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Archive for Paper Recycling

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. 

Rachel Kagan

Executive Director Paper & Paperboard Packaging Environmental Council (PPEC)

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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.

Rachel Kagan

Executive Director Paper & Paperboard Packaging Environmental Council (PPEC)

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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.

Rachel Kagan

Executive Director Paper & Paperboard Packaging Environmental Council (PPEC)

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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.

Rachel Kagan

Executive Director Paper & Paperboard Packaging Environmental Council (PPEC)

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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.

Rachel Kagan

Executive Director Paper & Paperboard Packaging Environmental Council (PPEC)

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Celebrating Waste Reduction Week and the Circular Economy of Paper-based Packaging

The Paper & Paperboard Packaging Environmental Council (PPEC) is pleased to celebrate the 20th anniversary of Waste Reduction Week in Canada, taking place this week.

Waste Reduction Week is an important program focused on the principles of circular economy, resource efficiency, and waste reduction; principles that PPEC and its members strongly support and apply to their daily operations in the production of recyclable paper-based packaging.

Paper is a renewable resource and a highly sustainable material that can be recycled and remade into new paper-based packaging products. 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.

Canada recycles almost 70% of its paper and cardboard, making it among the top paper recycling countries. And looking at corrugated boxes in particular – which have seen an increase in demand due to the pandemic and a rise in e-commerce – the national recycling rate for corrugated boxes is estimated by PPEC to be at least 85%, while Ontario has a 98% recovery rate for corrugated cardboard.

Keeping these materials in the recycling stream allows PPEC member mills to primarily use recycled fibres in their products. Recycled content is a key component of the Canadian paper-based packaging industry’s circular economy, keeping raw materials flowing for longer, reducing waste, and allowing them to be remade into new paper packaging products by PPEC member mills.

Circular Economy Chart for Waste Reduction Week

PPEC’s 2020 Recycled Content Survey of Canadian mills found that the average recycled content of domestic Canadian shipments of the three major paper packaging grades – containerboard (used to make corrugated boxes), boxboard (used to make boxboard cartons), and kraft paper (used to make paper bags) – is collectively 81.7%, up from 73.5% in 2018, and up from up from 47% back in 1990 when PPEC first began collecting this data.

And consumers play a critical role in the paper-based packaging industry’s circular economy through their important act of recycling. The majority of Canadians (94%) have access to recycling programs – and not only do they have access – they actively and regularly recycle their paper-based packaging, allowing those recycled fibres to make their way back to the mill to be remade into new paper packaging products again and again.

Waste Reduction Week - paper-based packaging materials are recyclable

And while most paper-based packaging made in Canada is made with recycled content, the paper fibres it was originally made from came from a tree. That’s why resource protection and sustainable forest management is critical to the operations of PPEC members and the Canadian paper-based packaging industry. All PPEC-member mills have independent, third-party certification that verifies that their paper fibre sources – recycled fibre, wood chips, and sawmill residues – are responsibly sourced. And while less than half of one per cent of Canadian commercial forests are harvested for paper-based packaging, every hectare that is harvested must be successfully regenerated; in 2018, at least 427 million seedlings were planted across Canada. When you add it up, the Canadian paper-based packaging industry hardly uses any freshly cut trees to make paper packaging, and the little that is harvested, 0.2% in 2018, is successfully regenerated.

When we use paper-based packaging, we all play a part in the circular economy of the paper-based packaging industry. Learn more the environmental sustainability of paper-based packaging by visiting PPEC’s website and follow us on social media on Twitter and LinkedIn. And to learn more about Waste Reduction Week visit https://wrwcanada.com/en.

Rachel Kagan

Executive Director Paper & Paperboard Packaging Environmental Council (PPEC)

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Survey Says: Recycled Content a Key Component to Paper Packaging’s Circular Economy

Most boxes and cartons manufactured in Canada are made of recycled content – from old boxes and other used paper material collected from the back of factories, supermarkets, office buildings, and residential Blue Box recycling programs.

And there has been a significant increase in average recycled content for paper-based packaging over the years, up from 47% back in 1990, to over 80% today, according to the latest results from PPEC’s recently released Recycled Content Survey.

PPEC’s 2020 survey of Canadian mills that makes packaging grades found that the average recycled content of domestic Canadian shipments of the three major paper packaging grades – containerboard (used to make corrugated boxes), boxboard (used to make boxboard cartons), and kraft paper (used to make paper bags) – is collectively 81.7%, up from 73.5% in 2018.

Chart of recycled content

The survey results reinforce that recycled content is a key component of the Canadian paper packaging industry’s circular economy.

Mills produce the raw material used to make paper-based packaging – and the majority use 100% recycled content – which is sent to a converter, where it is made into packaging products. Once used by the customer, it is recycled – keeping raw materials flowing for longer – making its way back to the mill to be remade into new paper packaging products.

The majority of Canadians – 94% to be specific – have access to recycling programs; and not only do they have access, they actively and regularly recycle their paper-based packaging, with the national recycling rate for corrugated boxes estimated to be 85%.

This important act of recycling allows mills to continue to maintain their high levels of using recycled content in Canadian made paper packaging.

PPEC New Infographic 2021 - circular economy and recycled content

2020 PPEC Recycled Content Survey Key Findings:

Key findings from Recycled Content Survey
  • Total Canadian mill shipments: 3.37 million tonnes
  • Total recycled content shipments to domestic and export markets: 2.35 million tonnes
  • Average recycled content of domestic shipments for all three major packaging grades: 81.7%
  • Average recycled content for domestic shipments of boxboard, which is used to make cereal or shoe boxes: 79.8%.
  • Average recycled content for domestic shipments of containerboard, which is used to make corrugated shipping boxes: 86.5%

For more information on PPEC’s 2020 Recycled Content Survey please see our Press Release and Backgrounder.

Rachel Kagan

Executive Director Paper & Paperboard Packaging Environmental Council (PPEC)

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Ontario’s Blue Box Regulations Reflect PPEC Recommendations, Targets Still a Concern

On June 3, 2021, the Ontario Ministry of the Environment, Conservation and Parks released the final Blue Box Regulation. The new regulation sets out a framework to transfer the costs of the blue box program away from local communities and requires the producers to operate and pay for blue box services.

PPEC has been actively engaged in the government’s consultation process, providing input into the development of the regulation at every stage, as well as providing our formal comments in response to the draft regulation on December 3, 2020; which outlined our industry’s concerns regarding the government’s proposed targets and approach to recycled content.

Several changes were made to the final regulation as a result of the consultations, which are summarized in the Environmental Registry posting.

Of importance to PPEC and its members, the Ontario government reduced the paper diversion targets, and removed the recycled content proposal, in the final Blue Box Regulation.

Paper Targets Reduced

For the paper material category, the target for both 2026-2029, 2030 and beyond, was proposed to be 90% in the draft regulation.

In the final regulation, the proposed target for paper was reduced to 80% for 2026-2029, and 85% for 2030 and beyond.

While PPEC is pleased the government heard our concerns and reduced the target, we remain concerned that the targets of 80% and 85%, respectively, may not be achieved, as explained below and in PPEC’s blog post, Ontario Blue Box will struggle to make 60% diversion, and none of the ministry’s proposed new targets will be reached.

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.”

Blue Box diversion targets lower but still out of reach

While paper material is the single largest component of the Blue Box – with 67% of it currently being recovered for recycling – the composition of the overall paper category has been changing, which impacts the diversion rate.

Newspapers continue to see an overall decline as consumers choose to read the news online instead of in print – this decline in newspaper generation means less newspapers being diverted, since less are being collected in Blue Boxes, taking away from the overall paper diversion rate. While other categories – corrugated box diversion is 98% in Ontario – already have high diversion rates, leaving little room for any increase.

So as some materials within the paper category decrease, while others are already at high diversion rates, it begs the question of how will the overall paper diversion rate increase to meet the government’s new targets?

The hope is that a move to a more standardized system across the province will see better consumer participation at the household level – and at the end of the day, it is the consumer who makes the final decision of how they dispose of their waste and recyclables – so the more aware and educated they are, the more likely consumers are to properly source separate their waste and recyclables. This should help increase diversion, and hopefully reduce contamination levels – the higher the contamination, the harder it is to achieve better recovery rates.

But it all remains to be seen and PPEC will be watching the diversion data closely in the coming years.

Recycled Content Proposal Removed

The original proposal for recycled content in the draft regulation stated that:

    • The proposed regulation recognizes the use of recycled content sourced from blue box materials managed in Ontario that is incorporated into new products and packaging. A producer that uses recycled content sources from blue box materials would be allowed to reduce their supply for that material category for the next calendar year in proportion to the initiatives undertaken.
    • The proposed regulation would limit the overall reduction to no more than 50% for a material category. The proposed regulation establishes a formula for calculating a producer’s management requirement. The proposed regulation would ensure that the use of recycled content does not reduce overall diversion by redistributing the sum of recycled materials used in a given material category amongst all producers in that category.

In the final regulation, the government eliminated the recycled content proposal “to ensure that new provision can align with the federal intent to develop national recycled content standards.”

PPEC believes that recycled content is a key component of a circular economy, as it keeps raw materials flowing longer, reducing the need to extract virgin materials.

In our submission we explained our concerns with a mandated approach to recycled content: it only applies to the government’s jurisdiction i.e. Ontario, which could have international trade implications for material being shipped into Ontario; and it disregards that most design decisions on recycled content are often made at a global scale, not a local Ontario one.

We also felt that Ontario’s proposal would be administratively challenging in an already highly complex Blue Box program. In PPEC’s blog How about a different approach to recycled content and the circular economy?, we outline the advantages of looking at alternatives like a tax rebate or credit, as a way to support a Ontario recycling businesses and a more circular approach.

For now, we are pleased that the recycled content proposal has been removed, and we are proud that most of PPEC’s paper mill members already produce 100% recycled content boxes and cartons.

Special thanks to John Mullinder, PPEC’s long-standing Executive Director, for all his work in effectively representing PPEC members’ interests in working with the government on the development of the Ontario Blue Box regulation.

For more information, please see the Ontario government’s news release, Ontario Enhancing Blue Box Program, and the final Blue Box Regulation.

Rachel Kagan

Executive Director
Paper & Paperboard Packaging Environmental Council
(PPEC)

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Providing Clarity on The Ottawa Citizen’s Cardboard Recycling Article

Last week, The Ottawa Citizen’s Kelly Egan wrote an article about cardboard recycling in Canada. In Thinking inside the box — pandemic creates crush of new cardboard, Egan provides some stats about paper packaging recycling and the consumption of trees — some of which are correct, and some of which are confusing.

Egan reached out to the Paper and Paperboard Packaging Environmental Council (PPEC) for some information on paper recycling, and while he used some of the data we provided, PPEC was not mentioned in the article.

With regards to recycling, Egan wrote:

“Paper and cardboard are considered the success stories in the recycling world. Two main reasons: as much as 98 per cent (depends who’s counting) of corrugated cardboard is recycled and any “new” cardboard uses very high content of recycled fibre.”

Yes, paper and cardboard are indeed success stories, and PPEC and the Canadian paper packaging industry is proud of that. As for who’s counting, it is Stewardship Ontario (who operates the Blue Box program under the authority of the The Waste-Free Ontario Act, 2016) who is doing the counting. Ontario’s 98% recovery rate for corrugated cardboard, the most recent available data, is from the 2020 Blue Box Pay-In Model.

As for recycled content, most of the paper packaging material made by Canadian mills today is 100% recycled content, according to PPEC’s most recent Recycled Content Survey. Old corrugated boxes and cartons are collected through residential Blue Box recycling programs across the country, as well as from the factories and supermarkets, and used to create recycled content product.

Cardboard Recycling chart of the circular economy

Egan goes on to write about tree consumption:

While this is considered a shining example of the so-called circular economy, paper and cardboard production does gobble up a lot of trees, as per this snippet from a recent Washington Post story: “Global consumption of trees reaches roughly 15 billion each year, including three billion for paper packaging, according to the Environmental Paper Network. The industry relies on recycling virgin fibre — the basis of cardboard boxes — five to seven times, saving trees and improving the bottom line.”

The Washington Post story Egan is quoting from is How Big Cardboard is handling the 2020 box boom (December 30, 2020). But using a global figure about tree consumption, in an article about paper packaging in Ottawa, could lead to some unnecessary confusion.

When it comes to Canada’s trees, less than half of one per cent of our forests are harvested for pulp, paper and lumber uses each year. In 2018, the harvested area represented 0.2% of the total area of forest land, according to Natural Resources Canada. And by law, all forests harvested on crown land (over 90% of Canada’s forest land is publicly-owned) must be successfully regenerated.

Not that we use of lot of trees to make paper packaging to begin with. On average, the recycled content of paper packaging shipped domestically is 71 per cent; and the balance of Canadian paper packaging comes from wood residues – wood chips, shavings and sawdust left over from lumber operations – with only 11% coming directly from trees (roundwood pulp), according to PPEC’s The Truth About Trees members only Fact Sheet.

According to the Washington Post article Egan quoted from, virgin fibre is recycled five and seven times; but according to our information, paper fibres can be recycled between four and nine times in Canada.

And while Egan refers to the “so-called circular economy,” PPEC truly believes that we do have a circular economy for paper packaging. Our Paper Packaging Flow Chart shows the cycle of how our material is collected, sorted, and sent to recycling mills to make new packaging; illustrating the circularity in the manufacture and use of paper, a renewable, sustainable and recyclable resource.

Rachel Kagan

Executive Director Paper & Paperboard Packaging Environmental Council (PPEC)

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How about a different approach to recycled content and the circular economy?

Estimated reading time: 8 minutes

Recycled content is the key component in the creation of a circular economy. It keeps raw materials flowing within the economy longer, reduces the pressure to extract more virgin materials from the earth, and delays their eventual disposal as waste. Recovering more materials for further use also creates jobs. A circular economy is something that companies and governments say they want to encourage.

Recycled content and the circular economy
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Voluntary and Mandatory Approaches

The strategies to encourage recycled content range from voluntary approaches through to government mandated minimums and the threat of banning product sales if those minimums are not met.

With a voluntary strategy, the government adopts a hands-off approach, allowing the marketplace to determine what happens. In the Canadian province of Ontario, the paper packaging industry has gone from below 50% recycled content to all but one mill today producing 100% recycled content boxes and cartons. This is presumably the type of ‘’circular economy” that Ontario wants. The ‘problem’ is that the approach is slow. It took some 25 years to get there.

The mandatory approach, on the other hand, is where the government regulates or legislates a framework of minimum recycled content targets, with fines or penalties or sales bans for non-achievement.

One of the problems with government mandates, however, is that they apply only to that government’s jurisdiction. For example, an Ontario mandate would not apply to other provinces. There may also be international trade implications for material being shipped into Ontario. Another complication is that most design decisions on recycled content are not made in Ontario but rather at company head office (in the US or Europe) with packaging design undertaken at global not local (Ontario) scale.

Also, the last thing industry wants is provinces or states leapfrogging over themselves to set successively higher (and perhaps public relations inspired) targets for industry to achieve in different jurisdictions. A federal mandate would be preferable, but that would mean getting all provinces/states to agree (which may prove difficult and time-consuming). 

Mixed Approaches

Some governments have chosen to mix voluntary and mandatory approaches to increasing recycled content. They have done this by including incentives within regulated programs. The choice is voluntary and at a company’s own pace.

An example of this is the current suggestion by the Ontario Ministry of Environment, Conservation and Parks (MECP) where companies are offered discounts on Blue Box diversion targets when they can prove use of Ontario Blue Box recycled content.

This approach does have several benefits. It gets the government out of the role of playing policeman and sorting out the technical issues of how to actually set specific recycled content targets for different materials that are sensible and fair. It also means the province does not need to enforce the achievement of these targets because they are voluntary. The onus is on the brand owner/retailer/publisher to prove the claim, with the added expense of mandatory auditing of company reports.

Administratively challenging

The current Ontario proposal, however, is administratively challenging at best, and impossible at worst.

Let’s follow the path of some recovered Ontario Blue Box paper. First it goes from a municipality or a service provider to either a broker or a MRF (processor). That first step is relatively easy to track. Then it gets complicated. Because the broker and the processor have other clients, other suppliers of recovered paper fibre. It could be Blue Box fibre from Quebec or Manitoba; it could be used boxes and office paper recovered from industrial, commercial and institutional (IC & I) sources within Ontario or maybe shipped in from Manitoba or Quebec or the United States. It could be pre-consumer clippings and cuttings from those same disparate sources (Manitoba, Ontario, Quebec, the US).

The same diversity of sources applies at the mill level when the recovered fibre gets there from the processor. The mill is interested in the quality of the different fibres it uses to make its product, not in placing a special watch-out for the fibres coming in specifically from Ontario’s Blue Box program.

From all those different fibres, the mill (which may or may not be located in Ontario) makes board or paper that is shipped to converters who then turn it into the end-product (a newspaper, printing and writing paper, corrugated boxes, boxboard cartons and so on). These converters could be in Ontario or the US and they have other mills supplying them with other recovered fibre feedstock as well, making it very difficult to single out only those fibres coming from Ontario’s Blue Box.

More Complicated

It gets more complicated. A corrugated box comprises two parts (linerboard and corrugating medium). Each of these can be made from recycled content but each could come from different mills and be blended at the same or different converting plants. So, the medium of the box could have a portion of Ontario Blue Box fibres in it but the linerboard none. However, it’s all blended into one box for the customer. How do you keep track of that? And the customer (the brand owner/retailer) could be located in Canada, the US, Asia, Africa or Europe. And can ship the box anywhere in the world.

Tracing specific fibres such as from Ontario’s Blue Box once they enter the regional and international fibre recovery streams is thus extremely problematic. And what about corrugated boxes shipped into Ontario from China? They might have recycled content in them (which is a good thing) but not Ontario-processed recycled content.  What about old corrugated boxes that are collected through the Blue Box in Ontario but shipped across the border to the US for recycling there? There is no credit for the use of that Ontario-derived recycled content.

There are possible ways around some of these complications. If a mill can create a paper trail linking say 25% of its annual feedstock to Ontario’s Blue Box, then could 25% of its annual output be considered to be Ontario Blue-Box sourced? Could that 25% be pro-rated across all its customers? Or 25% allocated to those customers who are placing paper into the residential Ontario marketplace and therefore obligated under the Blue Box regulations?

Complete accuracy is not possible under the current proposal. And, as one insider has noted, it leaves lots of opportunity for fraud and gaming the system. Is there another way of looking at the problem?

How about a tax rebate or credit?

The current Ontario approach to recycled content seems unnecessarily complicated in a Blue Box program that is already highly complex. Recent research also indicates that EPR fees or adjustments for things like recycled content provide little incentive to brand owners to change packaging design or to influence consumer behaviour in purchasing.[i]

So why not look at an alternative approach (a tax rebate or credit) that focusses on supporting Ontario recycling businesses, on creating Ontario jobs, on companies that use Ontario Blue Box material as feedstock? Encourage them to enhance Ontario’s circular economy. Think globally but act locally.

The advantages are these:

  • The credit/rebate focusses on one thing only: increasing the use of recycled content in Ontario. It does not get cluttered or distracted by other waste management objectives (see the quotation from the Eunomia report to the EU commission in the footnote).
  • It can apply beyond the Blue Box (bringing in the IC & I sector) so it is broader in scope and in line with the province’s overall goal of a comprehensive waste management (and circular economy) policy.
  • It retains a voluntary approach with incentives for companies to act.
  • It applies to Ontario specifically but is transferable to other provinces (so could become national).
  • It doesn’t have to be in the current Blue Box regulation (greatly simplifying it).
  • Depending on how the credit/rebate is structured, the people who are actually building the recycling infrastructure in Ontario could benefit (the paper, plastic, glass and metal plants) rather than a brand owner head office in the US or Europe. It would make local (Ontario) businesses more competitive in what are global markets for recycled materials.
  • The credits could go to companies located in Ontario only (unless expanded across Canada). The system could therefore help keep existing industries in Ontario (meaning green jobs). For example, one paper packaging mill in Ontario (using 100% recycled content) recently closed.
  • It will create jobs (by encouraging recyclers to stay in Ontario and to invest in recycling infrastructure here).
  • It could have declining levels of tax credit (higher for sourcing from Ontario’s Blue Box, lower for feedstock imported from other jurisdictions).
  • It could be a joint governmental effort (Environment, Economic Development, Job Creation and Trade, Finance). Make Ontario the recycling hub of Canada or go for a national approach. A federal climate change project? We need to look beyond a narrow environmental approach, beyond our own provincial borders on this one. The idea needs work and it needs champions.

[i] From the Eunomia report for the Director General Environment for the European Commission: “It is better to focus a policy instrument on doing one thing well, than on seeking to achieve multiple objectives. A tension can be created within an EPR scheme if it is seeking to do too many things. A focus on seeking to meet recycling targets in a way that is cost-effective and fair to different packaging formats gives a clear steer to the way in which an EPR scheme should use fee modulation. However, to also introduce an incentive for recycled content can disrupt the efficient operation of the price signals.” (Study to Support Preparation of the Commission’s Guidance for EPR Schemes).