December 3, 2020 Jamelia…

December 3, 2020
Jamelia Alleyne
Resource Recovery Policy Branch
40 St. Clair Avenue West
8th floor
Toronto, ON
M4V 1M2
Canada

Dear Ms. Alleyne,
Thank you for the opportunity to provide feedback to the Ministry of Environment regarding Blue Box regulation. As you may know, Waste Management is the largest provider of residential recycling collection in North America and one of the largest recycling processors in North America.
Waste Management has been involved in multiple transitions to Extended Producer Responsibility throughout many jurisdictions. Our experience has shown it is imperative that strict legislation is in place to prohibit the same company to be both the recycling collector and the recycling processor of the same material. (ie Company A collects and processes a Municipality’s volume). Allowing the same company to do both the collection and recycling of the same volume enables the company to have an unfair advantage in the marketplace in terms of access to scales; front of the line dumping access; contamination thresholds; operating hours etc. Ensuring that the collector and the processor are a different entity promotes healthy marketplace competition which is critical to the long-term success of EPR.
If you have any questions or concerns, please feel free to contact me at 416-702-9458 or nwillett@wm.com.

Thank you,
Nicole Willett