The Peterborough Downtown…

The Peterborough Downtown Business Improvement Area (DBIA) welcomes the Ministry’s recognition of opportunities to improve
efficiency in blue box collection by better integrating small businesses, particularly those
located along existing residential collection routes. We strongly encourage the Province
the Resource Recovery and Circular Economy Act, 2016. to formally include these
small commercial establishments as eligible sources within the producer-led collection
system.
1. Support for Regulatory Change
The current exclusion of small businesses from the blue box regulation creates
inefficiencies and missed opportunities:
 Many small businesses generate recyclables similar in type and volume to
residential sources;
 These businesses are often located along existing residential routes and could
be easily and efficiently serviced by the same collection vehicles;
 Maintaining separate private and public systems for similar materials is
duplicative and increases overall system costs.
Amending the regulation to include these businesses would significantly improve
system efficiency, reduce emissions from redundant truck traffic, and enhance diversion
outcomes for the province.
2. Local Impacts and Missed Efficiencies
In Peterborough, many small businesses—such as street-level shops, clinics, and
cafes—are located within mixed-use neighbourhoods already serviced by the blue box
program. Under the current framework:
 These businesses or City is required to contract privately for recycling, despite
being directly accessible via PRO-led routes;
 This results in unnecessary costs for businesses or City and inefficiencies in the
system;
 It causes confusion and reduces participation in recycling when neighbouring
residents and businesses are subject to different rules.
3. Recommendation for Expanded Eligibility
The DBIA strongly recommends the Ministry consider:
 Amending the regulation to allow small businesses along residential routes to
be included as eligible sources;

 Ensuring funding responsibility remains with producers for all included
sources, to avoid shifting costs back to municipalities or small businesses.
4. Equity and Environmental Outcomes
Including small businesses aligns with the environmental intent of the Blue Box
Regulation and promotes fairness. Businesses that generate the same types of
packaging and printed paper as residents should be part of a unified, producer-funded
collection system. This change would:
 Simplify participation for small businesses;
 Maximize recovery rates across sectors;
 Reduce burden on municipalities and local taxpayers.
Conclusion
The DBIA urges the Province to make this regulatory change a priority.
Expanding eligible sources to include small businesses is a practical, low-barrier
opportunity to advance waste diversion, create efficiencies, and support local economic
resilience. We are prepared to work with the Ministry and PROs to help shape
implementation and ensure a smooth transition.

Thank you,
Nour Mazloum