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Little Green Lies: Q&A with Author John Mullinder

The Paper and Paperboard Packaging Environmental Council (PPEC) sat down with its former and long-standing Executive Director, John Mullinder, who helped formed PPEC in 1990, and retired in February 2021.

Photo of John Mullinder

John recently published his new book, Little Green Lies and Other BS, which focuses on environmental claims and advertising; it is a follow up to his first book, Deforestation in Canada and Other Fake News, published in 2018.

Little Green Lies Book Cover

Little Green Lies is well researched and organized, covering about 40 different subjects in alphabetical order from “Ancient” Forests to “Zero” Waste.

PPEC chatted with John about his new book, and excerpts from our conversation follow, edited for length.

Hi John! Can you please give our readers a brief description of your new book and why you wrote it?

One of my reviewers described it as “an entertaining and informative dictionary of environmental buzzwords (and claims) that are widely used (or made) but often poorly understood.” The book examines those buzzwords, what they mean and whether the current use of these terms is accurate, misleading, confusing, deceptive or just plain wrong, and includes 38 pages of sources for the information (that’s the dictionary part).

I wrote it because there is so much misinformation, and sometimes deliberate greenwash, about these buzzwords and claims, and I want to set the record straight.

What can readers hope to learn from this book?

Not to accept all environmental claims as apple pie. To question the use of particular buzzwords. To understand and analyse the context in which claims are made, whether they are made by businesses, governments, or environmental groups. And to avoid making those same claims themselves.

The book doubles as an educational tool for staff, customers, journalists, policy advisers.

Or as one of my reviewers wrote: “This is a great reference book that will help you sort the facts from the fiction. If you’re a writer, editor, public relations professional, legislator, educator, work for an NGO, or are simply a consumer who wants to know the truth, this book should be on your shelf or Kindle list.”

What can people expect to learn from reading Little Green Lies (image)

How does this book differ from your first book, Deforestation in Canada and Other Fake News?

The focus of “Deforestation in Canada and Other Fake News” was to debunk two commonly-held myths: that Canada is running out of trees, and that massive deforestation is taking place in our own backyard. Both not true.

While “Little Green Lies” does cover these issues as well, it is far broader, examining a wide range of forestry and paper issues, packaging, recycling, and waste. It is also more international, incorporating as much global and US data and perspectives as possible, not just Canadian data.

There are a lot of misconceptions when it comes to forestry – particularly related to deforestation and “ancient” forests – where does the confusion come from, and how do we address it?

There is widespread confusion about each of these because people work to different definitions of them. And the media makes it worse by not explaining what the terms mean and/or misapplying the meaning of the words. We (and I mean collectively) need to develop broadly agreed-upon definitions that we can all work to, and to publicize them widely, especially to journalists. The United Nations, for example, has a very clear definition of deforestation.

UN definition of deforestation

With increased activity and attention on corporate greenwashing — the practice of making false or misleading environmental sustainability claims — and with the Competition Bureau of Canada archiving its Environmental Claims Guide, do you believe there are enough resources available to provide clarity on claims and misleading marketing practices?

Absolutely not. And even the advice that is out there (the archived guidelines you refer to) are inadequate. This is one of the reasons they were archived as a matter of fact. Greenwashing is a major issue and it needs sufficient resources allocated to it, urgently. Or nobody will believe anything. And that is a slippery slope.

PPEC has long called for disposal bans on paper-based packaging, considering such materials are recyclable and end markets exist; why do you think there is resistance to implementing such bans?

What really gets up my nose are provinces spouting off about how we should all move to a circular economy while they do little or nothing to change the economics that make it cheaper to send stuff to landfill rather than to recycle it.

The circular economy is all about reusing materials again and again, and the provinces have the power to do something about this. They need to demonstrate some political fortitude and be willing to take on the commercial interests of municipalities and waste haulers who happen to own landfills.

Ban old boxes from landfills, says paper industry

Do you have any comments on the state of Extended Producer Responsibility (EPR) policies and legislation in Canada as they relate to the paper-based packaging industry? And how does the consumer/resident – who ultimately decides how to dispose of their waste and recyclables – fit into the concept of EPR?

I think we have to be very careful in claiming EPR as the solution for materials ending up in landfill. Any costs that producers incur through EPR schemes will inevitably be passed on to consumers. What’s important for industry (including the paper industry) is that any fee structure be fair and evenly applied. Non-performers must be penalized for any scheme to work.

And a major education job is required to get the consumer in the loop. For example, about 40% of Ontario Blue Box recyclables go straight to the trash because householders are confused about whether certain materials are recyclable or not. Much (but not all) of this trashed material is perfectly recyclable.

Is there anything else you would like to share about your new book Little Green Lies?

I know this will sound a bit like a sales pitch (it is!), but I think the book provides a sound basis for critically examining many of the environmental claims we see and hear today (whether they are from industry, governments, or environmental groups). The sources for the information I provide are all there. Facts do matter. 

Government Amends Ontario Blue Box Regulation

The Government of Ontario made amendments to the Blue Box Regulation, which came into effect on April 14, 2022.

The amendments do not change the original intention of the regulation – to transition the existing Ontario Blue Box model from a shared funding model to a full producer responsibility model – and do not impact collection requirements, diversion outcomes, or key dates (transition will still begin July 1, 2023). The amendments were made to clarify the process for creating the province-wide system for collecting Blue Box materials. The key changes include:  

  • Removing the rule creation process, including the allocation table, from the regulation.
  • Allowing producer responsibility organizations PROs to collaborate on a province-wide collection system; and requiring PROs that represent producers that supply more than 66% of Blue Box tonnes to submit an operational plan to RPRA for how they will operate the system by July 1, 2022.
  • Exempting newspaper producers (whose supply accounts for at least 70% of their total Blue Box supply) from collection, management, and promotion and education requirements for two years; newspapers will remain an obligated material under the regulation, and will continue to be collected in the Blue Box system.

RPRA Webinar May 18 

The Resource Productivity and Recovery Authority (RPRA), which is the regulator mandated by the government to enforce the province’s circular economy laws, is hosting a virtual Q&A for stakeholders on May 18 at 11:00am EST to review the amendments; to register click here.

Newspaper Associations Support Newspaper Exemption

On the news of newspaper producers being exempted from the Ontario Blue Box amended regulations, both the Ontario Community Newspaper Association (OCNA), who represent provincial community newspapers, and News Media Canada, the voice of the print and digital media industry in Canada, expressed their support for the government’s decision.

Alicia McCutcheon, president of the OCNA said: “We do applaud the Ford government for doing this… We’ve never viewed ourselves as the same as the tin can or the plastic wrap people of the world, we’re not packaging,” according to the National Post’s Newspaper lobby group ‘applauds’ exemption from Ontario’s new recycling program.

And Paul Deegan, president of News Media Canada, issued a statement:

Canada’s newspaper publishers applaud the Ontario government’s leadership in recognizing that newspapers are not packaging and should be exempt from extended producer responsibility fees. We hope other provinces will follow Ontario’s lead in eliminating this punitive measure. The unintended consequence of EPR on newspapers is to reduce the number of pages in a newspaper or for the paper to simply close or go online only…. Newsprint has the highest level of collection of all recyclable materials, a stable end market, and high commercial value.” 

Newsprint and the Ontario Blue Box Program

Stewardship Ontario’s 2020 Annual Report states that: “Historically, newspapers have represented a large volume of material in the Blue Box and, because of their high recycling rate, boosted the performance of the Blue Box program overall.”

In 2010, newsprint accounted for over 55% of the total Blue Box marketed tonnes, but it now makes up 23% of tonnage, according to RPRA’s 2020 Datacall.

2020 Marketed Ontario Blue Box Materials (in tonnes,, expressed as a percentage)

Marketed tonnes represent the tonnage sorted and processed by a Material Recycling Facility, which are then baled, sold, and used in place of virgin materials. 

Paper-based Packaging – which includes old corrugated cardboard, old boxboard and a portion of residential mixed papers and mixed fibres packaging – has the largest component of Ontario Blue Box marketed tonnes (271,433 tonnes), representing 35.9% of total Blue Box marketed tonnage (756,984). 

As for the performance of Ontario’s Blue Box program, the 2019 recycling rate was 57.3%, down from 60.2% in 2018, the decline explained by Stewardship Ontario in their 2020 Annual Report:

“The reduction of newsprint, magazines and catalogues and other printed paper materials, along with higher residue rates and higher contamination standards imposed by end markets, are the main reasons for the overall decline in recycled tonnes.”

Table 4 of RPRA’s 2020 Datacall Report shows Marketed Blue Box Tonnes from 2015 to 2020, with Printed Papers – which includes newsprint, household fine paper, telephone books, and catalogues – showing a nearly 62% decline in tonnage over the five-year period; while Paper-based Packaging is up nearly 73% over the same period.

Marketed Ontario Blue Box Tonnes, 2015-2020

PPEC Commentary

It will take some time to understand the implications of the regulatory amendments, and any impacts they may have on the transition to a producer responsibility model for the Ontario Blue Box program. PPEC continues to remain concerned about the feasibility of meeting the paper targets under the new transitioned program, which we have previously written about. We will continue to monitor developments.

What Does “Old” Mean When it Comes to Canada’s Forests?

On April 7, 2022, Finance Minister Chrystia Freeland tabled Canada’s 2022 Budget. The federal government’s environmental and climate change initiatives are outlined in Chapter 3 of the budget, including the proposal to establish a $55.1 million Old Growth Nature Fund to conserve and protect British Columbia’s old growth forests. The funding is proposed to be provided over a three-year period, starting in 2022-23, and conditional on the B.C. government making a matching investment.

The Paper and Paperboard Packaging Environmental Council (PPEC) is a strong proponent of environmental conservation and the protection of forests, and we often write about the importance of sustainable forest management in Canada.

But the federal government’s budget got us thinking: what does “old” mean when it comes to Canada’s forests?

The Government of British Columbia’s website states that their coastal forests are “considered to be old growth if they contain trees that are more than 250 years old,” going on to explain that some types of interior forests “are considered to be old growth if they contain trees that are more than 140 years old.”

So just how old are Canada’s forests?

According to the statistical data provided by Canada’s National Forest Inventory, over 60% of Canada’s forests are less than 100 years old; while a quarter are between 101-140 years old, 5.6% are over 140, and 4.1% are over 200 years old.

Area of forest land by age class in Canada expressed as a percentage

In British Columbia, there are about 11.1 million hectares of old growth forest, representing about 18% of the total forest area of 60 million hectares. The province is currently undergoing a shift in how it manages old growth forests, implementing recommendations from its Old Growth Strategic Review.

In Canada, the majority of forests are publicly owned, with provincial and territorial governments responsible for forest management under various regulations and policies. And by law, all forests harvested on public lands must be successfully regenerated. The most recent data available from The State of Canada’s Forests 2021 Annual Report states that about 550 million seedlings were planted in Canadian forests in 2019 (up from over 440 million seedlings planted in 2018), which is the equivalent of 1,048 seedlings planted every minute.

Number of tree seedlings planted in Canadian forests every minute in 2019

And while any trees that are harvested must be replanted, the Canadian paper packaging industry does not use much in the way of freshly cut trees to begin with: Canadian-made containerboard (used to make corrugated boxes), boxboard cartons, and kraft paper bags are made with over 80% recycled content.

Recycling allows old paper packaging to be continually collected from Canadian residents and businesses so that it can be remade into new paper-based packaging products again and again.

Discussing the Toronto Star’s Ontario Blue Box Article

On March 19, the Toronto Star published The Ford government is overhauling Ontario’s blue box recycling program — and critics say it will be a disaster, by Business Feature Writer Richard Warnica.

The Paper and Paperboard Packaging Environmental Council (PPEC) was interviewed for the article on February 4, but our comments about paper-based packaging in Ontario’s Blue Box program, including concerns over the new paper targets and the importance of the consumer role, were not included.

The focus of the detailed article is primarily about the multiple Producer Responsibility Organization (PRO) model, and the confusion surrounding the final Blue Box regulation, which was released in June 2021, and sets out the framework to transition to a producer responsibility model.

The new model will transfer the full operational and financial management of the Ontario Blue Box program to producers, with implementation beginning July 2023.

It marks a significant change from the existing shared model, which sees producers pay 50% of municipal Blue Box costs. Producer responsibility for packaging and printed paper is not new, with British Columbia being the first province to implement a full 100% industry funded and controlled program in 2014, run by Recycle BC.

But back to the Star article. The general feeling is that the new regulation is confusing.

Jo-Anne St. Godard of the Circular Innovation Council (formerly Recycling Council of Ontario) said: “This is the most bizarre approach to packaging regulation and EPR we’ve seen.”

Denis Goulet of Miller Waste Systems said: It’s confusing to people who’ve been in the industry for 30 years.”

Duncan Bury, a consultant specializing in producer responsibility, said: “What they’ve developed is way more complicated than it needs to be, and I think there’s real worries about how this will actually roll out.”

Warnica writes that the confusion could have consequences, including meeting regulated timelines and potentially higher costs:

“It would force some municipalities to sign expensive contract extensions with existing suppliers…or work out new deals in a tight market already constrained by supply chain backlogs.”

Transition to Full Producer Responsibility Timeline

Multiple PROs…and David vs. Goliath?

Part of the confusion and complexity, some say, have to do with having a multiple PRO model, versus the current single PRO model, which is also the case in British Columbia.

The PROs that have registered to date include: Circular Materials Ontario, a not-for-profit created and governed by producers; Resource Recovery Alliance, owned and operated by GFL Environmental; and Ryse Solutions Inc.

Warnica’s article quotes Patrick Dovigi, CEO of GFL Environmental, who said: “The government at the time decided to go out with multiple PROs because they think it created competition…. All the multiple PROs dynamic does is create inefficiencies where all the costs really are.”

The article speaks to specific concerns regarding GFL. First, that their PRO may create a conflict of interest – ie. having a waste management company operate a PRO who is also contracting out business to waste management companies – and second, that they could have an unfair advantage given their size.

Jo-Anne St. Godard explained it this way: “I think you need to be able to have separate church and state,” going on to say “if you have a monopoly service provider, or one that has a very big dominant position, the buyers of that service may find themselves only having one price-taker effectively.”

In the article, Dovigi refers to himself as David, as in David vs. Goliath, with Goliath being the major producers.

David vs. Goliath and Blue Box recycling bin

Dovigi went on to say: “People are making me out to be the bad guy…and we’re just little GFL from Toronto.”

As the article points out, GFL is the fourth largest waste management company in North America with a market cap of $12.3 billion. GFL also completed 46 acquisitions in 2021, and are planning another 25-30 deals this year, according to Waste Dive.

But back to the issue of competing PROs. According to the article, both the Resource Recovery Alliance and Circular Materials Ontario have requested changes to the regulation, specifically “to reverse the central tenet calling for competing PROs, and to impose a single Producer Responsibility Organization to oversee the entire system.”

Though not everyone agrees with that. The Ontario Waste Management Association (OWMA) reaffirmed its support for the current Blue Box regulation. OWMA wrote a letter to Minister Piccini that they do not support any amendments to the regulation “that would create uncertainty for public and private waste service providers and residential customers.”

PPEC Concerns with Paper Targets and Needing to Recognize the Role of the Consumer

When PPEC spoke to Warnica in February, we talked about our concerns with the feasibility of meeting the new Ontario paper diversion targets (80% for 2026-2029, and 85% for 2030 and beyond). The below graph plots the material composition of the Ontario Blue Box program (stacked bar) and total recycled tonnage (broken line) from 2004 to 2019. Paper is the largest component of the Blue Box (the orange and blue), but the overall composition of the paper category has been changing for years, which impacts diversion. Printed paper makes up much less of the Blue Box than it used to, and paper packaging has doubled, while overall recycled tonnes are on a downward trend.

Ontario Blue Box Material Composition and Total Recycled Tonnes Chart: 2004 to 2019

With less being collected in the Blue Box, such as newspapers, while other categories, such as corrugated boxes already achieving 98% recovery from Ontario households (according to the 2020 Blue Box Pay-In Model), it begs the question of how will the overall paper diversion rate increase to meet the government’s new, higher targets?

Confusion over targets - person with question mark with "80%" and "85%" thought bubbles

PPEC commissioned a study, conducted by Dan Lantz at Crow’s Nest Environmental, to examine Blue Box diversion data to help determine if the government’s proposed diversion targets could be achieved. The study found that the proposed targets could not be met:

“A 90% target is unreachable. This would effectively require 95% of the population capturing and putting out for recycling 97% of their paper and making sure it is not contaminated at all. And then the recycling facility would have to capture 98% of all that paper (including paper that’s shredded) and send it on to the end-market.”

Diversion targets lowered but still out of reach

We also spoke about how the new model could help achieve harmonization through a more standardized system. There are 444 municipalities in Ontario, with 250 programs participating in the Blue Box program. That’s 250 separate programs, with different collection lists, and different approaches to educating their residents, aka the consumer.

And the role of the consumer is paramount to the success of any recycling program, including Ontario’s Blue Box program. At the end of the day, it is the consumer who makes the decision of how to dispose of their waste and recyclables. The more aware and educated they are, the more likely consumers are to clean and empty their recyclables, and separate them from waste and organics. Standardization may help deliver a more uniform educational message to Ontarians, which could help increase diversion and reduce contamination (the higher the contamination, the harder it is to achieve better recovery rates).

The latest Ontario Blue Box data shows that the recovery rate increased slightly in 2020 to 59.9%, which means that a little over 40% of what is placed in the Blue Box ends up in landfill.

It goes without saying that it is in everyone’s best interest to ensure that programs run efficiently, are able to capture the value of materials, prevent recyclables from ending up in landfill, and ensure consumers understand their role.

PPEC will continue to monitor the developments related to Ontario’s Blue Box regulation, and the transition to the new producer responsibility model.

Sustainable Forest Management and Canada’s Paper Packaging Industry 

With today’s International Day of Forests, the Paper and Paperboard Packaging Environmental Council (PPEC) would like to explain how sustainable forest management is critical to the circular economy of Canada’s paper packaging industry, and share the latest developments related to how forests can help mitigate climate change.

Environmental sustainability is at the core of PPEC member company operations and the Canadian paper packaging industry, including the sustainable management of Canada’s forests. And yet, misconceptions surrounding forestry and paper packaging persist when it comes to how paper packaging is made.

How Paper Packaging is Made

In Canada, paper packaging is made from virgin, recycled, or blended pulp (a mix of the two); with all paper fibre sources verified to be responsibly sourced by independent, third-party certification bodies.

Most domestic shipments of the three major paper packaging grades made in Canada – containerboard (used to make corrugated boxes), boxboard (used to make boxboard cartons), and kraft paper (used to make paper bags) – are made from recycled content (81.7%).

Mills also use sawmill residues – such as wood chips, shavings and sawdust left over from sawmill operations – and some supplement their pulp with virgin fibres from trees, which represents about 12% of the average paper-based box, carton, or bag.

Canada's Major Paper Packaging Grades Made Primarily from Recycled Content

The mixture of using recycled content – old boxes and other paper materials collected from residential and business recycling programs – along with some new fibres from sustainably managed forests, is an important component to paper packaging’s circular economy.

First, by law, every hectare of commercial forest that is harvested in Canada must be successfully regenerated, so any trees that are harvested are replanted.

And second, through the important act of recycling, paper packaging is continually collected from Canadian residents and businesses, so it can be remade into new paper-based packaging products again and again.

Paper Packaging: One of Canada's Original Circular Economies

And while stats show that paper can be recycled up to seven times, and corrugated box fibres up to ten times, a recent study from Graz University of Technology in Austria found that fibre-based packaging material can be recycled at least 25 times without losing mechanical or structural integrity.

While this new research suggests that paper and board fibres are even more durable than previously thought, we know that over time fibres weaken, which means a small amount of new virgin fibre needs to be introduced now and again, which leads to a second common misconception regarding deforestation.

The Causes of Deforestation and the Role of Regeneration in Sustainable Forest Management

According to Natural Resources Canada’s State of Canada’s Forests 2020 Annual Report, Canada’s 347 million hectares of forest area is stable, with less than half of 1% deforested since 1990.

But there is often a lot of confusion about deforestation, which is when forest land is permanently cleared and converted to make way for new, non-forest land use.

Canada’s annual deforestation rate has been declining since 1990, when it was 64,000 hectares, down to about 34,300 hectares in 2018. During that time, less than half of one per cent of Canada’s total forest area was converted to other land uses.

The major causes of deforestation are due to agriculture, mining, oil and gas projects, new homes, and the development of ski hills and golf courses, which together represent over 90% of deforestation in Canada.

The Major Causes of Deforestation in Canada (2018)

The forestry sector’s (which includes pulp and paper manufacturing and the wood product manufacturing subsectors) share of deforestation represents 1,494 hectares, or approximately 0.0004% of total deforestation in Canada.

And given that the Canadian paper packaging industry doesn’t use much in the way of freshly cut trees, the little that is harvested (0.2% in 2018) must be successfully regenerated (427 million seedlings were planted across Canada in 2018), making packaging’s share of deforestation zero.

Deforestation Facts

The Role of Forests in Mitigating Climate Change

Sustainable management of y managed forests have an important role to play in helping to mitigate climate change, as trees capture and store carbon, acting as carbon sources or carbon sinks: a forest is considered a carbon source if it releases more carbon than it absorbs, and a carbon sink if it absorbs more carbon from the atmosphere than it releases.

The Canadian government knows this and has committed to plant two billion additional trees by 2030, which would represent a 40% annual increase in the number of trees already being planted, and would lower emissions by up to 12 megatonnes annually by 2050 by removing carbon from the atmosphere.

Considering the carbon storage by forests is just one of the many recommendations from a new report by the United Nations’ Food and Agriculture Organization (FAO), Forest Products in the Global Bioeconomy: Enabling substitution by wood-based products and contributing to the Sustainable Development Goals; which speaks to the role renewable forest products have in helping to combat climate change, and explores how wood-based products could help replace fossil-based and GHG-intensive products:

“There is strong evidence at product level that wood products are associated with lower GHG emissions over their entire life cycle when compared to products made from non-renewable or emissions-intensive materials. A review of 488 substitution factors obtained from 64 published studies indicates that the use of wood and wood-based products is generally associated with lower fossil and process-based emissions when compared to non-wood, functionally equivalent products. However, over three-quarters of studies in the literature focus on the construction sector and significantly less information exists for other traditional forest products such as paper for printing, writing, and packaging, or emerging forest products.”

As Two Sides North America’s Kathi Rowzie explained in Can Paper Help Save the Planet?:

“The document left open for later study the extent to which paper and paper-based packaging may serve as substitutes for non-wood products in the search for those that contribute to the net reduction of greenhouse gases, but there’s little doubt that any product sourced from materials that are grown and regrown are better for combating climate change than the non-paper alternatives.”

In addition to the FAO’s new report, the Forest Products Association of Canada recently released the documentary, Capturing Carbon, highlighting the role of sustainable forest management and wood products in helping to mitigate climate change; and the World Business Council for Sustainable Development released its Forest Sector Net-Zero Roadmap, about the forest sector’s role in enabling the transition to a net-zero economy. These are just a few of the developments related to forestry’s role in addressing climate change, which PPEC is monitoring.

When we use and recycle paper-based packaging, we all play a part in protecting and replenishing our renewable resources, contributing to the sustainable management of Canada’s forests, and supporting the circular economy of the paper-based packaging industry.

On International Day of Forests, it is important to remember that Canada’s forests are stable and sustainably managed.

The Latest Ontario Blue Box Recycling Data for Paper-based Packaging

Paper-based packaging continues to be the largest captured material in Ontario’s household Blue Box program, based on new data released by the Resource Productivity and Recovery Authority (RPRA).

Each year, municipalities, recycling associations, and First Nation communities in Ontario report on their residential waste diversion programs to RPRA, through the annual Datacall. The most recent Datacall Report summarizes information generated by the 250 programs participating in the Blue Box Program in 2020, and highlights residential waste management trends.

Overall, the Blue Box recovery rate – the amount of designated packaging and printed materials recovered as a per cent of the amount generated – increased to 59.9% in 2020, up from 57.3% in 2019.

Of interest to the Paper and Paperboard Packaging Environmental Council (PPPEC) and its members, is Figure 3 from the report, which shows Marketed Blue Box Materials in tonnes. Paper-based Packaging has the largest component with 271,433 tonnes, representing 35.9% of the total Blue Box marketed tonnage (756,984).

Source: Resource Productivity and Recovery Authority 2020 Datacall Report

Marketed Blue Box tonnes represent the tonnage sorted and processed by a Material Recycling Facility, which are then baled, sold, and used in place of virgin materials.

The second largest material is Printed Paper with 23% of marketed tonnes. However, this category – which includes newsprint, household fine paper, telephone books, and catalogues – continues to decline year over year.

Table 4 of the Datacall Report shows Marketed Blue Box Tonnes from 2015 to 2020, with Printed Papers showing a nearly 62% decline in tonnage over the five-year period.

Meanwhile, paper-based packaging – which includes old corrugated cardboard, old boxboard, and a portion of residential mixed papers and mixed fibres packaging – shows a nearly 73% increase in tonnage over the same period. The most recent year shows a 13.1% increase, which may be attributed to the rise in e-commerce shipments due to the pandemic.

Source: Resource Productivity and Recovery Authority 2020 Datacall Report

RPRA’s Datacall Report states that 99.8% of Ontario households have access to recycling corrugated and boxboard paper-based packaging. And not only do they have access, Ontario households are actively doing their part to recycle these materials.

The Ontario household recovery rate for Corrugated Cardboard is 98%, and 47% for Boxboard, according to Stewardship Ontario’s 2022 Blue Box Fee Calculation Model.

RPRA’s Datacall Report also offers insights into 10-year trends, including declining newsprint and rising program costs. Overall, Blue Box marketed tonnage decreased by 14.7% from 2010 to 2020, largely due to the continued decline of printed paper in Ontario, which has seen a 64% decrease over the last 10 years. Meanwhile, Net Blue Box costs have increased 35.2% from $203 million in 2010, to $349.8 million in 2020, while revenue received by programs is declining.

The Ontario Blue Box program is currently undergoing transition to a full producer responsibility framework, which will see producers take over 100% operational and financial management of the program by December 31, 2025.

Paper-based packaging is collected for recycling at both the household level, and from the backs of factories, supermarkets, and office buildings (also known as the Industrial, Commercial and Institutional sector). And as recycling plays an important role in the sustainability of Canada’s paper-based packaging industry – allowing PPEC member mills to maintain high levels of recycled content – PPEC closely monitors recycling and waste diversion statistics published by provincial stewardship organizations, Statistics Canada, and other organizations.

PPEC is proud of our industry’s circular economy approach to managing paper packaging products, which are continually collected and recycled through residential and business recycling programs across Canada, allowing them to be remade into new paper-based packaging products again and again.

This National Pizza Day Don’t Forget that Pizza Boxes are Recyclable in Canada

It is National Pizza Day on February 9, 2022, and the Paper and Paperboard Packaging Environmental Council (PPEC) wants to celebrate by reminding you that pizza boxes are recyclable in Canada! You thought we were going to say eat pizza, right? You can do that, too, but don’t forget to recycle that box once you’re done!

Pizza boxes are normally made from corrugated board, and in Canada, corrugated board is made mostly from recycled content. So, once that empty and clean pizza box is placed in the recycling bin – where it is then collected, sent for processing, baled, and sold – that recycled material then makes its way back to our members’ paper packaging mills, where it will get remade into a new pizza box, or another type of paper-based packaging.

That recycled pizza box represents an important slice of the Canadian paper packaging industry’s circular economy. Recycled content keeps raw materials flowing longer, reducing the need to extract virgin materials. And the average recycled content for domestic shipments of containerboard – which is used to make corrugated board – is close to 87%, based on PPEC’s 2020 Recycled Content Survey.

In general, paper can be recycled up to seven times, while corrugated box fibres can be used up to ten times, to make new boxes and other paper-based packaging products. We already thought those numbers were quite good, but a new study from Graz University of Technology in Austria found that fibre-based packaging material can be recycled at least 25 times, without losing mechanical or structural integrity, suggesting that paper and board fibres are even more durable than previously thought.

Thanks to the important act of recycling, it’s likely that your pizza box has had multiple lives, and we want that to continue. But unfortunately, there has been some confusion over the years when it comes to their recyclability.

National Pizza Day - three images of Pizza boxes Recyclable and Compostable

In the past, it has been suggested that pizza boxes should not be placed in blue box recycling bins because of the grease and cheese scraps. But that’s not true. If you remove the food scraps (eat those crusts!) and any plastic (like that three-pronged pizza saver which is meant to prevent the box top from sagging), that corrugated pizza box is recyclable in Canada.

And when it gets to the recycling mill, the empty pizza box goes into a pulper – which is like a big washing machine – where any non-paper materials are removed through a series of cleaning and screening processes. The paper fibres are then pumped onto a fast-moving screen to form paper or board. The rest of the process involves removing the moisture out of the paper or board so that it can be wound onto big rolls or cut into sheets, which are then shipped to a converter or a box plant, where it is remade into new paper-based packaging.

But what about the greasy residue you sometimes see on a pizza box? Well, in a typical mill’s recycling process, the temperature of the paper sheet reaches up to 240 degrees Fahrenheit – well above 100 degrees Celsius, the boiling point of water and the temperature required for sterilisation – which gets rid of the grease. Though there is not much grease to begin with, as the average grease content of a pizza box found in the recycling stream is approximately 1-2% by weight level, according to WestRock’s Incorporation of Post-Consumer Pizza Boxes in the Recovered Fiber Stream Study.

Paper-packaging is a successful recycling story in Canada and pizza boxes are no exception.

Not only do 96% of Canadians have access to recycling for corrugated boxes, determined through an independent third-party study commissioned by PPEC, but Canadians actively do their part by recycling. PPEC has estimated a national recovery rate for corrugated boxes of at least 85%, with recycling even higher in certain provinces, such as Ontario’s Blue Box program, which has a 98% recovery rate for corrugated.

However, it should be noted that for some Canadian communities, composting paper packaging (including pizza boxes) may be more convenient, such as in Nova Scotia and Prince Edward Island, who are hundreds of kilometres from the nearest packaging recycling mill.

Happy National Pizza Day from PPEC, and don’t forget to recycle your empty pizza boxes so they can be recycled into new pizza boxes!

Competition Bureau Archived Canadian Environmental Claims Guide: Now What?

On November 4, 2021, the Competition Bureau archived Environmental claims: A guide for industry and advertisers, stating that:

“The Guide may not reflect the Bureau’s current policies or practices and does not reflect the latest standards and evolving environmental concerns. The guide will remain available for reference, research and recordkeeping purposes, but it will not be altered or updated as of the date of archiving. Please consult Environmental claims and greenwashing for information about false, misleading and unsubstantiated environmental claims.”

The Competition Bureau is an independent law enforcement agency, responsible for the enforcement of the Competition Act, which forbids companies from making false or misleading claims about a product or service; and takes aim at environmental claims that are vague, non specific, incomplete, or irrelevant and that cannot be supported through verifiable test methods.

The practice of making false or misleading environmental claims is known as “greenwashing,” and it is illegal in Canada and many other jurisdictions.

And under the Competition Act, Canadians can apply to have the Bureau investigate a greenwashing claim. 

This blog talks about recent greenwashing investigations and activities, the importance of evidence-based claims, and PPEC’s commentary about how recent developments are signalling increased awareness and enforcement around environmental claims.

Competition Bureau image

Competition Bureau Investigates and Fines Canadian Beverage Company over Recycling Claims

The Competition Bureau investigated Keurig Canada, a producer and distributor of hot and cold beverages, over its environmental claims on the recyclability of their K-Cup pods.

According to the Bureau’s January 6, 2022 news release, “Keurig Canada to pay $3 million penalty to settle Competition Bureau’s concerns over coffee pod recycling claims,” it reached an agreement with Keurig Canada “to resolve concerns over false or misleading environmental claims made to consumers about the recyclability of its single-use Keurig® K-Cup® pods.”

The Bureau’s investigation concluded that the company’s recyclability claims for its single-use coffee pods were “false or misleading in areas where they are not accepted for recycling.” Outside of British Columbia and Quebec, K-Cup pods are currently not widely accepted in municipal recycling programs.

As part of the settlement, Keurig Canada agreed to pay a $3 million penalty; donate $800,000 to a Canadian charitable organisation focused on environmental causes; pay an additional $85,000 for the costs of the Bureau’s investigation; change its recyclable claims and the packaging of the K-Cup pods; and publish corrective notices about the recyclability of its product on its websites, on social media, in national and local news media, in the packaging of all new brewing machines and via email to its subscribers.

For additional information, please see the Competition Bureau’s news release and public case documents.

Reaction to Competition Bureau Investigation and Other Potential Inquiries

Ecojustice, a Canadian environmental law charity, called it a “major win for consumers and the environment,” in their January 14, 2022 blog post Keurig’s $3 million fine highlights thepervasive issue of greenwashing, writing:

“This victory comes following a 2019 submission by Ecojustice and the University of Victoria Environmental Law Clinic to the Competition Bureau which highlighted several instances of false and misleading marketing of K-cups as a ‘green’ and easily recyclable product for Canadian consumers.”

In addition to the Keurig inquiry, Ecojustice “has also prompted the Competition Bureau to open two other inquiries into greenwashing claims: about so-called ‘flushable’ wipes and the Sustainable Forest Management Standard.”

Ecojustice believes that the Canadian Standards Association’s Sustainable Forest Management Standard (CSA Z809) “is patently false and misleading,” and in July 2021, they called for an investigation into ‘sustainable’ logging in B.C., regarding their concerns that “it is not at all possible to sustainably log 800-year-old trees.”

Ecojustice hopes that “the Keurig case signals the Competition Bureau will take meaningful action to hold companies to account for greenwashing.”

Italy’s First Greenwashing Case

On January 13, 2022, law firm Clifford Chance reported on Italy’s first greenwashing case between corporates, where an Italian Court upheld a company’s request for an interim injunction against a competitor.

The case was brought forward by Alcantara S.r.l., a textile manufacturer – who recently hosted the 6th edition of the International Symposium on sustainability entitled “Greenwashing and Sustainability: a growing trend that needs to be addressed” in October 2021 – against Miko S.r.l., one of its competitors, who markets a microfibre product.

The claims made by Miko included statements such as: “environmentally friendly,” “100% recyclable,” and “natural choice,” to name a few. The Court ruled that the statements were “vague, generic, false, and non-verifiable and needed to be immediately removed.”

Forbes’ December 8, 2021 article, Alcantara Wins Major Court Battle Against Greenwashing, states that Judge Francesca Clocchiatti cited the “rapid expansion of the pathological phenomenon of greenwashing.”

Words Matter: The Importance of Evidence-Based Claims

So why is the Canadian association for paper-based packaging talking about an Italian court case?

Because it is a reminder of the importance of terminology, and that environmental claims must be clear, accurate, and based on fact and data.

PPEC has written about this issue before – see Clarifying some of the confusion over “recyclability” and Nothing is 100% recyclable or 100% compostable – but in terms of environmental labelling, what matters is whether the consumer can actually send the product or material for recycling or composting. It does not matter whether the product or material is technically capable of being taken apart and broken down so it can be properly recycled or composted. It does not matter what the actual recycling or recovery rate of that material might be.

What matters is how many Canadians have access to the recycling (or composting) of that product or material.

Competition Bureau - 50% in Canada, 60% in the U.S image2

In Canada and in the U.S., the definition of the word “recyclable” for environmental labelling purposes has been understood to mean that a reasonable proportion of the population – which is 50% in Canada, according to the Competition Bureau; and 60% in the U.S., according to the Federal Trade Commission – has access to the recycling of that package or packaging material.

In Canada, we know that 96% of Canadians have access to recycling for corrugated boxes and paper bags, and 94% for boxboard cartons, determined through an independent third-party study. Knowing that, PPEC has stated that Canadian box, bag and carton manufacturers can print the word “Recyclable” and use the Recyclable logos on their packaging. However, we do not currently have the same data available for access to composting in Canada. 

It’s also important to note that while most Canadians have access to recycling facilities, there are some who live in remote regions who do not have easy or convenient access to recycling. Therefore, it is important to remember that 100% access for Canadians will likely never be achieved, which make claims like “100% recyclable,” misleading and untrue.

In the U.S., 94% of Americans have access to community paper recycling programs, and 79% have access to residential-curbside recycling programs, according to the American Forest & Paper Association’s (AF&PA) recent 2021 Access to Recycling Study.

Recyclable and compostable claims, then, are based on whether and to what extent consumers have access to recycling or composting facilities. While we have data on access to recycling, we do not currently have the same data available for access to composting in Canada. 

PPEC’s Commentary  

These recent developments signal increased awareness and enforcement around environmental claims.

Any company which puts forward environmental claims on their products or packaging are reminded that they need to know the applicable laws to ensure they are making informed legal decisions and evidence-based claims.

PPEC members are no exception, and we have historically pointed our members in the direction of the Competition Bureau’s now archived Environmental Claims guide, in addition to providing them with information and data about access to recycling.

So, what does it mean now that the guide has been archived? And if the guide “may not reflect” current policies, practices, or standards, what does?

At first, we took the archiving of the Competition Bureau’s guide in the most literal sense of the word – “archive” as in put aside, put in storage, basically shelving it – which felt confusing and unexpected during a time when there has been a significant increase in “greenwashing” news.

But knowing that the opposite of archive means to remove or delete, we are now taking this move to mean that the guide is still here and “will remain available for reference, research, and recordkeeping purposes,” as the Competition Bureau put it.

While we recognize that the guide is not going anywhere, PPEC encourages the Competition Bureau to provide updated guidance as it becomes available.

Meanwhile, we remind PPEC members to ensure they are aware of, and comply with, existing obligations when making environmental claims, and to refer to the Competition Act, the Competition Bureau’s Environmental claims and greenwashing, and its January 2017 news release, Calling it “organic”, “green” and “eco-friendly” isn’t enough, that’s greenwashing, and it’s against the law, for additional information.

Multinational companies may also need to consider guidance available in other jurisdictions, including, but not limited to:

In general, PPEC advises against using vague claims, broad terms, “100%” claims. Environmental claims should be clear, accurate, evidence based, and comply with existing obligations.

Consumers are increasingly environmentally conscious, aware, and informed, and in many jurisdictions, including Canada, they are empowered to take action.

We believe the news reported on in this blog signals more than just a trend, but a concerted pushback against greenwashing, both here in Canada, and globally.

What PPEC will be Watching in 2022

As the Paper and Paperboard Packaging Environmental Council (PPEC) continues to work on achieving its mission to promote the environmental, social, and economic sustainability of the Canadian paper packaging industry, we will also be closely monitoring the following key issues in 2022.

Extended Producer Responsibility and Recycling

Extended Producer Responsibility (EPR) is a policy approach in which a producer – a business that makes or sells obligated materials – is made financially responsible for ensuring their products and packaging are properly managed at the end of their life.

In Canada, EPR recycling programs for residential packaging and printed paper (PPP) are currently legislated in British Columbia, Saskatchewan, Manitoba, Ontario, and Quebec.

While PPEC members have not historically been obligated stewards of these programs – our members typically engage in business-to-business transactions, and do not directly supply finished products to consumer – such recycling programs are critical to our industry, and on behalf of its members, PPEC participates in government discussions related to new or changing recycling regulations.

This year will be busy with changes to existing programs and new government consultations, and PPEC will be closely monitoring:

  • Ontario as the Blue Box program transitions to a full producer responsibility model, regulated in June 2021, which means it is moving to a full 100% operational and financial management model, with implementation beginning July 2023. Under the previous regulation, producers were responsible for funding 50% of program costs; while the new model requires producers to establish and fund a collection and management system to manage Blue Box materials.
  • Alberta introduced the Environmental Protection and Enhancement Amendment Act which will enable the development of EPR regulations for designated categories of materials. The government is currently conducting a stakeholder consultation.
  • New Brunswick amended the Designated Materials Regulation under the Clean Environment Act in October 2021, to establish an EPR program for packaging and paper products. Recycle NB will oversee the PPP program, and under the amended regulation, brand owners are required to register with Recycle NB by February 11, 2022. The program is proposed to begin in the spring of 2023.
  • Nova Scotia introduced The Environmental Goals and Climate Change Reduction Act, which includes a provision to develop and legislate an EPR program for paper and packaging in Nova Scotia, with new EPR regulations expected to be developed by 2023. A 90-day government consultation is expected to launch in early January.
  • Quebec will begin its transition period to an EPR model for its curbside recycling system in 2022, with implementation by 2025. Companies who already finance the Quebec curbside recycling system will be given control over its the system and its management, in partnership with municipalities. Under the current system, companies finance 100% of the costs of municipal collection services for recyclable materials, without control over system management.
  • Manitoba’s PPP stewardship organization, Multi Material Stewardship Manitoba (MMSM), submitted the draft Transition Plan to Minister of Conservation and Climate November 2021, outlining how it proposes to transition the current shared responsibility model for the delivery of residential recycling of PPP, to one that is fully operated and financed by industry. It is expected that there will be additional consultations this year.

PPEC is proud that paper-based packaging is highly recyclable across Canada in provincially legislated Blue Box-type programs. Not only do Canadian residents have access to these programs, but they actively recycle their paper-based packaging, allowing PPEC’s paper packaging mill members to maintain high levels of recycled content in Canadian made paper packaging, illustrating our home-grown circular economy where used paper is recycled again and again.

New Forestry Statistics

Sustainable forest management is a fundamental pillar for PPEC and its members and is essential to the Canadian paper-based packaging industry.

While most paper packaging made in Canada is made with recycled content, the paper fibres it was originally made from came from a tree. However, less than half of one per cent of Canadian commercial forests are harvested for paper-based packaging, and every hectare that is harvested must be successfully regenerated.

The State of Canada’s Forests Report, published annually by Natural Resources Canada, is an important resource to PPEC, as it is a source of key data on Canada’s forests and its sustainable management, which we use correct misinformation and dispel myths surrounding the paper-based packaging industry and trees.

The 2021 Annual Report has been delayed due to the pandemic but is expected to be released within the next few months; the scheduling of the tabling date of the report is also dependent on Parliament’s agenda and procedures.

Compostability Initiatives

Of the many environmental-attributes of paper-based packaging, not only is it made from a renewable resource and is easily recyclable and recycled, some types of paper-based packaging can also be composted, where facilities exist.

PPEC monitors composting-related initiatives, and most recently, in December 2021, a few national compost organizations, including the US Composting Council and the Compost Council of Canada, established the International Compost Alliance, a voluntary partnership to advance awareness and understanding of the benefits and use of compost on a global scale.

PPEC is looking forward to learning more about this new partnership and their aim to maximize the recycling of organic wastes and advance the manufacturing of certified, high-quality composts.

In the meantime, PPEC will continue to provide clarity on paper-based packaging that may be both recyclable and/or compostable. For example, in Ontario, paper flour bags can be recycled in the Blue Box program, but if they have some food residue, they can be placed in the Green Bin for composting.

For additional information, the Compost Council of Canada has an interactive map of Canada with information on composting facilities, and any related regulations or guidelines, organized by province and territory.

Carbon and Climate Change

Coming out of the COP26 climate summit, and the federal government’s recent Speech from the Throne and their commitments on taking bolder climate action, PPEC will continue to monitor government and industry climate change initiatives and announcements; as well as stewardship organizations who have begun tracking greenhouse gas (GHG) emissions across their recycling activities.

Paper-based packaging is made from a renewable resource and is a sustainable material, one that it is highly recyclable and recycled across Canada. In general, paper can be recycled up to seven times, while corrugated box fibres can be used up to ten times, to make new shipping boxes and other paper-based packaging products. Canadian paper packaging mills average recycled content of domestic Canadian shipments of the three major paper packaging grades is close to 82 percent.

And Canadians play a critical role when they recycle their paper-based packaging, which allows recycled fibres to make their way back to the mill to be remade into new paper packaging products, avoiding GHG emissions that would have resulted if the material ended up in landfill.

Sustainable forest management practices can also help sequester carbon (the process of capturing and storing atmospheric carbon dioxide) as forests act as either carbon sources or carbon sinks: a forest is considered to be a carbon source if it releases more carbon than it absorbs, which can result from old age, fire, or insects; or it’s considered to be a carbon sink if it absorbs more carbon from the atmosphere than it releases through photosynthesis. According to Natural Resources Canada, our country’s managed forests have primarily been a carbon sink, but recently there has been a shift and they have become carbon sources, releasing more carbon than storing it, due in large part to wildfires and insect outbreaks, a likely result of a changing climate.

To date, PPEC has not collected data from its members on their carbon emissions, but we are currently conducting preliminary research related to the Canadian paper-based packaging industry, based on available data, and will be sharing that information in future PPEC communications.

Happy Holidays from PPEC and thank you for your support in 2021!

2021 Thank you and holiday greeting from PPEC. Celebrating the environmental sustainability of the packaging industry

Greetings from the Paper and Paperboard Packaging Environmental Council!

Thank you for supporting PPEC and our mission to promote the Canadian paper-based packaging industry’s environmental sustainability story. Some of the highlights of our work over the past year include:

  • The release of PPEC’s exclusive 2020 Recycled Content Survey, which shows the average recycled content used to make paper-based packaging products in Canada has increased to 82%, an excellent result that shows recycled content is a key component of our industry’s circular economy.
  • Continuing to advocate for fairness in legislated paper packaging recycling and Extended Producer Responsibility (EPR) programs across Canada, participating in government consultations, preparing submissions, and monitoring provinces considering new EPR programs.
  • Participating in a successful national media campaign to raise awareness about PPEC and promote the environmental sustainability of our industry.
  • Being featured in the trade publication, Recycling Product News for PPEC’s important commentary about how media articles about paper-based packaging must recognize the environmental attributes of our products.
  • The creation of PPEC’s new infographic to help explain our industry’s a circular economy approach to managing paper-based packaging, which are continually collected and recycled, allowing them to be remade into new paper packaging products again and again.
  • And blog posts about Sustainable Forest ManagementProviding Clarity on The Ottawa Citizen’s Cardboard Recycling Article, and an Ontario Blue Box Update, amongst others.

Looking ahead to 2022, we are hoping to accomplish even more, and will continue to work to promote the environmental sustainability success story of the Canadian paper-based packaging industry.

Thanks again for your support and best wishes for a happy, healthy, and safe holiday season from all of us at PPEC!

PPEC Holiday Closing Dates:

Please note the PPEC Office will be closed December 27, 2021 – January 3, 2022 for the holiday season. The office will reopen on January 4, 2022.