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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.”

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.

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]

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.

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.

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.

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.

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.

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.

Time to move on

Estimated reading time: 4 minutes

This will be my last blog as executive director of PPEC, the environmental council I have run for the past 30 years. Yes, 30 years. Unbelievable how time marches on, isn’t it?

I remember my first day on the job being asked to take the minutes of the board meeting. I knew only two people in the room (the ones who had interviewed me) and had absolutely no idea what these guys were talking about (C flute, Rule 41, corrugators). It was a steep learning curve, but I had some great help along the way from board members, staff, industry colleagues, government folks, environmental activists. A wide range of helpful people, many of them still in regular or occasional contact.

Thirty years ago, packaging was a major political target (things haven’t changed much, have they?) and paper packaging, in particular, was ‘public enemy number one.’ Paper packaging tends to be larger and stand out more; it’s widely used across a broad range of industries and commerce and delivers household goods as well; and somehow it is always captured in stock images of ‘nasty’ landfill. But when you dig deeper, as I did, you quickly discover that it has a great story to tell about sustainability and a circular economy. That’s what I’ve tried to add to, and pass on, over the last 30 years.

I won’t list the council’s many achievements here (there’s a series of videos on the website) but several were world or North American firsts. Possibly the most significant was leading North America in the further recycling of old cereal and shoe boxes (boxboard). Back in the mid 1980s, this already highly-recycled material ended up in the dump because the fibres were considered too thin and short to be of any further use in papermaking.

Working with brand owners like Lever Brothers, Kellogg’s and Procter & Gamble, and municipalities like Quinte in Southern Ontario, we undertook pilot trials at Strathcona Paper and Paperboard Industries, and developed what we called a food packaging protocol to give the brand owners confidence that re-using residential boxboard in new food packaging would not be a health concern. We then persuaded other mills (Atlantic Packaging, for example) to use old boxboard as filler material in corrugated board. To make a long story short, back in the early 1990s this material went straight to the dump. Today, some 94% of Canadians can recycle it, and those that don’t recycle it can send it on for composting.

Educating people about what has been done, and is being done, is a constant and daunting challenge, and this is possibly more so today with the proliferation of social media and a far looser adherence or ambivalence towards fact-checking. Yes, this bugs me intensely! Whether it’s on forestry or waste issues, recycling or recyclability, please dig for the facts before splurging into print. At the very least, please cite your sources of information so that people can check them out and judge their credibility. Here endeth the rave!

No, I am not sailing off into the sunset. This is au revoir not goodbye. I will continue to write about environmental issues that concern me.

I had planned to do some travel after PPEC, but COVID-19 has put that on hold. COVID-19 has, however, got me into walking/jogging seven kilometres almost every morning, and I am now in better shape than I have been for years. Mental shape too. There’s nothing like an early morning jog/walk to clear your head and think about the next blog, or article, or book you want to write. Yes, I’m working on another book. No surprise, it’s on false and misleading environmental claims! So, if you have some good examples, let me know and I’ll check them out!

In the meantime, PPEC is in good hands with a new executive director coming aboard. Here’s a link to the press release. Please give Rachel your support. Au revoir!

What is it about pizza boxes?

Estimated reading time: 4 minutes

What is it about pizza boxes that they always seem to get singled out for special mention? Is it the guilt we feel at scoffing down all that cheese and pepperoni? At tearing into that soft fresh crust knowing full well that our long-delayed and somewhat erratic weight-loss program will be pushed back a few days, maybe weeks? Especially if that piping hot and mushy mess is washed down with large dollops of ice cream. To cool it off, you understand.

Stack of three pizza boxes

Whatever it is, municipalities seem to go out of their way to make an example of the poor old pizza box. It’s not recyclable, they claim. The paper mills don’t want it. It’s the mountains of grease and cheese. Put it in your organics or food waste bin. At least it will make good compost.

There is some truth to that. Paper can be composted, and for some households, composting is likely the better option. Ask the residents of Nova Scotia and Prince Edward Island who are hundreds of kilometres from the nearest packaging recycling mill.

But pizza boxes are perfectly recyclable too. Sure, the recycling mills don’t want the plastic centrepiece that sometimes holds the slices together in the box. (Memo to self: why isn’t this plastic do-hickey made of paper so it can be recycled with the box?). Anyway, while the mills greatly appreciate your kind offer of leftover crusts, they would really prefer that you deal with them yourself. It’s a pride thing.

But the box itself is fine. Normally it’s made of corrugated board. And in Canada anyway, that is mostly 100% recycled content. So, it’s been around before. And will be around again. What?  you say. That gooey, greasy stuff that I kindly left for the paper mill workers will be in my next box? Yuck!

No dear friend, it won’t. When it finally gets to a recycling mill, your kind gift is first dumped into a big washing machine called a pulper. It’s not that the mill is ungrateful, it’s just that pizza crust doesn’t make great paper. So, any crust you’ve kindly donated will be shaken free and exit the system. Same for the cheese. It tends to clump together and gets screened out during the pulping process. 

Aha, but what about the grease? Well, that is a little bit harder to get rid of, but if you thought the pizza was hot, wait until you hear the temperatures that paper is made at. In a typical mill recycling process, the temperature of the paper sheet reaches 220 to 240 degrees Fahrenheit, well above 100 degrees Celsius, the boiling point of water and the temperature required for sterilisation. So goodbye grease! The average grease content of a pizza box is less than 2% anyway, and at that level does not affect the strength of the new board being made[i].

And if you are still not totally convinced, there’s a further check in the system. The board goes from the mill to a converting plant where the board is blended with other paper layers to form a corrugated sheet, which will then be shaped into your next pizza box. Sorry we can’t do anything about the ice cream! But the corrugation process, as it is called, destroys any bacteria that might remain. In fact, a recent study showed that every single one of 720 corrugated boxes from six different suppliers tested at six different locations in three different regions met acceptable sanitisation levels[ii].

So, there you have it. Pizza boxes are recyclable. Now, was that vegetarian or Hawaiian?


[i] Incorporation of Post-Consumer Pizza Boxes in the Recovered Fiber Stream, Impact of Grease and Cheese on Finished Product Quality, WestRock 2020. https://www.westrock.com/greasecheesestudy

[ii] Haley study released February 2015, see blog by John Mullinder Retailers can’t duck food safety issues when pushing growers to re-use crates, March 28, 2017.

This was prevously posted on  www.johnmullinder.ca 

© John Mullinder Contact the author for permission to reprint.

Ontario Blue Box will struggle to make 60% diversion, and none of the ministry’s proposed new targets will be reached

Green visions, aspirational goals, and political grandstanding are all very well in their place. But at some point, we have to be realistic. The fact of the matter is that the overall waste diversion rate of Ontario’s Blue Box is unlikely to improve much over the next ten years, and the new diversion targets proposed by the Ministry of Environment, Conservation and Parks (MECP) will not be achieved.

These are the stark findings of a PPEC-commissioned study by Dan Lantz of Crow’s Nest Environmental. Lantz has more than 30 years’ experience in the waste and recycling industries.

The study examines Blue Box diversion patterns from the current program’s inception in 2003 together with industry reports on the future of given materials and an understanding of the capabilities of the recycling system and end-markets. To establish future generation and recycling rates, all on a per person or per capita basis to account for population growth, the study determines and applies mathematical formulas to predict whether Blue Box materials will meet the ministry’s two new proposed diversion target dates of 2026 and 2030. The answer is no, they won’t.

Blue Box will struggle to make 60%

Where are we now? The Blue Box program is currently diverting 57% of the printed paper and packaging that ends up in Ontario homes. Its performance, though, has been steadily declining over the years as lighter and less recycled materials make up a growing portion of the residential waste stream.

The data tell the story. In 2003, the generation of printed paper (mainly newspapers) represented almost half (47%) of the Blue Box materials in Ontario households. By 2019, printed paper’s share of generation had shrunk to 27%. Its share of what was diverted shrank too (from 61% in 2003 down to 30% in 2019).

At the same time, plastic packaging’s share of generation increased from 16% to 25% and its diversion share rose from 5% to 13%. These trends are expected to continue over the next decade and to impact diversion rates accordingly.

And while the ministry has wisely not specified a new overall Blue Box diversion target, its consultation papers make clear it would like to achieve somewhere between 75% and 80% within the next ten years. That’s not going to happen, says Lantz.

“Based on projections out to 2026 and 2030, the ministry’s targets are not realistic under the current program structure.’’ In fact, he says, unless something major changes like the Blue Box giving people more opportunities to recycle (say through an extensive depot network) and the public becomes more engaged and recycles far more than it does at the moment, then the Blue Box will continue to struggle to achieve the existing 60% diversion target into the future. He forecasts just over 58% diversion by 2030.

It’s important to note that the ministry is talking about diversion targets here, not collection targets. It is one thing to measure Blue Box performance by collecting materials at curbside and depots, as British Columbia does. But in Ontario, diversion is measured after the collected material has been processed at a material recycling facility (MRF).

The level of contamination can make a big difference as the higher the contamination the harder it is to achieve better recovery rates. So, BC’s performance (aided by the strategic location of some 250 collection depots) should not be equated with what Ontario is proposing.

Another complication is that the Ontario ministry wants more material diverted from a wider range of sources. This is fine, but broadening how much needs to be diverted (the generation base) automatically reduces the diversion rate as well, because unfortunately not all of that new source material will be diverted.

The only way the diversion rate would improve would be if the new materials achieve diversion rates above the average. Considering that some of the new materials proposed by the ministry for collection (including straws and plastic cutlery which will not be recycled at all because they are too small to be effectively captured and will just end up going to disposal), the diversion rate will not improve above what is projected in the Lantz report.

The province has not offered any estimates of how large this new supply of material will be, making it harder to calculate whether its proposed diversion rates are practically achievable or not.

90% for paper ‘just isn’t going to happen’

And if the ministry is expecting paper to ride to the rescue, forget it. Paper material is the single largest component of the Blue Box with 67% of it currently being recovered for recycling. The ministry’s proposed paper diversion target for 2026 and beyond, however, is 90%.

“Ninety per cent just isn’t going to happen,” says Lantz. There will be even fewer newspapers in future, more online and digital transactions (therefore less paper use), and very little opportunity for significant increases in paper recovery (corrugated box diversion is already at 98%, for example). This means the paper group as a whole will likely come in with a 69% to 70% diversion rate, he says. Far short of the ministry’s wished for 90%.

90%

“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. Add in the fact that some Ontarians use paper with kindling to start their fireplaces and woodstoves in winter and burn paper, and it’s just not reasonable to expect a 90% diversion rate.”

Other material groups won’t make targets either

Rigid plastics (bottles containing water, soft drink, laundry detergent and shampoo, and mixed plastic tubs and lids, cottage cheeses and ice cream containers) currently have a diversion rate of 26 per cent. The ministry is targeting an improvement to 60% by 2030. Lantz predicts, however, that there will be little change over the next ten years, maybe an increase to 47 per cent.

As for flexible plastic packaging (currently at 8% and targeted for 40%), he says 15% may be as far as it gets, unless there is a dramatic shift to mono-materials (single-resin) flexibles, that is, stand-up plastic pouches that are much easier to capture and recycle. “Most plastics aren’t hard to sort in a material recycling facility. People just don’t put them in the recycling system like they should, and until they do, recycling rates will stay low.”

He predicts that steel and aluminum diversion through the Blue Box will improve to maybe 60% (missing the metals target). Glass packaging will also miss its target but maybe reach 75% diversion by 2030.

There are many factors that could influence these projections: pressure for higher recycled content levels; landfill bans or surcharges; alternative collection systems including deposit/return; and the impact of the extra tonnes the ministry wants collected from a wider range of sources.

There are also behavioural changes that could influence the results. “It often boils down to that flick of the wrist decision where the householder decides whether to put something into the garbage or into the box,’’ says Lantz. “We need to be much clearer about what goes where, and to give people more opportunities to make the right decision.”

Lantz suggests the province should set disposal targets instead, thereby reducing the burden on municipalities that have to handle the recyclables that householders place in the garbage. Environmentally, he says, it would be better if we reduced consumption at the front end. “Setting unreachable diversion targets that effectively allow unfettered consumption, and relying on recycling to overcome that consumption, is not the best approach.”

Estimated reading time: 7 minutes

How about a different approach to recycled content and the circular economy?

Estimated reading time: 8 minutes

Recycled content is the key component in the creation of a circular economy. It keeps raw materials flowing within the economy longer, reduces the pressure to extract more virgin materials from the earth, and delays their eventual disposal as waste. Recovering more materials for further use also creates jobs. A circular economy is something that companies and governments say they want to encourage.

Voluntary and Mandatory Approaches

The strategies to encourage recycled content range from voluntary approaches through to government mandated minimums and the threat of banning product sales if those minimums are not met.

With a voluntary strategy, the government adopts a hands-off approach, allowing the marketplace to determine what happens. In the Canadian province of Ontario, the paper packaging industry has gone from below 50% recycled content to all but one mill today producing 100% recycled content boxes and cartons. This is presumably the type of ‘’circular economy” that Ontario wants. The ‘problem’ is that the approach is slow. It took some 25 years to get there.

The mandatory approach, on the other hand, is where the government regulates or legislates a framework of minimum recycled content targets, with fines or penalties or sales bans for non-achievement.

One of the problems with government mandates, however, is that they apply only to that government’s jurisdiction. For example, an Ontario mandate would not apply to other provinces. There may also be international trade implications for material being shipped into Ontario. Another complication is that most design decisions on recycled content are not made in Ontario but rather at company head office (in the US or Europe) with packaging design undertaken at global not local (Ontario) scale.

Also, the last thing industry wants is provinces or states leapfrogging over themselves to set successively higher (and perhaps public relations inspired) targets for industry to achieve in different jurisdictions. A federal mandate would be preferable, but that would mean getting all provinces/states to agree (which may prove difficult and time-consuming). 

Mixed Approaches

Some governments have chosen to mix voluntary and mandatory approaches to increasing recycled content. They have done this by including incentives within regulated programs. The choice is voluntary and at a company’s own pace.

An example of this is the current suggestion by the Ontario Ministry of Environment, Conservation and Parks (MECP) where companies are offered discounts on Blue Box diversion targets when they can prove use of Ontario Blue Box recycled content.

This approach does have several benefits. It gets the government out of the role of playing policeman and sorting out the technical issues of how to actually set specific recycled content targets for different materials that are sensible and fair. It also means the province does not need to enforce the achievement of these targets because they are voluntary. The onus is on the brand owner/retailer/publisher to prove the claim, with the added expense of mandatory auditing of company reports.

Administratively challenging

The current Ontario proposal, however, is administratively challenging at best, and impossible at worst.

Let’s follow the path of some recovered Ontario Blue Box paper. First it goes from a municipality or a service provider to either a broker or a MRF (processor). That first step is relatively easy to track. Then it gets complicated. Because the broker and the processor have other clients, other suppliers of recovered paper fibre. It could be Blue Box fibre from Quebec or Manitoba; it could be used boxes and office paper recovered from industrial, commercial and institutional (IC & I) sources within Ontario or maybe shipped in from Manitoba or Quebec or the United States. It could be pre-consumer clippings and cuttings from those same disparate sources (Manitoba, Ontario, Quebec, the US).

The same diversity of sources applies at the mill level when the recovered fibre gets there from the processor. The mill is interested in the quality of the different fibres it uses to make its product, not in placing a special watch-out for the fibres coming in specifically from Ontario’s Blue Box program.

From all those different fibres, the mill (which may or may not be located in Ontario) makes board or paper that is shipped to converters who then turn it into the end-product (a newspaper, printing and writing paper, corrugated boxes, boxboard cartons and so on). These converters could be in Ontario or the US and they have other mills supplying them with other recovered fibre feedstock as well, making it very difficult to single out only those fibres coming from Ontario’s Blue Box.

It gets more complicated. A corrugated box comprises two parts (linerboard and corrugating medium). Each of these can be made from recycled content but each could come from different mills and be blended at the same or different converting plants. So, the medium of the box could have a portion of Ontario Blue Box fibres in it but the linerboard none. However, it’s all blended into one box for the customer. How do you keep track of that? And the customer (the brand owner/retailer) could be located in Canada, the US, Asia, Africa or Europe. And can ship the box anywhere in the world.

Tracing specific fibres such as from Ontario’s Blue Box once they enter the regional and international fibre recovery streams is thus extremely problematic. And what about corrugated boxes shipped into Ontario from China? They might have recycled content in them (which is a good thing) but not Ontario-processed recycled content.  What about old corrugated boxes that are collected through the Blue Box in Ontario but shipped across the border to the US for recycling there? There is no credit for the use of that Ontario-derived recycled content.

There are possible ways around some of these complications. If a mill can create a paper trail linking say 25% of its annual feedstock to Ontario’s Blue Box, then could 25% of its annual output be considered to be Ontario Blue-Box sourced? Could that 25% be pro-rated across all its customers? Or 25% allocated to those customers who are placing paper into the residential Ontario marketplace and therefore obligated under the Blue Box regulations?

Complete accuracy is not possible under the current proposal. And, as one insider has noted, it leaves lots of opportunity for fraud and gaming the system. Is there another way of looking at the problem?

How about a tax rebate or credit?

The current Ontario approach to recycled content seems unnecessarily complicated in a Blue Box program that is already highly complex. Recent research also indicates that EPR fees or adjustments for things like recycled content provide little incentive to brand owners to change packaging design or to influence consumer behaviour in purchasing.[i]

So why not look at an alternative approach (a tax rebate or credit) that focusses on supporting Ontario recycling businesses, on creating Ontario jobs, on companies that use Ontario Blue Box material as feedstock? Encourage them to enhance Ontario’s circular economy. Think globally but act locally.

The advantages are these:

  • The credit/rebate focusses on one thing only: increasing the use of recycled content in Ontario. It does not get cluttered or distracted by other waste management objectives (see the quotation from the Eunomia report to the EU commission in the footnote).
  • It can apply beyond the Blue Box (bringing in the IC & I sector) so it is broader in scope and in line with the province’s overall goal of a comprehensive waste management (and circular economy) policy.
  • It retains a voluntary approach with incentives for companies to act.
  • It applies to Ontario specifically but is transferable to other provinces (so could become national).
  • It doesn’t have to be in the current Blue Box regulation (greatly simplifying it).
  • Depending on how the credit/rebate is structured, the people who are actually building the recycling infrastructure in Ontario could benefit (the paper, plastic, glass and metal plants) rather than a brand owner head office in the US or Europe. It would make local (Ontario) businesses more competitive in what are global markets for recycled materials.
  • The credits could go to companies located in Ontario only (unless expanded across Canada). The system could therefore help keep existing industries in Ontario (meaning green jobs). For example, one paper packaging mill in Ontario (using 100% recycled content) recently closed.
  • It will create jobs (by encouraging recyclers to stay in Ontario and to invest in recycling infrastructure here).
  • It could have declining levels of tax credit (higher for sourcing from Ontario’s Blue Box, lower for feedstock imported from other jurisdictions).
  • It could be a joint governmental effort (Environment, Economic Development, Job Creation and Trade, Finance). Make Ontario the recycling hub of Canada or go for a national approach. A federal climate change project? We need to look beyond a narrow environmental approach, beyond our own provincial borders on this one. The idea needs work and it needs champions.

[i] From the Eunomia report for the Director General Environment for the European Commission: “It is better to focus a policy instrument on doing one thing well, than on seeking to achieve multiple objectives. A tension can be created within an EPR scheme if it is seeking to do too many things. A focus on seeking to meet recycling targets in a way that is cost-effective and fair to different packaging formats gives a clear steer to the way in which an EPR scheme should use fee modulation. However, to also introduce an incentive for recycled content can disrupt the efficient operation of the price signals.” (Study to Support Preparation of the Commission’s Guidance for EPR Schemes).

Good news and bad news on Ontario’s Blue Box

The good news is that Ontario householders are generating less paper, plastic, glass and metal waste these days, 14% less than they were back in 2003. That is the year the province regulated industry to share the net cost of the province’s popular Blue Box program and waste statistics became more widely available.

Of course, the number of people living in the province has increased since 2003, which normally means more waste is generated, but on an individual basis Ontarians have done well here too, reducing their generation of Blue Box waste by an impressive 27% over the period.

Generating less waste in the first place (the first of the three Rs, reduction) normally means sending less waste to garbage. Which, in this case, is also true. Ontario households dumped 22% less printed paper and packaging in 2019 than they did some 16 years ago. As individuals, Ontarians were even better, dumping 34% less than before.

This is all good news. The ‘bad’ news is that waste performance is usually measured by weight (as above): by kilograms per person, tonnes per household. Unfortunately, measurement by weight distorts the overall picture somewhat because it is not the weight of materials that fills up recycling trucks and landfills, it is how much space they take up (their volume). Landfills get fat, not heavy, as they say.

This caveat on measurement, weight instead of volume, helps explain the other piece of bad news: that Ontario’s Blue Box today is sending less material on for recycling than ever before. In 2003 the system was estimated to be recovering 53% of all Blue Box materials. In 2010 it peaked at 68%, but ever since then it has been on a progressive downward slide to its current 57% (the first time it has been lower than the province’s required 60% target since 2005).

Why? In addition to some straight out elimination of printed paper and packaging there has been a significant light-weighting of materials over the years (reducing the size and shape of newspapers, using lighter and thinner variations of paper, plastic, glass and metal, cutting out a layer here, a flap there).

But there has also been a major change in the type of material ending up in the home. Gone are many newspapers (replaced by digital alternatives). And when did you last see a telephone directory delivered to your doorstep? The generation of printed paper has plummeted 36% over the last 10 years alone. And these, of course, are heavier materials.

At the same time, there has been a major increase in the amount of lighter weight plastics in the home (up 20% per person since 2010). The biggest increase has been in the catch-all category of “other plastics” (things like yoghurt containers, hand cream tubes, margarine tubs and lids, blister packaging for toys and batteries, egg cartons, and laundry detergent  pails). Most of these (65%) currently end up in the garbage.

So, there you have it. We are generating less waste but the waste we are generating today tends to be lighter and less recyclable. Which is why the overall Blue Box recycling rate is trending downwards. This has major implications for meeting the province’s proposed new waste diversion targets. Are they realistic? Or are they just a political green wish? Stay tuned.

Source: Stewardship Ontario