Blue Box Regulation Amendment: CIC's Position

For over 40 years, as the Recycling Council of Ontario (RCO), [now Circular Innovation Council (CIC)], our organization has been a leader in advancing effective waste reduction policies and programs across Ontario and beyond. In fact, it was RCO [now CIC] that the Province of Ontario first commissioned to facilitate the pioneering partnership between producers and municipalities—an initiative that led to the creation of the now world-renowned Blue Box program.
Jo-Anne St. Godard, Executive Director

Blue Box Regulation Amendment

The Government of Ontario has proposed to amend the Blue Box Regulation under the Resource Recovery and Circular Economy Act, 2016

These amendments represent a significant step backward from the government’s commitments to achieving zero waste.

Strengthening Producer Responsibility

Effective policies like Extended Producer Responsibility (EPR) are vital tools to redesign markets and reassign end-of-life management of products and packaging to producers and first sellers. We have been at the forefront of advocating for and implementing EPR as a critical policy intervention for Ontario’s transition to a circular economy.

Ontario’s Blue Box program has been a cornerstone of the province’s waste management and recycling efforts. Maintaining its current trajectory and fostering further innovation are vital for Ontario’s environmental and economic future. The Blue Box program not only helps reduce waste and environmental impact but also creates opportunities for innovation in recycling technologies and sustainable materials management. These initiatives can generate new economic opportunities, support green jobs, and demonstrate Ontario’s commitment to environmental leadership. Undermining or significantly altering the Blue Box program at this critical juncture would jeopardize these benefits and impede our progress toward a broader circular economy.

Local governments and producers have collaborated for over a decade to transition to full producer responsibility. This regressive step is unfair to all stakeholders, particularly Ontario municipalities and the materials management industry, which have been managing the finances and making investments to prepare for this transition. Almost all other Provinces have been able to maintain and or increase their collection and recycling targets under the same conditions (high inflation, labour shortages and supply chain bottlenecks for infrastructure) as Ontario.

Summary of CIC Recommendations

Proposed Amendment – Recommendation

  1. Delay Recovery Targets for selected material categories by five years to 2031 – CIC does not support this amendment. The prescribed recovery targets and timelines to achieve them for Selected Material Categories as they are currently stated in the Regulation should be maintained and enforced. 
     
  2. Reduce flexible plastic target to 5% and delay enforcement until 2031 – CIC does not support this amendment. Flexible plastics have had chronically low collection and recycling performance in Ontario, yet they continue to proliferate in the marketplace. Maintaining a target of 25% diversion will ensure efforts and investments are focused to support improvement. 
     
  3. Remove planned expansion for multi-residential buildings schools and specified long term care homes and retirement homes – CIC does not support this amendment. Maintain the scheduled onboarding of multi-residential buildings, and long-term care and retirement homes and schools. 
     
  4. Remove the requirement to collect non-alcohol beverage containers from ‘away from home’ sector – CIC does not support this amendment. Recommend re-establishing the beverage container deposit return working group to continue and deliver a plan to expand and improve non-alcohol beverage container collection and recycling that matches or exceeds the performance in other Provinces.
     
  5. Allow deductions for beverage containers – CIC does not support this amendment. More clarity is needed to understand where outside of the blue box non-alcohol beverage containers are being collected as the proposal suggests and how collection is verified to facilitate a fair and transparent deduction. 
     
  6. Remove expansion of public space collection – CIC does not support this amendment. Continue the service expansion of public space collection. 
     
  7. Allow energy recovery to count toward diversion – CIC does not support this amendment. The objective of the Regulation is to optimize value from collected materials and to make them available to be re-integrated back into manufacturing of new PPP and products. 
     
  8. Consider the best way to ensure collected materials are sent for processing – CIC supports this amendment. Registering collection and processing service providers and directing all collected materials through them supports transparency and promotes fairness. Accuracy of performance is critical for assessing the efficacy of the policy including target setting. It is also critical to ensure fairness between Producers and their Pros that all obligated parties are meeting their obligations.
     
  9. Allowing collection from SMEs – CIC supports this amendment

Read CIC’s full response to understand the full depth of our rationale and recommendations for each discussed amendment.

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