The Ontario government recently proposed amendments to the province’s Blue Box Regulation, triggering swift reactions from stakeholders. As the environmental voice of Canada’s paper packaging industry, the Paper and Paperboard Packaging Environmental Council (PPEC) believes it’s important to move beyond reactionary narratives and look at the facts. Instead of pointing fingers or pitting stakeholders against one another, PPEC’s latest blog aims to provide context to help inform a more productive conversation.
What’s Being Proposed?
The Ontario government proposed amendments to the Blue Box Regulation and the Resource Recovery and Circular Economy Act. At a high level, some of the objectives of the changes are to improve data collection, delay recovery targets, and focus the collection of Blue Box materials from residential sources by removing planned expansions to long-term care and retirement homes, schools, and public spaces.
What Were the Reactions?
In their blog, Trashing Ontario’s Blue Box Regulations Will Reverse Progress on Waste Reduction, Environmental Defence, a Canadian environmental advocacy organization, said the proposal would set back progress and lead to more litter:
“The government’s proposal to gut the Ontario Blue Box regulations trashes more than a decade of progress toward effective waste reduction policy. If adopted, it would lead to more plastic burning and more litter, while further straining Ontario landfills. The government is betraying Ontarians by seeking to reverse requirements that would have reduced single-use and unrecyclable plastics and to delay enforcement of these—now weakened—rules for another five years, to 2031.“
An article by CHCH News, Changes to Ontario’s Blue Box Program spark air quality concerns, is a result of the government’s proposal to permit energy from waste (the process of incinerating waste to produce energy) as an allowable form of waste diversion.
And Duncan Bury, a consultant who spent his career working on municipal and federal waste management policy, called the proposal “a significant step backwards,” in the Toronto Star’s article, Ontario proposing to loosen blue box regulations, citing costs on producers
PPEC Perspective
Ontario’s move to full producer responsibility for the Blue Box program is a complex transition involving many players across the recycling value chain, not just producers.
In this section, we address some of the claims made in response to the government’s proposal, provide data, discuss the realities of litter, the importance of informed targets, ask questions about energy from waste, and overall, emphasize the importance of shared responsibility among producers, consumers, and all players in the system.
“A Decade of Progress”?
Environmental Defence claims Ontario’s proposed amendments will hurt over a decade of progress. PPEC analyzed ten years of publicly available data from the Resource Productivity & Recovery Authority’s (RPRA) Datacall. While some data gaps exist for 2022 and 2023 due to Ontario’s transition to the new producer responsibility model, the available data tells a different story.
Ontario’s residential waste diversion rate (the proportion of residential waste diverted from landfill), as represented in the broken black line in the chart below, has remained relatively flat, hovering around 50% for much of the last decade. This suggests the system has been stagnating, rather than improving year over year.
And when it comes to marketed Blue Box tonnes – materials that are actually sold for recycling to be used in place of virgin materials – these numbers have been declining. While paper-based materials, particularly corrugated and boxboard, remain the most successfully marketed materials thanks to strong infrastructure and end markets, the composition of the paper category has changed significantly, with less printed paper (such as newspapers and magazines).
The data shows a Blue Box system that has plateaued and highlights the need for improvement, which we hope the new model will achieve. But achieving progress requires recognition of the full recycling value chain, having infrastructure that supports efficient and effective collection and processing, stable end markets, residents doing their part to properly sort and prepare their recyclables, as well as the time to allow the new model to take hold.
Public Space Littering Is a Consumer Behaviour Issue
The suggestion that changes to Ontario’s Blue Box regulation will lead to more litter draws a false connection. Litter is not a producer responsibility issue. It is a consumer behaviour issue.
Waste diversion is a shared responsibility. We all have a role to play in managing waste and ensuring it is properly disposed of. Linking Blue Box regulation amendments with increased litter reflects a misunderstanding of what producer responsibility is meant to address.
Producer responsibility should not be seen as a catch-all solution for every waste challenge, especially given the complexity of the broader waste and recycling system, of which littering is just one example. Solutions to litter require public action to not litter in the first place.
Targets
Some have argued that without targets, there will be no incentive for producers to make progress under Ontario’s new Blue Box system. But targets or no targets, producers are already deeply invested — financially, operationally, and reputationally — in making this transition work.
Yes, targets are important. But they also need to be realistic, and right now, that’s part of the problem. The original targets were set without a solid data foundation — not grounded in current data or recycling realities. Delaying them by five years doesn’t fix that, but it does create the opportunity to collect better data to make more informed decisions.
Energy From Waste
We understand that energy-from-waste (EFW) is a controversial topic and while PPEC is not taking a position, we want to reiterate that what matters to our sector is recycling. Paper packaging is a recycling success story in Ontario, with high recovery rates and a well-established system, which our members rely on for clean, high-quality recycled fibre to use as their primary feedstock.
If EFW were to be introduced, the government must ensure it doesn’t create an unlevel playing field. For materials that don’t have strong recycling systems in place, EFW could be seen as a shortcut, and that could be unfair to industries that have invested to build effective recycling infrastructure.
We also have some questions. Where did the 15% figure come from? Was it based on a jurisdictional scan of systems with strong air quality standards, strict emissions limits, and advanced pollution controls? We don’t have the answers, but these are the kinds of details that matter when assessing whether EFW should play a role in Ontario’s waste management strategy.
We’re not weighing in on whether EFW should be allowed, but would caution against allowing it to undermine progress in recycling.
Conclusion
We support the government’s intent to strengthen Ontario’s producer responsibility framework. As end markets and recyclers of residential and commercial paper packaging, our members rely on a recycling system that is effective and sustainable.
At its core, producer responsibility is a policy that holds producers accountable for the end-of-life management of their packaging. But when you get into the realities of how recycling systems function, it becomes clear that success depends on coordination across the entire recycling value chain.
While producer responsibility places regulatory responsibility on producers, system effectiveness relies on everyone doing their part: consumers sorting properly, haulers collecting materials, sorting and processing facilities preparing materials for sale, end-markets that buy back those materials, and governments creating the regulatory conditions needed for success.
Ontario’s current Blue Box regulation has faced some concerns for being overly complex and difficult to implement. The government’s proposed amendments reflect real-world feedback from the obligated parties and show that policymakers are willing to adapt.
We recognize that some of the responses to the proposed amendments reflect genuine concern. But we caution against reactive or overly simplified narratives that risk distorting understanding. Producer responsibility is complex and was never intended to solve every waste challenge. Ontario needs evidence-based policy, not finger-pointing, to build a recycling system that works better.
As Calvin Lakhan wrote in The Structural Failure of Extended Producer Responsibility: What Ontario’s Recycling Crisis Teaches Us About Policy Design:
“Ontario’s EPR crisis isn’t just a speed bump—it’s a red flag. The policy failed not because producers are unwilling to act, but because the framework asked them to do the wrong things. It locked them into outdated recycling systems, imposed unrealistic cost burdens, and penalized innovation in the name of compliance…. If we want to make EPR work, we need to realign it with how the world actually operates—not how we wish it did.“
Ontario now has an opportunity to strengthen its residential recycling system, but doing so requires informed and data-based decision making and collaboration across the entire recycling value chain. While the consultation period has ended, no government decisions have yet been announced, and the Blue Box transition continues. We will be watching closely and we encourage all stakeholders to stay engaged and keep recycling.
