The proposed amendments are…

The proposed amendments are concerning as they will result in a significant regression for recycling in Ontario.

Delaying recovery targets for materials will not only result in poorer environmental and economic outcomes but will increase pressure on rapidly dwindling landfill capacity in Ontario. The proposal to delay recovery targets by 5 years reduces the incentive for producers of Blue Box materials to invest in new facilities/technologies, resulting in lost economic opportunities for Ontario.

Removing the planned expansion of producer-funded recycling services to multi-residential buildings, schools and specified long-term care and retirement homes would create inequities. All buildings must have access to a program that is provided by producers to all other residents in the province. In Toronto alone, this proposal will result in barriers to having residents living in approximately 300,000 multi-residential units in the city participating in recycling programs (the number of multi-residential units is projected to increase by tens of thousands of units each year). Why should certain residents living in multi-residential buildings have to pay for recycling services when most residents will have access to producer-funded recycling services?

I also oppose the proposed amendments to remove the requirement for producers to start collecting recycling from public spaces, including “away from home” beverage containers, starting in 2026. This proposed change, coming 6 months prior to the original implementation date, is unfair to municipalities that have been preparing, both operationally and financially, for this change over the last several years. Many recyclable products and packaging are disposed of in public spaces, and producers should bear the responsibility of collecting and processing these materials, ensuring they are diverted from disposal.

The proposed amendment to allow for energy recovery to count toward recovery targets is also deeply concerning. The intent of the Blue Box regulation and the move to Extended Producer Responsibility (EPR) was to incentivize producers to innovate their packaging to maximize the materials available for recycling. Allowing producers to include materials sent to energy recovery in the targets would not support the transition to a circular economy as it allows producers the option to incinerate rather than innovate.

Producers of Blue Box materials have had since 2021 to prepare for the transition to full EPR and should have no excuses for not meeting their obligations, as outlined in the regulation. The proposed amendments will weaken the Blue Box regulation, ultimately resulting in more valuable materials ending up in landfill. This waste of resources, the environmental impacts of mining and producing new materials, and climate change impacts must be avoided at all costs.