Archive for EPR

Are we putting the cart before the horse when it comes to EPR in the IC&I sector?

The Paper and Paperboard Packaging Environmental Council (PPEC) monitors environmental issues impacting the Canadian paper packaging industry, especially recycling, since recycled paper-based materials are an important supply of our industry’s feedstock.
To that end, we track federal and provincial government activities on Extended Producer Responsibility (EPR), which is a policy approach in which a producer is made financially and physically responsible for ensuring their packaging is properly managed at the end of its life.
In Canada, EPR policies have been mostly applied to managing waste and recyclables in the residential sector – that’s you and I at home – while paper and packaging from the Industrial, Commercial, and Institutional (IC&I) sector is managed separately.
But lately, some provincial governments have been considering EPR approaches for managing paper and packaging materials from the IC&I sector, similar to the approach used for managing materials from residential sources, leaving PPEC to wonder if we are putting the cart before the horse when it comes to EPR and the IC&I sector.
Current State of EPR
Historically, paper and packaging recycling for residential communities has been provided by municipalities as part of their waste management services. And over the last few decades, several provincial governments passed legislation that legally require businesses who make and sell packaging to submit data reports and fund municipal recycling costs. These are known as “cost-shared” program models, wherein municipalities run the programs and businesses pay a portion of the costs.
However, over the past few years, there has been a shift to move towards EPR-based models, where businesses would be responsible for 100% of program operations and funding. If municipalities want to continue their role as a service provider, they would need to agree to terms set by industry; otherwise, industry will negotiate with waste collectors, haulers, and processing facilities directly.
This EPR model currently only truly exists in British Columbia but is being rolled out in other provinces within the next few years.
The above map shows the status of provincial recycling programs for managing residential paper and packaging, but what about paper and packaging from the IC&I sector…
Paper and Packaging in the IC&I Sector
In the IC&I sector – which includes office buildings, schools, hospitals, retailers, grocers, malls, stadiums, theatres, restaurants, and manufacturing facilities – businesses are responsible for managing their own waste and recyclables. This is typically done through business-to-business relationships, where businesses contract directly with waste management service providers.
But over the last few years, some provincial governments have been discussing the possibility of an EPR approach for the IC&I sector.
In fact, Québec became the first precedent-setting province to regulate EPR for managing IC&I materials. It came as part of their move to modernize the existing recycling system for packaging, with the full rollout of the new EPR system for curbside residential and IC&I expected to be completed by January 1, 2025.
British Columbia’s EPR Five-Year Action Plan states that the government is evaluating opportunities and policy options related to improving the recovery and recycling of packaging and paper in the IC&I sector. That does not necessarily mean British Columbia will implement an EPR approach for IC&I, but it does appear to be something they are potentially considering.
And lately, other provinces that have been consulting on establishing new EPR approaches for residential waste streams have also been considering whether to include some IC&I sources of waste in future EPR programs.
PPEC’s Perspective 
While PPEC supports increased diversion and recycling of paper packaging materials from all sectors, IC&I included, we believe that EPR is not necessarily the right overarching policy approach for managing these materials, especially since they are currently being collected and recycled in many jurisdictions across Canada.
First, we can’t assume the same approach used for residential will work for the IC&I sector, as they are two very different and distinct waste streams.
Second, we question if EPR, as it is currently structured and understood, is working as effectively and efficiently as it could be for Canada’s residential Blue Box programs. It may be premature to suggest that the model is right and should be considered for other sectors. The reality is only one province, British Columbia, currently has a true EPR model; while other provinces are in the midst of transitioning programs to EPR or are just starting to develop new programs. It will take time to see if these shifts to EPR result in improved consumer participation, less contamination, better program performance, and overall higher recycling rates.
And third, producers are already taking responsibility for managing their waste and recyclables in the IC&I sector. We know materials are being recycled in the sector as we see it happening firsthand in our industry every single day. Most PPEC member mills use recycled paper packaging materials, including cardboard – collected from commercial and residential sources – as their primary feedstock, allowing them to use high amounts of recycled content in the major paper packaging grades made in Canada. In many cases, PPEC members have their own recycling divisions to make sure they have a good supply of recycled paper fibres that they rely on. Using recycled content is an inherent part of the Canadian paper packaging industry’s operations, and it has been that way for decades.

Bales of Old Corrugated Containers (OCC), collected from commercial sources and processed at the Cascades Recovery+ facility in Scarborough, Ontario, are ready to be sent to a mill, where they will be recycled so they can be remade into new paper-based packaging. Photo taken by PPEC on April 14, 2023.

The Need for Data
It is important that any policy considerations or future decisions be based on sound data. As we stated earlier, paper and packaging in the IC&I sector is already being collected and recycled as businesses contract directly with waste management service providers to collect and recycle their packaging and shipping materials.
PPEC reviewed the latest available data from Statistics Canada’s Biennial Waste Management Survey, which tracks waste diversion from the IC&I sector, and it shows that paper fibres lead the way when it comes to diverted materials from non-residential sources (which includes both the IC&I and the Construction, Renovation and Demolition sectors), with 1,954,655 tonnes of paper fibres diverted in Canada in 2020, representing 46% of total diverted materials (4,214,742 tonnes based on available information) from non-residential sources.

And when it comes to provincial performance, the data shows that several provinces divert more paper fibres from non-residential sources (orange line) than from residential sources (blue line).

We recognize that this data is not perfect, but the trend is encouraging, showing that paper fibres from non-residential sources are being actively recycled and diverted from landfill in Canada.
But we know that not all paper fibres are being diverted.
According to the Government of Canada’s National Waste Characterization Report, the main waste categories in the IC&I sector in 2016 were food and non-degradables at over 60%, while the category of paper represents 14% (though no information is available to describe the composition of the paper waste).
Average national characterization of waste from the ICI sector in Canada in 2016
The data is piecemeal at best. To gain a better understanding of current IC&I waste diversion activity, better data is needed to inform policy discussions.
Key Takeaways and Next Steps
To develop effective strategies and policies for IC&I waste diversion, data is needed. We need to know the statistics about waste in the IC&I sector – how much is being generated, recycled, and disposed of, as well as the composition and types of materials – to be able to identify opportunities to increase recycling.
The existing data is not complete, but it does broadly illustrate what PPEC believes to be true for the Canadian paper packaging industry: that the major paper packaging grades, such as containerboard (used to make cardboard boxes) and boxboard (used to make cereal or shoe boxes), are being collected from the backs of supermarkets, malls, and factories, and being responsibly recycled and diverted from landfill. We know this because using recycled content is an inherent part of our members’ operations.
And when it comes to EPR and IC&I, our message to governments is clear: do not put the cart before the horse.
Let’s not assume that the same approach for residential recycling will work for the IC&I sector since they are two different waste streams. And let’s not assume we have the right formula for EPR.
In many ways, EPR for residential paper and packaging is in its infancy in Canada, with only British Columbia currently having an EPR approach, while other provinces are transitioning to producer responsibility models. It will take time to see if these shifts result in higher recycling rates and more efficient and effective systems.
Let’s get EPR for residential right first before we even consider applying it elsewhere. Getting it right means that consumers understand their important role in properly recycling. Getting it right means focusing beyond just collection, and recycling more of what is being collected. Getting it right means having end markets consistently available to ensure materials are being recycled.
In the meantime, PPEC will be watching Québec closely as the precedent-setting province that regulated an EPR approach for managing materials in the IC&I sector; and we will continue to encourage governments to collect updated data to have informed policy discussions; while we keep promoting our industry’s circular economy approach to managing paper-based packaging materials in Canada.

Rachel Kagan

Executive Director Paper & Paperboard Packaging Environmental Council (PPEC)

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What PPEC will be Watching in 2023

As the Paper and Paperboard Packaging Environmental Council (PPEC) continues to work on achieving its mission to promote the environmental sustainability of the Canadian paper packaging industry, we will also be closely monitoring the following key issues in 2023:

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 and physically responsible for ensuring their products and packaging are properly managed at the end of their life.
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 consumers – such recycling programs are critical as they are an important supply of our industry’s feedstock, allowing PPEC members to use high amounts of recycled content in the three major paper packaging grades.
This year will be busy with changes to existing programs and government consultations, and PPEC will be closely monitoring and participating in consultations. For more information on EPR for paper and packaging, and the status of provincial programs, please visit PPEC’s new EPR web page.
EPR also continues to ramp up across the border with several U.S. states enacting or developing packaging producer responsibility laws including Maine, Oregon, Colorado, and California. PPEC follows the activities of the American Forest and Paper Association and the Fibre Box Association to stay informed about U.S. EPR activity.
Landfill bans
As part of the Government of Canada’s commitment to reduce emissions by 40 to 45% below 2005 levels by 2030, and achieve net-zero emissions by 2050, they are looking at ways to reduce methane emissions from municipal solid waste landfills.
PPEC has long supported banning old corrugated boxes from landfill as it would reduce methane and ensure that valuable materials are diverted and recycled.
When organic waste – such as food, yard waste, and paper products – is disposed in landfills, it produces methane, a greenhouse gas.
A landfill disposal ban is a tool that stipulates that certain materials are not accepted for disposal; they are often used when there is a recycling program in place for that material. For example, Nova ScotiaPrince Edward Island, and Metro Vancouver have banned corrugated cardboard from their jurisdiction’s disposal sites.
The bottom line is that used boxes should not end up in landfill. Recycled paper packaging represents our industry’s feedstock as it is continually collected and recycled through residential and business recycling programs, allowing those materials to be remade into new paper packaging products 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 produced with recycled content, the paper fibres it was originally made from came from a tree. However, 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, which is published annually by Natural Resources Canada.
The 2022 Annual Report was recently released and is a key source of data on Canada’s forests and its sustainable management, which PPEC uses to correct misinformation about the Canadian paper-based packaging industry.
PPEC continues to monitor government activity related to PFAS, or perfluoroalkyl and polyfluoroalkyl substances, which are a class of chemicals that, in some cases, have been found to be potentially harmful to the environment and human health.
As perfluoroalkyl substances can provide oil, grease, and water resistance, PFAS can be found in some types of paper-based food packaging.
The Government of Canada is currently considering activities that would address PFAS as a broad class and published a notice of intent in the Canada Gazette. In the U.S., several states have passed laws banning intentionally-added PFAS in packaging. New York’s new law took effect December 31 and prohibits the intentional application of PFAS in packages or packaging components designed for direct food contact, which can include wrappers, bags and tubs that are made from paper, paperboard, and other materials derived from plant fibres.
Environmental Claims and Definitions
The issue of greenwashing continues to be an increasingly important priority of enforcement agencies across North America and globally. In Canada, environmental claims are overseen by the Competition Bureau who archived its enforcement guidelines on environmental claims last year. In the U.S., the Federal Trade Commission oversees consumer protection and competition issues, and is currently consulting on potential changes to their Green Guides which provide guidance on the use of environmental and recycling claims. And in Europe, the European Union is apparently reviewing the definition of what counts as “recyclable” as they look to overhaul their packaging waste law.
Given recent enforcement activity surrounding environmental claims, and confusion around some of the terminology – recovery, collection, recycling, diversion, end markets – PPEC will be looking to address some of the issues with definitions, how it impacts data, and how they relate to environmental claims over the next year.
Carbon and Climate Change
PPEC continues to monitor government and industry climate change and carbon reduction initiatives. While paper-based packaging is highly recyclable and recycled across Canada and made from a renewable resource using sustainable forest management practices, we are currently gathering available data related to carbon emissions of paper packaging material.

Rachel Kagan

Executive Director Paper & Paperboard Packaging Environmental Council (PPEC)

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Key decisions looming on Canada’s Blue Box EPR programs

North America’s first full producer responsibility EPR program for the Blue Box has been running for over a year now in British Columbia, with positive results. Will Ontario and the other provinces follow suit? Will they have the political wherewithal to effectively address the key issues of free-riders and producer control?

The paper industry has a major interest in these matters. Some 75% of the material collected in Canada’s Blue Box systems is paper of one kind or another, most of it used again and again as feedstock to produce new printed paper or packaging. Paper products provide more than half of all Blue Box revenues.

But the Blue Box is only part of the story. Canada’s recycling mills rely far more on the collection of old corrugated boxes from the back of factories and supermarkets, and on the used printing and writing paper collected from offices. The infrastructure to recycle this material has existed for years.

This is why it is so important that the provincial politicians who make decisions on who controls the Blue Box, make them based on overall need, not just on what municipalities say they want or are lobbying for. There are economies of scale to be achieved by better coordinating the location and capacities of all transfer stations and material recycling facilities (MRFs) in a province, whether they cater to industrial, commercial and institutional recycling or to what comes out of people’s homes. Too many MRFs, with all the same bells and whistles, is a recipe for financial disaster.

PPEC’s upcoming seminar on October 28th couldn’t be better timed. The speakers include:

GlenMurrayGlen Murray, Ontario’s Minister of Environment and Climate Change. The minister has promised to introduce new waste reduction and resource recovery legislation to Ontario. This will impact all waste streams and recycling in the province. Here’s your chance to hear the minister explain, in person, the major thrust and intentions of the new legislation.


DLPicDan Lantz
, COO of Green by Nature EPR, which processes the residential materials from all of BC’s recycling programs. How is North America’s first full producer responsibility program working? What can we learn from it? Do we want it to be applied in other provinces? What are the implications for the paper, glass, plastic and metal industries?

RobertChantBob Chant
, VP Corporate Affairs and Communication at Loblaw, who represents Canada’s major grocery retailer on several producer-related bodies, including the industry funding organisation for Ontario’s Blue Box program, Stewardship Ontario, and its parent, the Canadian Stewardship Services Alliance (CSSA). What’s the retailer perspective on EPR in Canada? How are they handling the conflicting demands and range of programs across the country? What do they see as the key decisions to be made going forward? What are the implications for the material sectors?

DennisColleyThe seminar will be rounded out by an American perspective from Dennis Colley, President of the Fibre Box Association, representing the US corrugated box industry. What is the status of the EPR debate in the US, and what are the implications for the paper industry there?


For more details on this timely seminar, click here.

To register for this event please click here.

CCME’s false claims perpetuate packaging myths

We were recently invited by the Canadian Council of Ministers of the Environment (CCME) to comment on various aspects of extended producer responsibility (EPR) programs that have been, or are being introduced across the country. In the course of preparing our response, we re-read CCME’s Canada-Wide Strategy for Sustainable Packaging. While we have no problems with most of this interesting document, we were stunned to discover some factual errors that could help explain why packaging in particular, and industry’s waste management performance in general, continue to be held in such low regard in certain government circles.

In setting the context for this 2009 strategy document, CCME makes two claims: that “Current recovery rates for packaging are very low” and that “Statistics Canada (2006) data indicates the national recycling rate is 22 per cent[1].”  It gives the source for these claims as Statistics Canada’s WMIS survey of 2006[2].


Unfortunately for CCME, neither of these claims was true then, or is true now. Statistics Canada’s WMIS surveys do not break out recovery rates for packaging, and never have, so how could they be “very low”? Nor do WMIS surveys break out national packaging recycling rates. CCME has totally misread what the WMIS surveys say. The supposed 22% national “recycling” rate for packaging that CCME claims is actually the diversion rate for all of the following wastes added together (paper, glass, metals, plastics, electronics, tires, construction renovation and demolition materials, and organics)[3].

We pointed out these factual errors to CCME staff, expecting that they would check to see if we were correct, and then, if we were, amend and/or remove the claims from the document. This after all is an official publication available on the CCME website that is used as a current source of information by researchers and students, among others. As long as these false claims are there, they will continue to damage public perceptions of the packaging industry and its customers, and they will continue to colour government policy and claims on packaging issues.

The CCME staff response to date has been to fob us off, to claim that we have “differing interpretations” of “decade-old data” that was used to provide a portion of the context for CCME’s work on EPR. We disagree. The claims that the CCME is making in this document are either right or wrong. Whatever happened to “fessing up”, making the appropriate corrections, and moving on? This does not look good on the CCME. Canadian public policy should be based on accurate data, not false claims that perpetuate myths[4].


[1]A Canada-Wide Strategy for Sustainable Packaging, CCME, October 29, 2009, page 3.

[2] Statistics Canada, Waste Management Industry Survey: Business and Government Sectors (WMIS 2006). Catalogue no. 16F0023X.

[3] Table 2, WMIS 2006.

[4] Ironically, a survey that CCME commissioned specifically on packaging many years ago would have set a more accurate context for discussion of EPR. The 1996 National Packaging Survey conducted by Statistics Canada did establish recovery rates for packaging (over 70% re-use and recycling); and did establish a national recycling rate (45%). But one gets the distinct impression that CCME prefers not to talk too much about this study, partly because its data is now old, but also because it found that “industry” (bad guy that it is), was performing quite well thank you very much.