From the evolution of Extended Producer Responsibility (EPR) for packaging, to navigating potential regulations on PFAS use, and getting closer to receiving guidance on environmental claims, all while keeping an eye on the shifting political landscape. These are just a few of the issues the Paper and Paperboard Packaging Environmental Council (PPEC) will be focusing on in the year ahead.
Residential EPR for Packaging Evolving in Canada
Extended Producer Responsibility (EPR) – a policy approach where producers are financially and physically responsible for managing the recycling of their packaging – is at a pivotal moment in Canada.
Most provinces and territories have already enacted EPR legislation for residential packaging recycling programs (except for PEI, Newfoundland and Labrador, Nunavut, and Northwest Territories) and either have EPR programs in place, are in development, or are transitioning from the historical cost-share model (where municipalities run the programs and producers pay) to full EPR models.
By the end of this year, most provinces will have adopted full producer responsibility models for managing residential packaging recycling programs.
This shift to EPR will likely bring changes in how materials are collected, sorted, and baled, which could impact how they are processed and eventually sold to end markets – including PPEC member mills – who use them to make new packaging.
PPEC hopes that the evolution of EPR will lead to improved material recovery, reduced contamination, cleaner materials, and better residential recycling outcomes. This progress depends not only on the success of well-executed EPR programs, but also on residents doing their part by properly emptying and sorting recyclables.
Waste Management in the IC&I Sector
While PPEC supports efforts to increase recycling and waste diversion, we do not support an EPR approach for managing recyclables in the Industrial, Commercial, and Institutional (IC&I) sector, which includes offices, factories, malls, and other business settings.
Quebec is the first province to expand EPR into the IC&I sector as part of its recycling modernization efforts. The rollout begins this year with schools and outdoor public areas, and will gradually expand to the rest of the sector by 2030. However, many questions remain about how the program will operate – such as fee structures, material management, and potential impacts on existing waste management contracts.
In the IC&I sector, businesses are typically responsible for managing their own waste and recyclables, often through direct contracts with waste management service providers. When it comes to paper packaging, PPEC member companies are already taking responsibility by promoting the use of recycled content, while also serving as end markets by buying back used cardboard and paper materials from grocery stores and other commercial entities. These materials are then recycled and reused to create new paper packaging products.
Implementing EPR in the IC&I sector would introduce unnecessary complexity and disrupt existing systems, making it critical for PPEC to closely monitor Quebec’s rollout of this precedent-setting policy.
Monitoring PFAS Developments in Canada
Per- and polyfluoroalkyl substances (PFAS) are a class of chemicals used across various industries, and may be found in products such as firefighting foams, textiles, cosmetics, and some types of food-contact packaging.
The federal government has been working to address PFAS, proposing to regulate them under the Canadian Environmental Protection Act, due to their potential health and environmental risks. To support these efforts, the government recently completed a Section 71 survey notice to collect data on PFAS, which will be used by the government to inform their next steps.
It should be noted that understanding how PFAS may move through the recycling value chain, as well as how to treat and mitigate them, remains in its early stages. As an industry that relies on recycled content, we are committed to addressing this issue responsibly. PPEC is monitoring developments to ensure that our industry continues to support sustainability and recycling in an evolving regulatory landscape that may see future restrictions on the intentional and unintentional use of PFAS.
Greenwashing and Environmental Claims in Canada
In December 2024, the Competition Bureau issued Draft Environmental Claims Guidelines for consultation, following recent amendments to the Competition Act (via Bill C-59) that introduced new provisions targeting “greenwashing” — the act of making false or misleading environmental claims.
PPEC supports the development of clear, evidence-based guidance to help businesses make truthful, substantiated, and specific environmental claims. Canadian businesses have not had any guidance on making environmental claims since 2021, when the Competition Bureau archived its Environmental Claims: A Guide for Industry and Advertisers.
While this updated guidance is overdue and welcomed, it’s important to note that other jurisdictions are conducting their own reviews, including in the U.S., where the outcome of the Federal Trade Commission’s review of its Green Guides is still pending.
At a time when Extended Producer Responsibility is rolling out in the U.S. and expanding in Canada, changes to any recycling definitions need to be aligned across borders to ensure consistency and clarity for businesses navigating both Canadian and international markets.
Political Landscape
Lastly, PPEC is closely monitoring both Ontario and federal politics for any potential impacts on recycling and environmental policies.
In Ontario, the lieutenant-governor has dissolved the legislature, triggering an early election to take place on February 27, 2025.
Federally, the Canadian Parliament has been prorogued until March 24, 2025, to allow the Liberal Party to hold a leadership race. The next Canadian federal election is scheduled for October 20, 2025, but could take place earlier due to the evolving federal political landscape.
Elections can bring policy uncertainty, and businesses may need to prepare for potential regulatory changes.
PPEC is monitoring issues that could be impacted by election outcomes, including potential changes to Ontario’s Blue Box program under the Cutting Red Tape to Build More Homes Act, 2024.
Federally, the Zero Plastic Waste Agenda has impacts to packaging with its Single-Use Plastics Prohibition Regulations, the proposal for the development of recycled content and labelling rules for plastics, and the new Federal Plastics Registry, which could also be potentially impacted under a new government.
