CUPE believes private…

CUPE believes private producers should be responsible for reducing their environmental impact, but we have serious concerns with the proposed extended producer responsibility model (EPR). In summary, our key concerns are the deterioration of public accountability and oversight of Ontario’s recycling systems, the potential negative impact on employment in recycling collection and processing, and the many gaps in regulation that will undermine environmental targets in this new model.

As we have seen in British Columbia among other places, the risk is that instead of streamlining the blue box system in a way that improves services, we will wind up with a programme that is a patchwork of various individual agreements among municipalities and a variety of different producers. This will result in inconsistent delivery across the province. Municipalities will be the ones receiving complaints from dissatisfied residents, but they will have no ability to do anything to correct the problems.

This greatly risks undermining public confidence in our recycling systems. The overall shift of remaining public operations to the private sector will also likely have a negative impact on employment and will result in unexpected costs and service conflicts for municipalities — those who are the best at collection, processing, administration and diversion.

Furthermore, it is assumed producers will improve the overall environmental impact of the goods they sell, but nothing in this regulation compels them to do so. The government’s desire to hold producers accountable for their waste is commendable, but many gaps in the regulation must be addressed if we are to ensure our recycling systems operate for the public good.