incineration (aka ER, EFW, W2E, and similar technologies) has been strongly contested for decades. It cannot be denied that toxic pollutants, escaping into the air from these facilities, are a serious health concern, and that these toxins negatively impact the air, land and water.

Obviously, there are no resources more important than natural resources (i.e. air, land and water) that sustain life. But incineration also destroys valuable resources that Producers work hard to obtain to make their products. They use finances and energy to mine, ship, and manufacture products, before selling them to consumers. Sadly, too many of these products are single-use items, and are discarded after one use.

It is irresponsible for Producers to claim their products are recyclable, and then incinerate them. Destroying resources to produce energy is illogical. More energy is saved by not making poorly manufactured products in the first place. Producers have the ability to make durable, reusable products.

No proposal to burn waste materials is fitting. Ontario’s goal is to protect resources, not destroy them.

THE PROVINCE MUST NOT ALLOW INDUSTRY TO INCINERATE ITS MATERIALS TO MEET ITS RECOVERY TARGETS OR MANAGE ITS WASTE.

THE PROVINCE MUST HOLD PRODUCERS RESPONSIBLE TO QUICKLY ADOPT TRULY SUSTAINABLE PRODUCTS/PACKAGING AND DRS THAT PROVIDE BENEFITS TO ALL PARTICIPANTS.