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Author Archive for Rachel Kagan

Ontario’s Blue Box Regulations Reflect PPEC Recommendations, Targets Still a Concern

On June 3, 2021, the Ontario Ministry of the Environment, Conservation and Parks released the final Blue Box Regulation. The new regulation sets out a framework to transfer the costs of the blue box program away from local communities and requires the producers to operate and pay for blue box services.

PPEC has been actively engaged in the government’s consultation process, providing input into the development of the regulation at every stage, as well as providing our formal comments in response to the draft regulation on December 3, 2020; which outlined our industry’s concerns regarding the government’s proposed targets and approach to recycled content.

Several changes were made to the final regulation as a result of the consultations, which are summarized in the Environmental Registry posting.

Of importance to PPEC and its members, the Ontario government reduced the paper diversion targets, and removed the recycled content proposal, in the final Blue Box Regulation.

Paper Targets Reduced

For the paper material category, the target for both 2026-2029, 2030 and beyond, was proposed to be 90% in the draft regulation.

In the final regulation, the proposed target for paper was reduced to 80% for 2026-2029, and 85% for 2030 and beyond.

While PPEC is pleased the government heard our concerns and reduced the target, we remain concerned that the targets of 80% and 85%, respectively, may not be achieved, as explained below and in PPEC’s blog post, Ontario Blue Box will struggle to make 60% diversion, and none of the ministry’s proposed new targets will be reached.

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.”

Blue Box diversion targets lower but still out of reach

While paper material is the single largest component of the Blue Box – with 67% of it currently being recovered for recycling – the composition of the overall paper category has been changing, which impacts the diversion rate.

Newspapers continue to see an overall decline as consumers choose to read the news online instead of in print – this decline in newspaper generation means less newspapers being diverted, since less are being collected in Blue Boxes, taking away from the overall paper diversion rate. While other categories – corrugated box diversion is 98% in Ontario – already have high diversion rates, leaving little room for any increase.

So as some materials within the paper category decrease, while others are already at high diversion rates, it begs the question of how will the overall paper diversion rate increase to meet the government’s new targets?

The hope is that a move to a more standardized system across the province will see better consumer participation at the household level – and at the end of the day, it is the consumer who makes the final decision of how they dispose of their waste and recyclables – so the more aware and educated they are, the more likely consumers are to properly source separate their waste and recyclables. This should help increase diversion, and hopefully reduce contamination levels – the higher the contamination, the harder it is to achieve better recovery rates.

But it all remains to be seen and PPEC will be watching the diversion data closely in the coming years.

Recycled Content Proposal Removed

The original proposal for recycled content in the draft regulation stated that:

    • The proposed regulation recognizes the use of recycled content sourced from blue box materials managed in Ontario that is incorporated into new products and packaging. A producer that uses recycled content sources from blue box materials would be allowed to reduce their supply for that material category for the next calendar year in proportion to the initiatives undertaken.
    • The proposed regulation would limit the overall reduction to no more than 50% for a material category. The proposed regulation establishes a formula for calculating a producer’s management requirement. The proposed regulation would ensure that the use of recycled content does not reduce overall diversion by redistributing the sum of recycled materials used in a given material category amongst all producers in that category.

In the final regulation, the government eliminated the recycled content proposal “to ensure that new provision can align with the federal intent to develop national recycled content standards.”

PPEC believes that recycled content is a key component of a circular economy, as it keeps raw materials flowing longer, reducing the need to extract virgin materials.

In our submission we explained our concerns with a mandated approach to recycled content: it only applies to the government’s jurisdiction i.e. Ontario, which could have international trade implications for material being shipped into Ontario; and it disregards that most design decisions on recycled content are often made at a global scale, not a local Ontario one.

We also felt that Ontario’s proposal would be administratively challenging in an already highly complex Blue Box program. In PPEC’s blog How about a different approach to recycled content and the circular economy?, we outline the advantages of looking at alternatives like a tax rebate or credit, as a way to support a Ontario recycling businesses and a more circular approach.

For now, we are pleased that the recycled content proposal has been removed, and we are proud that most of PPEC’s paper mill members already produce 100% recycled content boxes and cartons.

Special thanks to John Mullinder, PPEC’s long-standing Executive Director, for all his work in effectively representing PPEC members’ interests in working with the government on the development of the Ontario Blue Box regulation.

For more information, please see the Ontario government’s news release, Ontario Enhancing Blue Box Program, and the final Blue Box Regulation.

Rachel Kagan

Executive Director Paper & Paperboard Packaging Environmental Council (PPEC)

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Articles on the Demand for Corrugated Cardboard Boxes Disregard the Importance of Environmental Sustainability

Over the last few months, there have been several articles about the increased demand for containerboard and corrugated cardboard boxes, due to the surge in online shopping during the pandemic.

There was the Wall Street Journal’s Cardboard Boxes Have Never Been in More Demand—or More Expensive (March 30), FOX Business’ Cardboard box prices skyrocket as COVID-19 pandemic causes spike in online orders (April 8), and Business Insider’s A surge in cardboard demand is causing a supply squeeze for box makers amid the online-shopping boom (May 20), to name a few.

These articles were primarily about the impacts of the increased demand on paperboard manufacturing businesses, including rising prices and shipment delays of raw materials.

And yet they barely mentioned the environmental attributes of containerboard and corrugated boxes, or the critical role that recycling plays in the sustainability of the paper packaging industry. Or even worse, provided misinformed comments about the industry.

It was not until the very end of the Business Insider article that recycling was even mentioned:

Terry Webber, executive director of packaging at the American Forest & Paper Association, said in a statement that “containerboard production in March increased 9% compared to March 2020,” when the pandemic hit the US. The AF&PA also mentioned that boxes are the most recycled packaging in the US, which can help keep the supply chain sustainable for both retailers and customers. 

And while the Wall Street Journal article was accompanied by a link to a 2019 video, Where Your Old E-Commerce Boxes End Up (about cardboard recycling), the focus of the article was about how the production of corrugated product increased 3.4% to 407 billion square feet in the U.S. in 2020, with the price of containerboard increasing by $50 to an average $765/ton, with only one mention related to recycling:

At a recent investor conference, Waste Management Inc. Chief Executive Jim Fish said more e-commerce could boost the waste hauler’s recycling business, which collects cardboard curbside and sells it to be pulped anew for more boxes.

Unfortunately, neither of these articles provided any additional context to explain the importance of why recycling helps keep the supply chain – and the industry – environmentally sustainable.

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 packaging.

Some key statistics:

  • 94% of Canadians have access to recycling[1]
  • Canada recycles almost 70% of its paper and cardboard, making it among the top paper recycling countries in the world[2]
  • The national recycling rate for corrugated boxes is estimated to be at least 85%[3]
  • Ontario has a 98% recovery rate for corrugated cardboard[4]
  • Most of the paper packaging material made by Canadian mills is 100% recycled content[5]
Articles on the Demand for Corrugated Cardboard Boxes Disregard the Importance of Environmental Sustainability

Not only are these materials recyclable, they are actually being recycled – an important distinction illustrating that Canadians understand their role and do their part by actively recycling. This allows those recycled materials to be remade into new paper packaging, as evidenced by the high amount of recycled content used by mills.

And it’s a similar story in the U.S. where 88.8% of cardboard and 65.7% of paper were recycled in 2020, according to The American Forest & Paper Association, who reported that those rates remained unchanged during the pandemic, calling that “a testament to the resilience of the paper and wood products industry.”

But it was FOX Business’ article that made no mention of the environment, except in a video clip that accompanied the story. In the 3-minute clip, FOX reporter Jeff Flock interviewed Andy Reigh of Welch Packaging, a corrugated box manufacturer located in Elkart, Indiana. Two minutes into the video, Flock makes a comment about “trees,” and then when he throws it back to the FOX newsroom, host Stuart Varney said “I thought all this stuff was recycled,” and you can barely hear Flock say that most of it is recycled.

Not only does recycling not get the airtime it rightly deserves as part of this story, but FOX also makes comments about trees and paper products with no context or facts. If they had the facts, they would know that the sustainable management of forests is a key issue for the paper packaging industry.

Even though most paper packaging made in Canada is high in recycled content, the paper fibres it was originally made from came from a tree. But by law, every hectare of commercial forest that is harvested in Canada must be successfully regenerated. On average, over 1,000 new tree seedlings are planted in Canada every minute. And all PPEC-member mills producing corrugated box material have independent, third-party certification that their paper fibre sources (whether wood chips and sawmill residues or recycled fibres) are responsibly sourced. When you add it up, the Canadian industry hardly uses freshly cut trees to make paper packaging, and the little that is harvested (0.2% in 2018) is successfully regenerated.

While the media articles mentioned told the story about increased demand for corrugated cardboard boxes, they did not provide the full story of what happens to those boxes after they leave the manufacturing facility; they end up going to a customer, then a recycling bin, and eventually those recycled materials are remade into new paper packaging. And that continuous and sustainable loop deserves to be part of the story, with the facts to back it up, to help inform and educate the public.


[1] Access to Residential Recycling of Paper Packaging Materials in Canada, October 2014. Report prepared for PPEC by CM Consulting.

[2] Two Sides Fact Sheet Corrects Common Environmental Misconceptions About the Canadian Paper and Paper-based Packaging Industry, January 2021.

[3] Where Packaging Ends Up, PPEC.

[4] 2020 Blue Box Pay-In Model, Stewardship Ontario.

[5] Recycled Content Survey, PPEC.

Rachel Kagan

Executive Director Paper & Paperboard Packaging Environmental Council (PPEC)

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Statistics Canada’s New Waste Management Survey Results: Paper Represents 36% of Diversion

Statistics Canada released the results of its biennial Waste Management Industry Survey: Business and Government Sector, containing waste diversion data for 2018.

The new data shows that Canadian households and businesses diverted 9,817,607 tonnes of waste in 2018, up 5.8% from 2016.

Of the total amount diverted, 3,519,689 tonnes were paper fibres (which includes newsprint, cardboard and boxboard, and mixed paper), representing 36% of the total amount diverted in 2018.

While paper diversion represents the majority of materials diverted from landfill in Canada, compared to previous years Statistics Canada data, paper diversion has been trending slightly down year over year since 2014.

The next leading category of materials diverted in Canada for 2018 was organics with 29% of the total share of diversion.

Digging deeper into paper diversion, of the 3.5M total tonnes diverted in Canada in 2018, about 44% was diverted through residential sources (ie. Blue Box recycling programs), while the remaining 56% was diverted through non-residential sources (ie. Industrial Commercial and Institutional collection).

Statistics Canada reported that Saskatchewan had the highest rate of residential paper fibre recycling among the provinces, at almost 70%, or 38,000 tonnes of its total 57,000 tonnes of paper recycling.

Below is a full breakdown of sources of paper diversion by province, for both residential and non-residential (IC&I) diversion. Of note, British Columbia had the highest IC&I paper fibre diversion rate at 78% (433,609 tonnes of its total 553,596 tonnes of diverted paper materials); while Ontario had the largest share of paper diversion by tonnage through both IC&I (736,790 tonnes) and residential (581,930 tonnes) sources.

Background on the Statistics Canada Data

Statistics Canada’s Waste Management Industry Survey of the business and government sectors is conducted every two years.

The 2018 results were released on March 8, 2021.

Some of the data contained in this blog are from Waste materials diverted, by type and by source (Table: 38-10-0138-01) which includes the following footnote:

This information covers only those companies and local waste management organizations that reported non-hazardous recyclable material preparation activities and refers only to that material entering the waste stream and does not cover any waste that may be managed on-site by a company or household. Additionally, these data do not include those materials transported by the generator directly to secondary processors, such as pulp and paper mills, while bypassing entirely any firm or local government involved in waste management activities.

Rachel Kagan

Executive Director Paper & Paperboard Packaging Environmental Council (PPEC)

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Providing Clarity on The Ottawa Citizen’s Cardboard Recycling Article

Last week, The Ottawa Citizen’s Kelly Egan wrote an article about cardboard recycling in Canada. In Thinking inside the box — pandemic creates crush of new cardboard, Egan provides some stats about paper packaging recycling and the consumption of trees — some of which are correct, and some of which are confusing.

Egan reached out to the Paper and Paperboard Packaging Environmental Council (PPEC) for some information on paper recycling, and while he used some of the data we provided, PPEC was not mentioned in the article.

With regards to recycling, Egan wrote:

“Paper and cardboard are considered the success stories in the recycling world. Two main reasons: as much as 98 per cent (depends who’s counting) of corrugated cardboard is recycled and any “new” cardboard uses very high content of recycled fibre.”

Yes, paper and cardboard are indeed success stories, and PPEC and the Canadian paper packaging industry is proud of that. As for who’s counting, it is Stewardship Ontario (who operates the Blue Box program under the authority of the The Waste-Free Ontario Act, 2016) who is doing the counting. Ontario’s 98% recovery rate for corrugated cardboard, the most recent available data, is from the 2020 Blue Box Pay-In Model.

As for recycled content, most of the paper packaging material made by Canadian mills today is 100% recycled content, according to PPEC’s most recent Recycled Content Survey. Old corrugated boxes and cartons are collected through residential Blue Box recycling programs across the country, as well as from the factories and supermarkets, and used to create recycled content product.

Cardboard Recycling chart of the circular economy

Egan goes on to write about tree consumption:

While this is considered a shining example of the so-called circular economy, paper and cardboard production does gobble up a lot of trees, as per this snippet from a recent Washington Post story: “Global consumption of trees reaches roughly 15 billion each year, including three billion for paper packaging, according to the Environmental Paper Network. The industry relies on recycling virgin fibre — the basis of cardboard boxes — five to seven times, saving trees and improving the bottom line.”

The Washington Post story Egan is quoting from is How Big Cardboard is handling the 2020 box boom (December 30, 2020). But using a global figure about tree consumption, in an article about paper packaging in Ottawa, could lead to some unnecessary confusion.

When it comes to Canada’s trees, less than half of one per cent of our forests are harvested for pulp, paper and lumber uses each year. In 2018, the harvested area represented 0.2% of the total area of forest land, according to Natural Resources Canada. And by law, all forests harvested on crown land (over 90% of Canada’s forest land is publicly-owned) must be successfully regenerated.

Not that we use of lot of trees to make paper packaging to begin with. On average, the recycled content of paper packaging shipped domestically is 71 per cent; and the balance of Canadian paper packaging comes from wood residues – wood chips, shavings and sawdust left over from lumber operations – with only 11% coming directly from trees (roundwood pulp), according to PPEC’s The Truth About Trees members only Fact Sheet.

According to the Washington Post article Egan quoted from, virgin fibre is recycled five and seven times; but according to our information, paper fibres can be recycled between four and nine times in Canada.

And while Egan refers to the “so-called circular economy,” PPEC truly believes that we do have a circular economy for paper packaging. Our Paper Packaging Flow Chart shows the cycle of how our material is collected, sorted, and sent to recycling mills to make new packaging; illustrating the circularity in the manufacture and use of paper, a renewable, sustainable and recyclable resource.

Rachel Kagan

Executive Director Paper & Paperboard Packaging Environmental Council (PPEC)

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PPEC Blog to Introduce Myself

Hello and welcome to my first blog as executive director of The Paper & Paperboard Packaging Environmental Council (PPEC). I am Rachel Kagan and as of February 1st I’ve taken over from John Mullinder, but you can still find him writing about paper on his personal blog.

But back to me… I enjoy organising information and data, drawing insights and identifying trends, and turning that into reports, blogs, social media posts, and other communication and advocacy vehicles.

History

For the past two years, I have been freelance consulting for small and medium-sized businesses and associations, providing research, legislative and policy analysis, content creation, and project management services.

Prior to that, I have 15+ years of industry association experience, working with members to develop consensus-based policy positions, as well as government submissions, industry reports, and presentations on packaging recycling and Extended Producer Responsibility, food waste, and climate change issues.

Over the past pandemic year, like others, my reliance on deliveries and online shopping has increased, and with it, so has my paper packaging (and my recycling of that paper packaging!). And in starting this role a few weeks ago, I haven’t been able to look at a corrugated box the same way since!

Thanks to PPEC, I now know that the wavy layer of the box is the corrugated medium, and the layers of paper are the liners; but more importantly, I know that those boxes are sustainable and made of recycled content.

And thanks to the Canadian Corrugated & Containerboard Association’s Humble Box Sanitary and Safe video, I also now know that the box being delivered to my home is hygienic and clean.

But I have a lot more to learn about the industry, so I am reading PPEC’s past blogs, Fact Sheets, and other informative resources.

I look forward to applying my experience, skills, and interest in sustainability to PPEC’s work in tracking, monitoring, and promoting the environmental performance and achievements of the Canadian paper packaging industry.

Please feel free to email if you have any questions or comments for me as I get started in this new role.

Rachel Kagan

Executive Director Paper & Paperboard Packaging Environmental Council (PPEC)

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