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A new discussion paper released last week provides a potential road map for the Ontario government to begin the transition of the Blue Box Program to full producer responsibility. 

On Dec. 6, Usman Valiante, Senior Policy Analyst at the Corporate Policy Group, released his proposal, A Practical Pathway to Producer Responsibility for Paper Products and Packaging in Ontario, which he also discussed in his presentation at the 2016 Canadian Waste to Resource Conference.

This discussion paper outlines how to move from Ontario’s current Blue Box Program to a system in which producers fully finance and manage the collection and processing of printed-paper and packaging (PPP).

Valiante’s objectives are to ensure a “seamless transition” by minimizing disruption to collection services and investments in equipment and facilities while incrementally providing more responsibility to producers. 

These goals align with the priorities that Premier Kathleen Wynne laid out in her mandate letter to Environment Minister Glen Murray. In it, she stresses the need to ensure the Blue Box Program “and the revised role of municipalities will not negatively impact Ontarians’ experience with and access to blue box services.”

To reduce and prevent disruption in the marketplace and for Ontario residents, Valiante recommends that the transition to full producer responsibility “should occur without having to modify or terminate existing municipal contracts.”

Producers should continue to fund municipalities under the 50/50 cost-sharing formula until these contracts expire, Valiante says. Once there are no longer any contracts under the old system, the Blue Box Program and Stewardship Ontario could be “wound up.”

At this point, the government could establish a new producer responsibility regulation under the Resource Recovery and Circular Economy Act.

The government has already indicated that this regulation would make individual producers responsible for:

  • meeting collection and processing standards;
  • record-keeping and reporting to the Resource Productivity and Recovery Authority; and,
  • and promoting and educating the public about resource recovery and waste reduction. 

As Valiante points out, “while individual producers will be responsible under the RRCEA, no single producer can practically deliver curbside collection to 4.9 million households.”

So by necessity many producers will form producer responsibility organizations (PROs). To maintain consistent services for Ontarians, Valiante says, the province must establish rules “for sharing the common household collection system” among different PROs that comply with Canada’s Competition Act.

Making all these changes happen properly will require a clear plan and plenty of stakeholder consultation. Valiante notes that it will be “critical” to have a “predictable” timeline “for the transition of responsibility for collection and management of PPP from municipalities to producers” to help businesses and municipalities make necessary decisions about investment in equipment and facilities.

Still, the timing to develop a new regulation for Blue Box waste remains uncertain. The government has said the transition may take two to four years to begin, leaving the start date as late as 2021.

However, over the next few years, Valiante says, the transition of Ontario’s other recycling programs for e-waste, used-tires and household hazardous materials will provide an example to assess before the “more complex” transition of the Blue Box Program.

Any changes to the Blue Box Program will come with potential risks for both private and public members, so this proposal should be reviewed carefully to assess both its risks and opportunities. To download a copy, click here

We understand the Association of Municipalities of Ontario is in the process of developing a similar discussion paper, which will be released shortly. The OWMA is currently working through its committee structure to provide feedback.

If you have any comments or questions, please call our office today at (905) 791-9500.