We understand the importance…

We understand the importance of protecting the environment and reducing waste. We believe that building a circular economy will be key to our economic ambitions and supply chain resilience as we embark on the most comprehensive rebuild of our manufacturing sector since the Second World War.

However, we are concerned about the implementation of deductions for specific sectors so close to the implementation of the new regulatory framework. Such deductions will ultimately shift the cost to a smaller pool of producers, inadvertently affecting essential consumer goods during high inflationary realities. To avoid unintended consequences, we recommend that the Ministry re-iterate the principle of individual producer responsibility by explicitly prohibiting cross-subsidization between producers or various Blue Box materials. This will ensure a level playing field and fairness during the program implementation and compliance enforcement.

More fundamentally, our members are concerned about the escalation of the program costs borne by industry, which has never been properly assessed by the Government of Ontario (including in its regulatory assessment for the current consultation). Compared to 2019, when industry paid 50% of $135M, a study conducted by Deloitte estimated those costs will balloon to $650M in 2026 (a 500% increase). Ontario brand owners, manufacturers and other producers will now shoulder 100% of program costs under the next framework, significantly impacting competitiveness.

There are potential remedies that could temporarily alleviate the burden on manufacturers and, therefore, on Ontarians. We recommend examining the opportunity to defer Blue Box's expansion to multi-residential buildings or public space collections.

Further, government should address the built-in inefficiencies within the existing regulatory framework. We urge the Ontario government to align Printed Paper and Packaging EPR closer with other provincial frameworks to support nationwide EPR compliance and stability and certainty of Ontario EPR.