Layout Image

Stewards need to rethink how they pay for the Blue Box

John Mullinder, Executive Director

One of the prime aims of the Ontario government when it passed the  Waste Diversion Act of 2002 was to regulate and secure industry funding for the province’s popular Blue Box program. The deal, a typical political compromise, was for Blue Box financial responsibility to be shared 50/50 between industry stewards and municipalities.

The hoped-for results were for the Blue Box to become more efficient and effective; to achieve a waste diversion target of 60 per cent; and to reduce the amount of printed paper and packaging ending up in Ontario homes. At the time, the Ministry of Environment claimed that the industry funding formula would encourage companies to use less packaging or recyclable materials; that stewards would pay lower fees when products were packaged in materials that were easily recycled; and that there would be “less and less non-recyclable materials used in packaging” in the future.[1]

Ten years later, we are all much wiser. And many of the fundamental parameters of Ontario’s Blue Box system have changed. Out of necessity, we need to adjust.

For starters, we should recognise that the current 50/50 cost-sharing deal is not an Extended Producer Responsibility (EPR) program at all. It is a financial arrangement. True or full EPR means producer (not municipal) control.[2]  And if the Blue Box is to be 100% industry-funded in future (as some municipalities would like) then it should also be 100% industry-controlled. Currently in Ontario, industry stewards make financial payments but have little or no control over which materials are collected, or how they are collected and processed. A new financial and operational plan needs to be developed (by the stewards who are paying for it), with the province first providing an appropriate overarching policy framework or direction.[3]

BlueBox10If the producers are fully responsible, financially and operationally, then they will be in a better position to reduce the net cost of the program, which has ballooned by almost 70% since 2003.[4]  Today, we do have a pretty good idea of how much it costs to collect and process Blue box materials. But there is a growing disconnect between how stewards pay for that (the funding formula) and the changing nature of the Blue Box system and its material composition.

The current weight-based formula is unfair and outdated.[5]  On a weight basis, the material that ends up in Ontario households is actually slightly lower than it was in 2003. But this is because bulky newspapers have taken a hit from competing digital media and because telephone books are pretty much disappearing. On the packaging side, some of the heavier glass and steel beverage containers have lost out to lighter plastics, whose generation, on a weight basis, is up an amazing 22% over the period. [6]

There has been uneven progress on recycling rates as well. Printed paper, corrugated boxes, and glass bottles have the highest diversion rates (between 85% and 96%) while plastic packaging has made little
improvement (some 73% of it still goes to landfill). And this is the more expensive material to recycle.[7]   As well, the advent and adoption by most large urban municipalities of single stream collection, where all materials are thrown together at curbside and sorted out later at a material recycling facility or MRF, has served to downgrade material quality and revenues. The cost for a single stream system is about 30% higher than the traditional two-stream system it replaced, so not only has its introduction contributed to higher net Blue Box recycling costs, it has also meant that some of the resulting commingled materials have been sent offshore rather than being used as a feedstock by Ontario recyclers.

The predominant material in the Blue Box used to be old newspapers (ONP), with the highest quality grade (#8) being left on the conveyor belt at a MRF and other materials charged the costs of being separated from it (called a positive sort). Today it’s different. A decline in newspaper sales, coupled with steady growth in corrugated and boxboard packaging (not to mention PET plastic thermoforms), and the widespread adoption of single stream processing, have made it increasingly difficult for MRFs to reduce contaminants and out-throws to meet the quality requirements of # 8 News. Many MRF operators, in fact, are giving up on producing the more valuable # 8 News grade and taking a price hit. The City of Toronto and Region of Durham, for example, no longer request #8 in their processing contracts.

These new realities of the marketplace and how MRFs handle them are cogent reasons why the current funding formula needs to be reviewed. At the moment, printed paper and packaging costs are treated separately, in different cost silos. There is also cross-subsidisation between materials in the packaging silo to preserve what’s called a “basket of goods” approach.[8]  The problem now, however, is that the nature of that basket has changed significantly, raising the larger question: how, in today’s predominantly single stream Blue Box system, do you properly allocate costs using the old “basket”?

In summary, what we have in Ontario is an increasingly expensive Blue Box system over which stewards have little control; major changes in Blue Box composition (less paper and more, and lighter plastics); and greater overall contamination with resulting lower revenues. We also have a funding formula that allows cross-subsidisation within the individual silos of packaging and printed paper but not between them (even though all Blue Box materials are now mostly collected and processed in virtually the same way: single stream).


We have a suggestion which takes these various market and process changes into account. How about a funding formula that is material-neutral, that does not pit one material against another, and which allocates costs fairly, reflecting the actual effort to recycle it? A unit-based formula. The time and effort taken to process materials as they speed down the conveyor belt in a MRF is relatively easy to monitor. Stewards are already measuring their product sales by the unit, or thousands of units. And Canada’s many deposit programs operate this way as well, basing their fees not on the weight of their packaging, but on their unit cost. Why not allocate all Blue Box recycling costs on a per unit basis? You don’t have to convert sales to weight and then come up with something as incredibly complicated and outdated as the funding formula we have now. A unit basis is simple and effective.

We would urge the Canadian Stewardship Services Alliance (which controls Blue Box program plans in British Columbia, Saskatchewan, Manitoba and Ontario) and Éco-Entreprises Québec (which funds a similar program in Québec) to seriously consider this alternative. It’s time for a change.




[1] Ontario MOE, Ontario’s 60% Waste Diversion Goal-A Discussion Paper, June 10, 2004, page 28. PPEC has consistently challenged several of these claims made for the funding formula. How it is intended to work and how it actually works are two different things. For example, PPEC pointed out that zero recovery in many cases was far less expensive for stewards that 60% recovery because the fee structure was so closely tied to the net cost of managing individual materials. Generally speaking, the more material managed, the higher the cost, and therefore the higher the fee.

[2] “EPR programs will require producers to take financial and/or physical responsibility for their packaging at the end of the packaging’s life cycle, shifting responsibility away from municipalities.” A Canada-Wide Strategy for Sustainable Packaging, Canadian Council of Ministers of the Environment, October 2009, page 1.

[3] The Elephant in the Room, PPEC blog, December 19, 2013.

[4] The Blue Box net system cost in 2003 was $117.5 million. In the latest data year (2012) it had reached $198.0 million (Comparison of Stewardship Ontario, Table 2: Gross and Net Costs for 2003 and 2012).

[5] Waste Diversion Ontario warned the minister in April 2004: “Given that fees paid by stewards are tied in large measure to the cost of managing each type of material recovered, there is a potential for a growing inequity in the fee rates (italics added) paid by stewards of materials with the lowest recycling rates who could not be making a fair contribution to total system costs” and that “Under the current weighting factors in the formula, those materials with the highest recycling rates … will attract the highest costs.” (WDO response to the minister, 60% Diversion of Blue Box Waste, Material Specific Targets, Municipal Benchmarks, April 30, 2004, Sections 5.2.2 and Section 5.1.2). See also footnote 1 above.

[6] Stewardship Ontario Blue Box data for 2003 and 2012 (Tables 1 and 2).

[7] Stewardship Ontario Blue Box data (2012).

[8] The “basket of goods” approach was adopted by Stewardship Ontario to both preserve the right of stewards to choose the packaging material they wanted, and to reflect the fact that many stewards used more than one packaging material to get their goods to market. The current funding formula does attempt (unsuccessfully in our view) to address the issue that some materials are less costly to recycle than others.

Is this a turning point for the world’s forests?

John Mullinder, Executive Director

Actions always speak louder than words but a document coming out of the UN climate summit last week has the potential to halve the world’s natural forest loss within six years, and to end it within sixteen.

The New York Declaration on Forests is a non-legally binding political agreement that has been endorsed by 32 national governments, including Canada[1] ; 40 major corporate FORESTS-New-York-Declaration-on-Forestsenterprises (including General Mills, Johnson & Johnson, Kellogg’s, McDonalds, Nestle, Procter & Gamble, Sobeys, Unilever and Walmart); 16 indigenous peoples’ organisations; and some 49 environmental groups (including the Environmental Defense Fund, Forest Ethics, Natural Resources Defense Council, Rainforest Alliance, Sierra Club and WWF). Enough fire power one would think to make sure something happens.

About 13 million hectares of forests (mostly in tropical countries) continues to be lost every year, mainly because of the clearing of land for commodities such as soy, palm oil, beef and paper. Infrastructure, urban expansion, energy, mining and fuel wood collection also contribute in varying degrees. What the endorsers are promising to do is to work together to eliminate or significantly reduce deforestation and to restore existing degraded landscapes and forest lands. Collectively, the backers claim their efforts could save between 4.5 billion and 8.8 billion tonnes of carbon emissions per year by 2030: the equivalent of taking all the world’s cars off the road. Forests represent one of the largest, and most cost-effective climate solutions available today, claims the document. Take a look at the work already underway or pledged. It’s impressive.



[1] Canada is regarded as a global leader on many forestry issues. Its net deforestation rate is minimal (0.01%) and it contains almost 40% of the world’s independently third-party certified sustainable forests.
P.S.  Don’t forget PPEC’s half-day seminar Paper Facts and Fiction November 12. More details here.

Boxes, boxboard, paperboard, folding cartons, cardboard: whatever you call it, we have them covered

John Mullinder, Executive Director

We have just launched a new website on the environmental attributes of paper boxes, but boy did we have a time before settling on what exactly to call it. You wouldn’t think there could be so many different names for what basically is a similar type of packaging material, but it’s a fact. There’s boxes, boxboard, paperboard, cartons, and these are just some of the terms used by industrylogopaperbags folk. Throw in the general, more public catch-all phrase of cardboard, and you can see why people get totally confused (What do you mean “cardboard” doesn’t exist?).

We finally settled on paper boxes because that is what they are made from, paper. And the thin lightweight paper box that we are talking about here is quite structurally different from its cousin, the heavier and stronger corrugated box. Huh? What’s a corrugated box?

Anyway, we now have four websites to get you all straightened out. This site (PPEC) provides general environmental information about paper packaging in Canada. If it’s paper bags you are interested in, you can get more specific info at If you want to know what corrugated means, go to And if you need specific information on Canadian paper boxes or cartons or boxboard or paperboard (!) then this is where you should click ( For those of you who are cardboard-inclined, you have a choice: the corrugated box site or the paper boxes Canada site!

The aim is to provide customers and consumers with easy access to the most accurate, concise and current environmental information possible. Each site outlines the common uses of the packaging type; what it’s made from; how it’s made; where it’s made; plus information on the industry’s use of renewable resources, recycled content, recyclability, compostability, and public policy issues. There’s even a quiz. We’d appreciate your feedback and any suggestions for improvement.

Plastics’ burning ambition and paper’s feedstock supply

John Mullinder, Executive DirectorThe plastic industry has made no secret of the fact that it would like to burn over a million tonnes of currently “non-recycled” plastics in Ontario alone[1] . In strategic terms this would remove a major solid waste problem (some 73% of residential plastic packaging in Ontario, for example, ends up in landfill)[2] , while at the same time provide a feedstock for the energy-from-waste (EFW) plants the plastics industry would like to see built. Better to burn the stuff and get some energy from it, rather than just send it to the dump, the argument goes.

It would be hypocritical of the paper industry to be opposed to energy-from-waste as a technology. After all, kraft paper mills convert parts of the tree that can’t be used to make paper into energy to power their operations; and several mills also use the residuals of municipal solid waste as an energy source. We will leave it to others to comment on the air pollution aspects of EFW plants, and on how much, if any, taxpayers’ money should be used to subsidise them.

Image for plastic blog

Most boxes and cartons manufactured in Canada are 100% recycled content.

Our major concern in this debate is what can be called the paper feedstock issue. The Canadian paper packaging industry is highly dependent on paper recovered from the back of factories and supermarkets and from households. Most boxes and cartons manufactured in Canada are 100% recycled content. Our mills are generally located in urban areas to capitalise on nearby supplies of recyclable feedstock. Paper materials represent almost 70% of the dry recyclables generated by Ontario households, and almost 80% of all that is recovered for recycling through the province’s Blue Box system[3] .

If anything happens to jeopardise this supply of recovered paper, we have a concern. If local supplies go down, we have to find recovered paper elsewhere, at higher prices, and with a possible cumulative effect of rendering paper products less competitive in the marketplace, in some cases, with certain plastic products that are recycled less easily.

Which brings us to the question of narrowing down exactly what materials, and how much of it, is needed to justify the economics of an EFW plant. Is the tonnage of currently “non-recycled” plastic materials enough? Will it have to be supplemented by paper materials? If so, which ones, and how many tonnes? What will be the impact on the paper industry’s fibre supply, and on the economics of the Blue Box? Do the materials used in an EFW plant count as “recycling” or “diversion”? What would be the impact on the Blue Box funding model if suddenly 82% of residential plastic packaging is deemed to be “recycled” through EFW or “diverted” rather than landfilled?[4]  Lots of questions. Not many answers.




[1] Residential and IC & I Disposal of Plastics, Tables 2 and 3, pages 11-12, Energy and Economic Values of Non-Recycled Plastics (NRP) Currently Landfilled in Canada, M.E. Haight and N. Antadze, University of Waterloo, December 2012, commissioned by the Canadian Plastics Industry Association, CPIA press release of Jan. 18, 2013.

[2] Stewardship Ontario, Table 1: Generation and Recovery (2012 data).

[3] Ibid.

[4] Household generation of plastic film, laminants, polystyrene and other plastics together with PET and HDPE bottles currently landfilled, Stewardship Ontario, ibid.


Some signs of progress

John Mullinder, Executive Director

The US-based environmental group, Upstream, has quietly changed the numbers in its Waste of Forests campaign, correcting the error that inflated its packaging waste claim by about 30 per cent (Upstream misses the boat). We remain hopeful that the group will also change its misleading view of how recycled and virgin material are used in packaging production (Upstream misses the boat – part 2).

While we are waiting for that, there’s another claim that caught our eye: that “Paper production is currently the single largest threat to our forests.”  We asked Upstream for the missing footnote (3) that accompanies this claim some time ago, but it hasn’t provided it. Maybe we are misreading this, but we would have thought that the “single largest threat” to any forest (US or Canadian) would be the actual removal of that forest itself for another purpose (deforestation for agriculture, oil and gas projects, or urban development) rather than the process of tree harvesting (where the harvested area is naturally regenerated or replanted with new seedlings). But that’s just us. Isn’t re-forest better than no forest?



P.S. Harvested forests are regenerated by both the US and Canadian forest industries, in Canada by a combination of natural regeneration and the planting of over a thousand new seedlings per minute (More than a thousand new tree seedlings are planted every minute in Canada). The major causes of net deforestation in Canada (the removal of forest for another purpose) are agriculture (41%), oil and gas projects (24%), and urban development 10% (PPEC blog February 14).

Got a spare moment?

John Mullinder, Executive DirectorTired of wading through the hundreds of emails that have accumulated in your inbox while you were on holiday? Can’t get hold of someone because they are now away? Love the kids dearly but secretly can’t wait until school starts again and you can get back on a regular schedule?

We have the answer, and the technology! All you have to do is click here for a small diversionary moment, and likely learn something you didn’t know before. No prizes, just a diversion. But of course we would like to know how well you scored!  Submit your score here

A case of shameless self-promotion

John Mullinder, Executive Director
If you want to find out more about paper packaging and the environment then set aside the morning of November 12 in Brampton, Ontario. There you will be treated to a frank State-of- the-Nation address by the executive director of the industry’s environmental council. This normally shy and diplomatic individual (who wrote this stuff?) will outline the challenges and opportunities facing the sector, and kindly demolish many of the common myths about paper in general and paper packaging in particular.

He will be followed by Dan (Of-all-Trades) Lantz. This gentleman knows the difference between paper and plastic (inside out), and never gets excited about which materials will or will not make it through a recycling plant. Wearing his Cascades Recovery hat, Dan will tell packagers what they need to know so that packaging can be successfully recovered for further recycling. And as COO of Green by Nature EPR, which has the processing contract for British Columbia’s new 100% industry-funded residential recycling program, he will update everyone on what’s really going on out there.

Finally, before lunch, Dennis Colley, President of the US-based Fibre Box Association, will present the findings from two recent life cycle analyses: one of the average US corrugated box, and the second, a comparative life cycle analysis of two competing systems for fresh produce (the traditional corrugated box and the reusable plastic crate). This should be fun!

For more details and to register, click here.  Sponsorships are still available.

Upstream misses the boat – part 2

John Mullinder, Executive DirectorThere are two things that bug us about the recent packaging campaign launched by US-based environmental group, Upstream: its misleading use of data (outlined in an earlier blog) and its superficial and one-sided view of how the paper packaging industries in both Canada and the United States work.

Basically what Upstream claims is that all the recyclable paper packaging thrown in the trash represents x million trees or so many thousand acres of forest land. Hence its tag line of “A Waste of Forests”1.  Upstream argues that if we recycled all this paper “instead of using virgin paper,” we could reduce carbon dioxide emissions, take millions of cars off the road, and save energy. It makes for a good sound-bite and is accompanied by the obligatory stark photo of a clear cut. But is it true? Or more appropriately for us, is it true in Canada?

The first point to make is that more than 70% of the consumer paper packaging that unfortunately ends up in Canadian landfills is already recycled content packaging2.  It’s been recycled at least once and maybe as many as nine times3.   It is not a question of racing into the forest with a chainsaw to find a virgin replacement for it.  Mills will simply seek alternative sources of recycled fibre, most likely from among the millions of tonnes of used packaging already being collected in North America and exported to Asia for recycling there4.

The 30% of so-called “virgin” material left in Canadian landfills represents less than 2,500 hectares of forest land, less than the size of Port Coquitlam in British Columbia. How many Port Coquitlam’s would fit into Canada? How about 342,0005! Four times more forest land is lost to oil and gas exploration, seven times more to agriculture, not to mention the real biggies: losses to forest fires (consuming 1.9 million hectares) and insects/bugs (chomping their way through a whopping 9.2 million hectares)6.

And of course, Upstream fails to mention that the harvested forest is regenerated by both the US and Canadian forest industries. That virgin material in landfill is actually replaced, in Canada by a combination of natural regeneration and the planting of over a thousand new seedlings per minute7.

So no, we don’t agree with the way Upstream exaggerates and characterises used consumer packaging as “a waste of forests.” We do agree with Upstream, however, that any paper packaging that ends up in landfill is a waste of resources that could be further recycled or composted. It seems to us that instead of playing the emotional card of the clear cut and laying blame at the feet of the paper industry, that Upstream would be far more effective focusing more closely on why packaging actually ends up in landfill. We don’t want it there either. It’s our feedstock. But we as the paper industry don’t have any control over the relative costs of sending stuff to landfill and recycling. State governments and provinces do. But that’s a subject for a whole other blog.




1 Upstream’s Make It, Take It Campaign, A Waste of Forests.

2It is substantially higher than 70% because we have not factored in imported packaging from countries like China where recycled content is known to be high. In Canada, most corrugated boxes and folding cartons are made from 100% recycled content, from old boxes collected from the back of factories and supermarkets or from curbside. The average recycled content of paper-based packaging as a whole is almost 80 per cent. There are only three packaging mills that actually use 100% virgin material, and these, plus a few that blend virgin fibres with recycled, do not use whole trees as such, they use wood chips and sawmill residues that are left over from logging trees for lumber (to make homes and hospitals).  For further information see PPEC press release and document Understanding Recycled Content.

3 Paper fibres can be recycled between four and nine times but progressively become weaker until eventually they wear out and must be replaced with a fresh infusion of longer and stronger virgin fibres (PPEC blog).

4 For example, the US collects almost 9 million tons of old corrugated boxes and exports them for recycling in other countries, principally China.

5 In the absence of national statistics on consumer packaging disposal, we extrapolated Ontario residential disposal data to Canada’s 2012 population, assuming that other Canadians disposed of paper packaging in a similar fashion. From this total of 440,811 tonnes we deducted recycled content tonnes (303,291 or 69%) based on national average recycled content rates (81.1% for corrugated, 70% for boxboard/folding cartons, and assuming 80% for laminants) to get a total of 137,520 tonnes of so-called “virgin” material in landfill. We then converted this total to short tons and used the same tons/acre ratio that Upstream uses (0.04 per acre) to derive a forest use number of 6,063 acres (which is 2,452 hectares when converted back to metric). Port Coquitlam is slightly larger than this at 2,917 hectares.

6 PPEC blog on net deforestation using Environment Canada/Natural Resources Canada data, and The State of Canada’s Forests, Annual Report, 2013, pages 16, 45.

7More than a thousand new tree seedlings are planted every minute in Canada (PPEC blog).




Upstream misses the boat

John Mullinder, Executive Director

There’s no question that the folks at the US-based environmental group, Upstream, have their hearts in the right place. We just wish they would get all of their facts straight.

The group recently launched a wide-ranging campaign against packaging waste, including a section on what it calls paper-based “consumer” packaging. Upstream defines this as pretty much everything except corrugated boxes, and claims that only 25% of it is being recycled in the US[1].

The assumption that corrugated boxes should not be considered part of consumer packaging, however, directly contradicts the 10 years of detailed residential data we have here in Canada. In fact, corrugated boxes are the single largest component (on average 46%) of Canadian consumer paper packaging (containing everything from appliances through to electronics, wine and beer, pizza, even hamburgers)[2].  So it doesn’t seem very honest to us for Upstream to exclude almost half of residential paper packaging from its calculations. We have no reason to believe that American and Canadian residential consumption patterns are significantly different.
AvggerationofpaperbasedpkgExcluding corrugated from one’s definition of consumer packaging, of course, makes a huge difference in the recycling rate. In Canada, more than 80% of these “consumer” corrugated boxes are being recovered for recycling[3].  We don’t know the equivalent rate for the US, but Upstream’s claim of only 25% recovery (by excluding residential corrugated) gives a very misleading impression to say the least[4].

This false impression is compounded when Upstream tries to calculate the supposed environmental impact of the “consumer” packaging that ends up in landfill, what it calls “a waste of forests.” For some reason, Upstream does not use the US EPA discard total for non-corrugated paper packaging (6.42 million tons), which would be consistent with its limited definition of consumer packaging.

textboxInstead it uses a tonnage number that’s almost 30% higher (the discard total for corrugated and non-corrugated packaging from both industrial and residential sources)[5].   In effect, what Upstream has done is ignore residential corrugated when discussing the recovery rate, but include residential (and industrial-sourced corrugated) when it calculates waste. You can’t do that! You can’t change your definition of consumer packaging halfway through without inviting criticism that you are deliberately distorting the numbers to make your target (paper-based consumer packaging) look worse.

Even if you buy Upstream’s argument of a “waste of forests” (we don’t, and will explain why in a later blog), correcting this statistical miscalculation would shrink the size of that “forest” by almost a third. We suggest that Upstream do the honourable thing and remove its “Waste of Forests” piece from both its website and its campaign while it corrects these errors.



[1] Upstream’s Make It, Take It Campaign, A Waste of Forests, claims that “only 25% of paper-based consumer packaging is recycled.” This ties in with Table 4, Paper and Paperboard Products in Municipal Solid Waste in the United States: Facts and Figures, 2012 (US EPA) which cites a recovery rate for paper packaging (excluding corrugated boxes) of 24.7%.

[2] Stewardship Ontario data for Ontario’s residential Blue Box program (2003 to 2012). Residential corrugated averaged 46% of all residential (consumer) paper packaging generation over a 10-year period.

[3] Stewardship Ontario, ibid. The recovery rate for residential corrugated over the same period averaged 81% (85% in the latest data year).

[4] Table 4 above (US EPA) cites a corrugated recovery rate in the US of 90.9% but there is no breakdown of recovery by consumer or industrial source.

[5] Upstream claims that “only 25% of paper-based consumer packaging is recycled. The rest – 9.1 million tons is wasted each year….”  But according to the US EPA (Table 4 above), the discards of Upstream’s chosen definition of “consumer” packaging (excluding corrugated) was only 6.42 million tons. Upstream inflated its waste calculation by 29 per cent.

Great news on the corrugated life cycle front

John Mullinder, Executive Director
The average US corrugated box has registered significant environmental improvements over a four-year period, according to a life cycle analysis released today.

Global warming results were 32% lower than recorded in a similar study undertaken in 2006, mainly because more old corrugated containers (OCC) were diverted from landfill (recovery increasing from 72% to 85%). Also significant were lower fossil fuel usage, a switch from coal to less carbon-intensive fuels such as natural gas, and reduced mill effluent phosphorus and atmospheric emissions.

The cradle-to-cradle study, commissioned by the Corrugated Packaging Alliance, was completed by the National Council for Air and Stream Improvement (NCASI), a third-party independent research body specialising in forestry issues. A Critical Review Panel comprising life cycle experts from the Athena Institute and EarthShift LCC confirmed that the study conforms to ISO 14040/14044 standards. The study considers seven environmental impact indicators and four inventory indicators.

All pertinent information is available here.