Pollution Probe is pleased…

Pollution Probe is pleased to provide the attached submission for consideration by the Ontario Ministry of the Environment, Conservation and Parks regarding the proposed regulation under the Resource Recovery and Circular Economy Act, 2016 to make producers responsible for blue box programs, and amendments to Regulation 101/94: Recycling and Composting of Municipal Waste to sunset municipal obligations to run blue box systems after transition to full producer responsibility.

A summary of key points are as follows:

• Where properly developed and implemented, a regulation such as that proposed, has the potential
to contribute to significant benefits for Ontario.
• A focus on continuous improvement and revisiting elements of the regulation over time would
ensure it continues to meet its intended objectives and can adapt to new information and
innovation.

1. Need for Increased Transparency and Accountability
• Promoting transparency on targets, actions and progress should be a key objective. Public
engagement and participation in blue box programs is highly dependent on a clear understanding
of efforts being made to ensure that what ends up in their bin is in fact, being diverted from
landfill.
• While an EPR model encourages producers to find new and innovative ways to reduce costs and
improve the environmental management of recyclable materials, there is currently limited publicly-
available data or messaging around the potential economic impacts and concerns related to the
extent to which the cost to operate the blue box program will be passed on or borne by
consumers. Greater transparency around the true impacts of the proposed regulation and a
transition to full EPR for all Ontarians will contribute to greater understanding and support for blue
box programs.
• The proposed regulation for blue box programs provides an important opportunity to help fill
critical data gaps related to recovery and diversion for the industrial, commercial and institutional
(IC&I) sectors being considered for inclusion.

2. Diversion Targets and a Need for Continuous Improvement
• Ambitious diversion targets can play a role in encouraging innovation and opportunities to reduce
those materials that are not easily recycled or that are without strong end markets.
• Diversion targets should continue to exceed current performance and increase over time to
facilitate continuous improvement.
• Limiting reporting and targets to broad material categories reduces the visibility of poor
performing materials. Efforts should be made to ensure that problematic materials are not
overlooked in efforts to improve diversion rates.

3. Ensuring a Holistic Approach to Waste Management
• It will be important to ensure that the broadening of the scope for blue box programs is done from
the perspective of recycling as one element of a more holistic approach to waste management that
also includes support for solutions that prioritize reduction and reuse.

About Pollution Probe
Pollution Probe is a national, not-for-profit, charitable organization that works to improve the health and well-being of Canadians by advancing policy and delivering programs that achieve positive, tangible environmental change. Pollution Probe has a proven track record of working in successful partnership with industry and government to develop practical solutions for shared environmental challenges.