Paper-based packaging continues to be a success story in Ontario’s household Blue Box program, as measured by marketed tonnage, based on new data released by the Resource Productivity and Recovery Authority (RPRA), the regulator mandated by the Government of Ontario to enforce the province’s circular economy laws.
RPRA’s new Datacall Report summarizes information generated by the 246 programs participating in the Ontario Blue Box Program in 2021, and highlights residential waste management statistics and trends.
Overall, the program saw a decline in the provincial diversion rate to 49.1%, a stat the program has mostly hovered at for the past 10 years as shown in Figure 1 (all charts in this blog are from RPRA’s Datacall Report).
Diversion is measured after the collected material has been processed at a material recycling facility (MRF). So that essentially means that nearly half of what is placed in the Blue Box does not get recycled, which could be for a number of different reasons, such as contamination (food soiled materials, such as used yogurt or peanut butter containers, for example), materials that are not readily recyclable (e.g., hangers, toys), or residents not properly separating their waste and incorrectly placing non-recyclables (i.e. organics, waste) in their Blue Boxes.
Of interest to the Paper and Paperboard Packaging Environmental Council (PPEC) and its members is marketed Blue Box tonnage (Figure 3), which represents materials that have been sorted and processed by a MRF, and then baled, sold, and used in place of virgin materials.
These are materials that are actually recycled and paper-based packaging – which includes old corrugated cardboard, old boxboard, and a portion of residential mixed papers and mixed fibres packaging – leads the way in the most marketed materials with 289,689 tonnes marketed in 2021 (up from 271,433 tonnes in 2020), representing 39% of the total Blue Box marketed tonnage (736,379).
Paper-based packaging leads the way in the most marketed materials with 289,689 tonnes marketed in 2021.
The second largest material is printed paper – newsprint, household fine paper, telephone books, and catalogues – with 20% of marketed tonnes. However, this category continues to decline year over year as more homes go paperless (when was the last time you saw a telephone book?!).
Printed papers have experienced a nearly 66% decline in tonnage from 2016-2021, as shown in Table 4, while paper-based packaging has increased by 72.5% over the same period.
In analyzing the latest Ontario Blue Box data, it’s clear that paper is a success story. More than two-thirds of all paper that Ontario households generate is not just collected but actually recycled through Ontario’s Blue Box program. And much of the recovered paper fibres are supplied to PPEC member mills who use it to produce new paper packaging products, including boxes and cartons, made primarily of recycled content.
The Ontario Blue Box program begins its transition to a new producer responsibility regulatory framework starting this July, which will see producers take over 100% of the operational and financial management of the program by December 31, 2025.
There is no doubt that paper-based packaging will continue to be an important component of the Ontario Blue Box program – and PPEC expects to see a continued increase in paper packaging as brands shift from other types of packaging to sustainable, renewable, and recyclable paper-based packaging – but we will be watching the transition closely. The hope is that a shift to a producer responsibility will result in improved end markets, better sorting by residents, less contamination, and overall higher diversion and recycling rates in Ontario.
Collected Blue Box Tonnes: Blue Box materials that are collected curbside and/or at a depot.
Disposed Tonnes: Includes garbage and processing residuals from recycling and composting operations disposed at a landfill or incineration facilities.
Diverted Tonnes: Includes recycling activities, municipal organic collection and processing activities, provincial deposit systems for alcohol containers, residential on-property management and municipally operated reuse activities.
Generated Tonnes: Includes recycling, reuse and garbage material produced by Ontario residents; represents combination of disposed tonnes and diverted tonnes.
Landfilled residential material: Includes garbage Tonnes and processing residues; part of Disposed Tonnes calculation.
Marketed Blue Box Tonnes: Blue Box materials sorted and processed by a Material Recycling Facility (MRF) that is then sold and used in place of virgin materials.
Diversion Rate: Diverted Tonnes / Generated Tonnes x 100
There continues to be increased global activity and enforcement around environmental claims and greenwashing, the practice of making false or misleading environmental sustainability claims.
The U.S. is consulting on updates to its Green Guides, Europe is planning to introduce new laws to prevent greenwashing, and the U.K. is cracking down on net-zero claims.
Which leaves the Paper and Paperboard Packaging Environmental Council (PPEC) wondering where Canada is at in providing updated guidance on environmental claims.
In November 2021, the Competition Bureau of Canada – the independent law enforcement agency responsible for the enforcement of the Competition Act – archived its Environmental Claims Guide, leaving a gap in available resources for Canadian companies looking for clarity and guidance on the use of appropriate environmental claims in their marketing practices.
The FTC is seeking stakeholder feedback by April 24 in response to their consultation document, which outlines a series of 31 questions, including asking if there is a continuing need for the Guides, and if so, what changes should be made, as well as if updated guidance is needed for “recyclable” and “recycled content” claims.
And in the U.K., the Committee of Advertising Practice and the Committee of Broadcast Advertising Practice published an update to their environmental claims guidance, stating that companies should avoid using unqualified carbon neutral and net-zero claims. The Competition and Markets Authority also recently announced plans to examine the accuracy of environmental claims made about household essential items, known as fast-moving consumer goods, such as food, beverages, and personal care products.
Where Does That Leave Canada?
Canadian companies do not have current guidelines or updated resources for making environmental claims.
In November 2021, the Competition Bureau archived Environmental claims: A guide for industry and advertisers – which was prepared in 2008 by the Bureau and the Canadian Standards Association to guide industry and advertisers on environmental claims – stating that the document “may not reflect the Bureau’s current policies or practices and does not reflect the latest standards and evolving environmental concerns.” The guide continues to be available online for reference, but the Bureau stated that it would “not be altered or updated as of the date of archiving.”
In September 2022, the Competition Bureau hosted the Competition and Green Growth Summit to better understand the relationship between competition policy and business sustainability goals. While no policy directives were made, discussions were held on enforcement in a greener economy, while the Commissioner of Competition spoke about the role of competition policy in helping consumers make informed choices in his opening remarks. The Competition Bureau recently released a What We Heard document with a summary of the Summit.
In addition to the Competition Bureau activities, the federal government is also holding a consultation on the future of competition policy in Canada. The government is reviewing the Competition Act, including the role and powers of the Competition Bureau. The consultation ends March 31, 2023, and input will be used to inform the government’s next steps, including potential legislative changes.
And as part of the federal Zero Plastic Waste Agenda, the government announced that new labelling rules are being developed that would prohibit the use of the chasing arrows recycling symbol, and other recyclability claims on plastic packaging, unless specific conditions are met. These conditions may include that at least 80% of Canadians have access to recycling systems that accept, sort, and re-process such plastics. The government will publish a proposed framework for the plastic packaging recycled content and labelling regulations for consultation later this year.
When you add it all up, these separate but related activities signal the government priority of addressing environmental claims and greenwashing in Canada. But whether these activities result in potential changes to competition law, or the powers of the Competition Bureau, or new definitions related to “recyclability” remains to be seen, but it does not change the need for guidance on environmental claims.
It is clear that Canada, the U.S., Europe, and the U.K. are all taking measures to address greenwashing and the accuracy of environmental claims. But providing clear guidance and resources should also be a priority. Archived Canadian guidelines are not enough and PPEC encourages the Competition Bureau to provide updated resources on making environmental claims.
In the November 28th New York Times Magazine article, Where Does All the Cardboard Come From? I Had to Know, writer Matthew Shaer does a deep dive on what he refers to as the “cardboard economy” – everything from the history of who invented it, how it’s made, and its global marketplace.
First off, to us at PPEC, while “cardboard” is a commonly used term that we all understand – the box our deliveries come in – the industry terms are a bit different.
A corrugated box is made from strong paper fibres, comprising a top and bottom layer of paper fibre known as linerboard, and a middle layer, called corrugating medium, which is the wavy part that gives the box its strength.
Image of linerboard corrugating medium
While a boxboard or paperboard carton typically only holds a single item – i.e. cereal or shoes – it does not require the same strength properties as a corrugated box, so you won’t see any wavy ripples in those.
But back to the article. While it is mostly focused on the scale and size of the international market for corrugated packaging – which is expected to reach an estimated $205 billion by 2025, according to the article – it does refer to some of the environmental attributes of corrugated packaging, noting that it is “more recyclable than other shipping methods,” and even likens it to a classic fairy tale:
“Corrugated packaging has a Goldilocks quality to it,” says Tim Cooper, a project director for the market-research and testing firm Smithers. “It’s easy to produce, it’s strong and it’s sustainable, because unlike plastic, it comes from a renewable resource.”
We agree that it is strong and sustainable, but there is nothing fictional about the environmental sustainability of corrugated packaging. What Goldilocks needs to understand is that not only is it recyclable, it is actually and actively recycled, allowing it to be reused again and again.
Using recycled content is an inherent part of the Canadian paper packaging industry’s operations. PPEC member mills have been using recycled paper fibres for decades. It makes environmental and business sense to recycle and reuse old paper packaging, including Old Corrugated Cardboard, so it can be remade into new paper-based packaging products again and again, keeping valuable raw material out of landfill.
While the New York Times article reports on its high recycling rates in the U.S., it does not discuss the importance of recycled content, making it sound like boxes are made mostly from trees.
In fact, trees are mentioned in the article 16 times, while recycling is mentioned 11 times.
The sustainable management of forests, and what happens after consumers and businesses recycle their boxes is not mentioned, which may perpetuate the myth that paper-based packaging primarily uses trees in the manufacturing process, which is simply untrue.
In Canada, the average recycled content for domestic shipments of containerboard, which is used to make corrugated boxes is 86.5%, and nearly 80% for boxboard, according to PPEC’s Recycled Content Survey.
The remaining materials used in the mix include sawmill residues and some virgin fibres from responsibly sourced forests. But to be clear, the Canadian paper packaging industry doesn’t use much in the way of freshly cut trees, and the little that is harvested must be successfully regenerated by law. In 2019, the total forest harvest (for lumber and all paper grades including packaging) represented 0.2% of Canada’s forest land, according to The State of Canada’s Forests Annual Report.
We don’t take issue with the New York Times article itself, it is a well-researched piece on what has become a preferred packaging choice, and we expect there will be a continued shift towards paper-based packaging, especially as governments consider banning some types of materials, similar to Canada’s ban on single-use plastics.
But, articles like this should also talk about the critical role that recycling plays in the sustainability of the paper packaging industry. That must be part of any story about corrugated and paper-based packaging because it is an inherent part of our industry’s story.
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 through the important act of recycling.
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.”
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.
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.
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.
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?
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.”
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.
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.
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.
In June, the Ontario government released the final Blue Box regulation, which sets out the framework to transition to producer responsibility, and transfer the full operational and financial management of the Ontario Blue Box program to producers – the businesses that make and sell obligated materials into the Ontario marketplace – with implementation beginning in July 2023.
Source: Ontario Ministry of the Environment, Conservation and Parks
Since the release of the regulation, there has been lots of news that PPEC has been monitoring, summarized below.
GFL acquires CSSA and forms new Blue Box PRO
On July 6, GFL Environmental Inc., a North American waste management services company, announced it acquired the Canadian Stewardship Services Alliance (CSSA), and formed the Resource Recovery Alliance (RRA), in response to the Ontario government’s shift to full producer responsibility for the Ontario Blue Box program.
CSSA was established to provide management and administrative services to obligated producers, and Producer Responsibility Organizations (PROs), providing support for provincial recycling programs across Canada, including Ontario’s Blue Box program, currently operated by Stewardship Ontario.
GFL’s RRA will become a new PRO for the Ontario Blue Box program. In an article in Recycling Product News, GFL’s Patrick Dovigi talks producer responsibility and the Ontario Blue Box transition, he said that “The end goal of RRA in Ontario is, number one, to work collaboratively with all producers. Number two, it is to meet or exceed the recycling diversion targets set by the province in the most efficient and cost-effective way. With our experience, from collection to processing, we think we can be a value-added partner, not only to our PRO, but for other PROs and whoever else is involved.”
Under the new regulation, a PRO or group of PROs that has two-thirds of the producers of recyclables signed up, as measured by weight, can set the rules for the next iteration of the Ontario Blue Box program. Some are concerned that if GFL reaches that threshold, the recycling system would be managed by one large waste management company.
GFL is the fourth largest diversified environmental services company in North America with more than 11,500 employees. GFL’s recent earnings results show a 32% increase in second quarter revenue, with an estimated revenue of over $5 billion expected for 2021.
Stewardship Ontario responded to the GFL/CSSA announcement saying it is examining the acquisition announcement. Regarding concerns over protection of data, Stewardship Ontario’s response states that “CSSA has provided Stewardship Ontario with written assurance that, following the transaction, all Stewardship Ontario data will be held in confidence within RRA; will be used solely for the purposes of providing services under the current CSSA-Stewardship Ontario Services Agreement; and will not be accessible to GFL.” Stewardship Ontario will also consider if additional measures are needed to protect confidential data.
Industry forms a new Blue Box PRO: Circular Materials
On July 28, a group of 15 food, beverage and consumer products manufacturers, retailers and restaurants launched Circular Materials, a new, national, not-for-profit PRO to offer compliance services to companies obligated under EPR regulations in Canada.
The companies that founded Circular Materials include Costco Wholesale Canada Ltd., Empire Company, Kraft-Heinz Canada, Keurig Dr Pepper Canada, Lassonde Industries Inc., Loblaw Companies Limited, Maple Leaf Foods, McDonald’s Restaurants of Canada Limited, Metro Inc., The Minute Maid Company Canada Inc., Nestlé Canada, PepsiCo Canada, Procter & Gamble Inc., Restaurant Brands International, and The Clorox Company of Canada Inc.
And while Circular Materials is a national organization, in Ontario it will operate as Circular Materials Ontario. They plan to represent producers’ collective interests, with the goal of ensuring that the blue box collection system operates with fair cost allocation, an open and competitive procurement process, and producer-led governance.
In addition to Circular Materials and RRA, waste company Emterra Group also has its own PRO called Ryse Solutions Inc. Registered Blue Box PROs will be listed on RPRA’s website.
It will take some time to understand the implications of the GFL/CSSA deal, including transferring assets producers have invested in over the years, to a for-profit company; or how a waste management company PRO will compete with a producer-led PRO, and the difference in their approach and business model, but PPEC will be monitoring this closely.
Green visions, aspirational goals, and political grandstanding are all very well in their place. But at some point, we have to be realistic. The fact of the matter is that the overall waste diversion rate of Ontario’s Blue Box is unlikely to improve much over the next ten years, and the new diversion targets proposed by the Ministry of Environment, Conservation and Parks (MECP) will not be achieved.
These are the stark findings of a PPEC-commissioned study by Dan Lantz of Crow’s Nest Environmental. Lantz has more than 30 years’ experience in the waste and recycling industries.
The study examines Blue Box diversion patterns from the current program’s inception in 2003 together with industry reports on the future of given materials and an understanding of the capabilities of the recycling system and end-markets. To establish future generation and recycling rates, all on a per person or per capita basis to account for population growth, the study determines and applies mathematical formulas to predict whether Blue Box materials will meet the ministry’s two new proposed diversion target dates of 2026 and 2030. The answer is no, they won’t.
The data tell the story. In 2003, the generation of printed paper (mainly newspapers) represented almost half (47%) of the Blue Box materials in Ontario households. By 2019, printed paper’s share of generation had shrunk to 27%. Its share of what was diverted shrank too (from 61% in 2003 down to 30% in 2019).
At the same time, plastic packaging’s share of generation increased from 16% to 25% and its diversion share rose from 5% to 13%. These trends are expected to continue over the next decade and to impact diversion rates accordingly.
And while the ministry has wisely not specified a new overall Blue Box diversion target, its consultation papers make clear it would like to achieve somewhere between 75% and 80% within the next ten years. That’s not going to happen, says Lantz.
“Based on projections out to 2026 and 2030, the ministry’s targets are not realistic under the current program structure.’’ In fact, he says, unless something major changes like the Blue Box giving people more opportunities to recycle (say through an extensive depot network) and the public becomes more engaged and recycles far more than it does at the moment, then the Blue Box will continue to struggle to achieve the existing 60% diversion target into the future. He forecasts just over 58% diversion by 2030.
It’s important to note that the ministry is talking about diversion targets here, not collection targets. It is one thing to measure Blue Box performance by collecting materials at curbside and depots, as British Columbia does. But in Ontario, diversion is measured after the collected material has been processed at a material recycling facility (MRF).
The level of contamination can make a big difference as the higher the contamination the harder it is to achieve better recovery rates. So, BC’s performance (aided by the strategic location of some 250 collection depots) should not be equated with what Ontario is proposing.
Another complication is that the Ontario ministry wants more material diverted from a wider range of sources. This is fine, but broadening how much needs to be diverted (the generation base) automatically reduces the diversion rate as well, because unfortunately not all of that new source material will be diverted.
The only way the diversion rate would improve would be if the new materials achieve diversion rates above the average. Considering that some of the new materials proposed by the ministry for collection (including straws and plastic cutlery which will not be recycled at all because they are too small to be effectively captured and will just end up going to disposal), the diversion rate will not improve above what is projected in the Lantz report.
The province has not offered any estimates of how large this new supply of material will be, making it harder to calculate whether its proposed diversion rates are practically achievable or not.
90% for paper ‘just isn’t going to happen’
And if the ministry is expecting paper to ride to the rescue, forget it. Paper material is the single largest component of the Blue Box with 67% of it currently being recovered for recycling. The ministry’s proposed paper diversion target for 2026 and beyond, however, is 90%.
“Ninety per cent just isn’t going to happen,” says Lantz. There will be even fewer newspapers in future, more online and digital transactions (therefore less paper use), and very little opportunity for significant increases in paper recovery (corrugated box diversion is already at 98%, for example). This means the paper group as a whole will likely come in with a 69% to 70% diversion rate, he says. Far short of the ministry’s wished for 90%.
“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. Add in the fact that some Ontarians use paper with kindling to start their fireplaces and woodstoves in winter and burn paper, and it’s just not reasonable to expect a 90% diversion rate.”
Other material groups won’t make targets either
Rigid plastics (bottles containing water, soft drink, laundry detergent and shampoo, and mixed plastic tubs and lids, cottage cheeses and ice cream containers) currently have a diversion rate of 26 per cent. The ministry is targeting an improvement to 60% by 2030. Lantz predicts, however, that there will be little change over the next ten years, maybe an increase to 47 per cent.
As for flexible plastic packaging (currently at 8% and targeted for 40%), he says 15% may be as far as it gets, unless there is a dramatic shift to mono-materials (single-resin) flexibles, that is, stand-up plastic pouches that are much easier to capture and recycle. “Most plastics aren’t hard to sort in a material recycling facility. People just don’t put them in the recycling system like they should, and until they do, recycling rates will stay low.”
He predicts that steel and aluminum diversion through the Blue Box will improve to maybe 60% (missing the metals target). Glass packaging will also miss its target but maybe reach 75% diversion by 2030.
Many Factors
There are many factors that could influence these projections: pressure for higher recycled content levels; landfill bans or surcharges; alternative collection systems including deposit/return; and the impact of the extra tonnes the ministry wants collected from a wider range of sources.
There are also behavioural changes that could influence the results. “It often boils down to that flick of the wrist decision where the householder decides whether to put something into the garbage or into the box,’’ says Lantz. “We need to be much clearer about what goes where, and to give people more opportunities to make the right decision.”
Lantz suggests the province should set disposal targets instead, thereby reducing the burden on municipalities that have to handle the recyclables that householders place in the garbage. Environmentally, he says, it would be better if we reduced consumption at the front end. “Setting unreachable diversion targets that effectively allow unfettered consumption, and relying on recycling to overcome that consumption, is not the best approach.”
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