December 3, 2020 Jamelia…

December 3, 2020

Jamelia Alleyne
Resource Recovery Policy Branch
40 St. Clair Avenue West, 8th floor
Toronto, ON, M4V 1M2
Submitted online through: https://ero.ontario.ca/comment/reply/node/5458/comment

Re: Comments on A proposed regulation, and proposed regulatory amendments, to make producers responsible for operating blue box programs

Thank you for the opportunity to provide our comments regarding the proposed regulation and regulatory amendments to make producers responsible for operating blue box programs in Ontario, as part of the Made-in-Ontario Environment Plan. We were very pleased to hear Minister Yurek confirm on a number of occasions that coffee pods will be included in the expanded list of products for blue box acceptance.

At Mother Parkers Tea & Coffee, we support the province’s commitment to “improve recycling across the province and address the serious problem of plastic pollution.” We are proud to contribute to those goals through our newly redesigned, recyclable polypropylene EcoCup® coffee pod. We’re also proud of our contribution to Ontario’s economic recovery and job creation by providing over 650 jobs in Mississauga and Ajax.

Mother Parkers agrees that Ontario needs to reduce the amount of waste we generate and divert more waste from landfill through proven methods like Ontario’s curbside Blue Box Program, existing and emerging municipal Green Bin programs and other waste recovery options. We strongly believe that when it comes to innovation for reducing packaging and food waste, there is room for more than one solution.

Designating materials:
Mother Parkers Tea & Coffee manufactures the EcoCup® capsule – a recyclable polypropylene coffee pod that allows the consumer to easily separate and sort the components that are clean, therefore helping to ensure higher recyclability rates. The organic coffee grinds or tea leaves can be easily composted and both the outer plastic cup and inner filter liner are made of #5 plastic that can be included in the Ontario Blue Box following a quick rinse by the consumer. In our experience, Ontario consumers are more than willing to properly divert single-serve coffee pods from landfill when manufacturers make it easy for them to do so. Our new EcoCup® pods continue to be manufactured in our GTA facility, primarily for national private label brands, as well as for our own brands including Marley Coffee®.

We are committed to continuing our work with municipalities, industry and government to find new and better ways to encourage consumers to recycle our products. Allowing our EcoCup® pod into the recycling stream through the Ontario Blue Box program will see more materials recycled back into the economy rather than landfill. In working with Material Recycling Facilities (MRFs) and City of Toronto staff to understand concerns about coffee pods, we heard that the level of contamination and the need for clean materials is the primary concern. Our EcoCup® solution is easy to separate leaving a clean, empty cup and filter made of polypropylene that is desired by recyclers. The addition of our recyclable coffee pods into the Blue Box Program will immediately reduce the amount of waste going to landfills or becoming litter and also increase opportunities for Ontarians to participate in efforts to reduce waste right in their home and/or workplace.

About EcoCup® Pods:
EcoCup® hot beverage capsules fit the “reduce and recycle” thinking at the heart of the vision for a waste-free future for Ontario.
Reduce:
• EcoCup® pods use less material in the cup and lid and are available packaged in a unique, “nested” box that saves considerable packaging material. For example, in a 100-count package of coffee pods, Mother Parkers’ nested EcoCup® format uses 33% less corrugate than traditional packaging.
Recycle:
• 92% of the EcoCup® pod’s packaging can be placed in a blue box for recycling (where facilities exist).
• The EcoCup® packaging carton contains recycled materials and is FSC certified.

Economic Impact:
Mother Parkers makes investments in numerous GTA businesses and suppliers to improve our facilities. Investments have been made in energy-efficient improvements in our plants, including HVAC, roaster upgrades, LED retrofitting and many pandemic prevention initiatives.

Clean polypropylene requires a cost to process in a MRF, however it is a desirable plastic for recyclers and provides revenue potential upon sale. The addition of clean used coffee pods into the recycling stream offers not only environmental protection benefits but also economic opportunity.

Producer Responsibility and Collection:
Mother Parkers supports and accepts the responsibilities of producers to bear the costs of operating the blue box program. We believe the government’s vision for a waste-free Ontario leaves room for both compostable and recyclable solutions for waste diversion, and we would hope that government legislation will reflect an appropriate balance to ensure producer responsibility and cost is shared, regardless of the method of waste diversion. This is important to ensure continued innovation by all producers to find new and better product and packaging solutions that are practical for consumers and municipalities.

We welcome the proposal for a common collection system across the province of Ontario. This would be a significant benefit for recyclable products such as the EcoCup® coffee pod, not only in terms of greater waste diversion but also in providing for simpler, consistent packaging education for consumers on the steps to proper recycling. Under the current system, consumer education, advertising and communication is more challenging for producers and brand owners based on the many differences in blue box programs operated by municipalities.

We are also pleased that the proposed regulation would expand collection requirements to public and private schools, long-term care homes and retirement homes as these types of facilities represent growing customer categories for coffee and tea pods. Regulated collection requirements would make recyclable pods more attractive to these customers and would lead to greater diversion of waste from landfill.

Mother Parkers looks forward to working with the province to improve recycling and reduce plastic waste through the Ontario Blue Box program. As a proud GTA company, we are committed to driving innovation in sustainable products and processes.

Sincerely,

Fred Schaffer
President & CEO
Mother Parkers Tea and Coffee
2531 Stanfield Road
Mississauga, ON L4Y 1S4
(905) 273-2300