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Archive for Paper Recycling

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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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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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.

Recycled content and the circular economy
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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.

More Complicated

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).

John Mullinder

John Mullinder, Executive Director, PPEC - Regular posts on environmental and sustainability issues impacting the Canadian paper packaging industry

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False arguments being used to promote post-consumer recycled content

Don’t get me wrong. I fully support the use of more post-consumer material in packaging and products. Just not some of the BS that goes with it. And this is important because governments are stipulating post-consumer content without knowing all the facts. Here are some of the false claims being made:

False Claim # 1: That post-consumer is ‘environmentally better’ than pre-consumer content

Setting aside the big question of what ‘environmentally better’ actually means, I am not aware of any scientific evidence that one is ‘better’ than the other. In fact, they are really the same material, just coming from different places along the feedstock supply chain.

In the paper industry, for example, there is no difference in the way that pre-consumer and post-consumer paper or board is originally manufactured in a mill. It is exactly the same material with the same environmental production inputs. The only difference is that they come back to the recycling mill from a different place (one from a converting operation and the other from the back of factories, supermarkets, offices or homes). In fact, it could be argued that pre-consumer has a lower environmental impact overall because it travels a shorter recycling loop back to the mill.

False Claim # 2: That post-consumer is ‘more circular’ than pre-consumer

Not true. Isn’t the circular economy all about minimising waste? So, what could be more circular than minimising waste at the converting stage? Pre-consumer material is like the off-cuts left after you cut a sewing pattern from cloth. Since you’ve already paid for the cloth, you make sure your design makes maximum use of the cloth you have. And what you have left over you send back (in the paper industry’s case) to a mill to be incorporated into another recycled content product. Nothing is wasted. Sounds pretty circular to me.

False claim refuted by Paper Packaging Flow Chart

False Claim # 3: That post-consumer is ‘better’ because it replaces virgin material

Hogwash. Both pre-consumer and post-consumer replace virgin material. Both were made in a mill (once) and both are now recycled again (potentially many times).

And now for the unintended consequences of pushing 100% post-consumer content. If a company or a government specifies only 100% post-consumer content, what’s going to happen?  Some suppliers may be able to produce only 100% post-consumer content, but who’s going to verify it? Those off-cuts mentioned earlier will still be coming to a paper recycling mill from other customers. What’s the mill or converter supposed to do with them now? Dump them? That would not exactly meet the ideals of a circular economy now, would it? And what about a mill tempted to add just a little bit of pre-consumer to the mix? Who will know, except the mill?

There are also physical limitations of the material to bear in mind. Wood fibres, for example, can only be recycled between four and nine times before they become too short and thin to be used again. So, if all paper was required to be 100% recycled content, it wouldn’t be too long before you couldn’t make paper at all. An infusion of virgin fibre is always required somewhere in the system to keep the whole recycling loop going.

 So, what’s the solution? By all means specify a recycled content number, but give the industry the flexibility to meet the target by not specifying how much should be pre-consumer and how much post-consumer. There is far less pre-consumer material out there (because companies are economically motivated to reduce their production costs). And once it’s gone, it’s gone. If companies need more recycled content to make their products or packaging, they’ll be forced to get it from post-consumer sources. That’s how the market works. That’s why the corrugated box industry started targeting residential sources of used paper decades ago. It couldn’t get enough from industrial sources.

John Mullinder

John Mullinder, Executive Director, PPEC - Regular posts on environmental and sustainability issues impacting the Canadian paper packaging industry

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Climate change demands that our focus should be on improving paper and organics recovery, not fiddling around with plastic straws

Yes, plastic litter (any litter for that matter) and marine pollution is terrible, and we need to have a long hard look at our consumption habits and to reduce our use of fossil fuels. But when we are warned by the United Nations’ Intergovernmental Panel on Climate Change that we have only 12 years for global warming to be kept to a maximum of 1.5 C, our prime focus should surely be on achieving some “big hits” that will rapidly reduce current greenhouse gas (GHG) emissions.

In waste management terms, those “big hits” are reducing the methane being emitted from landfills; and getting more paper and organics out of them. In landfill, paper and organics emit carbon dioxide and methane. Reducing methane and other GHG, and their causes, should be our prime focus, not publicly announcing vague aspirational goals for plastics somehow getting to 100% this or that, with no penalties if they don’t get there. Excuse the cynicism but we’ve seen this movie before.

Where the focus should be

Focus number one should be capping methane emissions from landfill. These efforts are underway but need to be accelerated.

Focus number two should be addressing the material streams in landfill that emit GHG: organics and paper. Both are sizable chunks of Canada’s waste stream. And here’s the good news. They already represent two-thirds of what Canadians divert from landfill. Let’s build on this foundation.Materials Diverted 2016

Organics

Many provinces and cities now have active “green bin” organics recovery programs. And the national diversion of organics has climbed steadily in recent years (up 11% since 2008 to 2.6 million tonnes).

The leader in this effort has been Nova Scotia, which banned organics from landfill way back in 1996. Nova Scotians diverted 170 kilograms of organics per person in 2016; almost six times more than their provincial cousins in Saskatchewan. If we assume that Canadians consume organics in much the same way across the country, how come Saskatchewan and Quebec are so far behind? Is it geography, population density, rural/urban mix, lack of infrastructure, attitude, government priorities, leadership? All good questions.

And here’s the missed opportunity. If we applied Nova Scotia’s organics recovery numbers to the whole country, we could have expected 3.36 million more tonnes of organics diversion in 2016. That would have raised Canada’s overall waste diversion rate by 6.5% and eliminated some 638,000 tonnes of GHG. While there are new costs in adding organics programs these are somewhat offset by saving millions of dollars in avoided landfill costs and by tax revenues flowing to governments from new jobs in organics processing.

Paper

It’s a similar story with paper, the most widely recovered material in Canada. The leaders in paper recovery in 2016 were Quebec and British Columbia (136 and 130 kilograms per person respectively). Manitoba and Saskatchewan lagged far behind, at 47 and 41 kilograms per capita.

Let’s assume that paper consumption was similar across the country. If we applied Quebec’s 136 kilograms per capita rate to the rest of Canada this would have meant an extra 1.21 million tonnes of paper diversion; would have lifted Canada’s overall waste diversion rate by 2.5%; and would have eliminated some 145,000 tonnes of GHG.  It would also have given longer life to existing landfills, something that seems to be getting more and more attention from governments this year.

Add these two major streams together (paper and organics) and you have close to 800,000 tonnes of GHG reduction from Canadian landfills while boosting Canada’s overall waste diversion rate by almost nine per cent. Aren’t these targets worth setting? And we’re not even addressing other waste streams that could and should be included.

So, how do we get more organics and paper out of landfill? Disposal bans or generator levies. Only two provinces have them: Nova Scotia (which coincidentally has the lowest waste disposal rate in Canada) and Prince Edward Island. Metro Vancouver has shown it can be done with benefits in an urban area. Diversion of Paper and Organics

PPEC, representing the paper packaging industry, has lobbied various provincial governments to ban old corrugated boxes from landfill since 2015. We have seen three different ministers of the environment in Ontario on this issue over the years but there has been no action to date, just statements that “we will consider it.”Focus on Banning Old Boxes From Landfill

We estimated back then that a ban on the disposal of old corrugated boxes in Ontario landfills would reduce methane and carbon dioxide emissions by up to 175,000 tonnes a year (equivalent to taking 33,000 cars off the road or eliminating the annual energy emissions of 70,000 homes).

These used boxes shouldn’t be in landfill. Every single packaging mill in the province uses old corrugated collected from the back of factories, supermarkets, office buildings or from curbside to make new packaging, most of it 100% recycled content. We import similar used boxes from the US when we can’t get enough in Canada. It’s our feedstock. We need it.

In summary: the key to reducing GHG emissions from the waste management sector lies in provincial landfill policy:

  • capping the current emissions
  • ensuring that GHG-emitting materials like organics and paper don’t end up there;
  • and tipping the scales away from landfilling being cheaper than recycling.

Yes, it’s not easy, but it’s doable. And don’t get me started on the BS that recycling is dead!

 

(This completes our series of blogs on Statistics Canada’s most recent data on disposal and diversion of waste. Here are the links to the previous articles: Canada’s ‘worst performers’ in waste management in Canada: Manitoba, Saskatchewan, and Alberta (April 12, 2019); Canada’s ‘middle performers’ in waste management: Quebec, New Brunswick, and Ontario (March 27, 2019); British Columbians and Nova Scotians are Canada’s best recyclers (March 14, 2019)    Canada’s waste diversion rate slowly inches higher (February 28, 2019); Where’s the garbage coming from? More and more from homes (February 19, 2019); Good news and bad news in dumping of waste (October 11, 2018).

John Mullinder

John Mullinder, Executive Director, PPEC - Regular posts on environmental and sustainability issues impacting the Canadian paper packaging industry

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Fighting media ignorance (battle # 5,041)

Yes, we know that packaging is evil and that it should be legislated out of existence. But sometimes those ignorant throw-away lines about packaging waste really do rankle and must be corrected. Case in point: a recent article by Eric Reguly in the Globe and Mail newspaper.

In his beef with Amazon Prime’s home-delivery service, Reguly ignorantly sideswipes the humble corrugated box that delivers the goods (Beyond Zuckerberg, it’s time to hold Bezos to account, too).

The used boxes that Reguly complains about are certainly not “thrown away.”  In fact, they form the backbone of one of the world’s great commodity trades; are an export earner for Canada; and Delivery Boxes are not packaging wasteprovide the feedstock for most of the new boxes made in this country. Yes, most corrugated boxes made in Canada are 100% recycled content, primarily formed by recycling those very same used boxes again and again.

We are currently recovering about 85% of the corrugated boxes used in Canada. And in Ontario’s Blue Box system, have achieved an amazing 98% recovery rate, according to Stewardship Ontario. That is pretty impressive.

And this recovery is not “mostly at taxpayer’s expense”, as Reguly falsely claims. In British Columbia and Quebec, it is industry that pays 100% of the net cost for residential (Blue Box) recovery. Ontario, which is currently at 50% industry-pay, is headed to 100% too. In Saskatchewan and Manitoba, industry pays 75% and 80% respectively.

Glib and ignorant throw away lines perhaps, but not throw away boxes.

John Mullinder

John Mullinder, Executive Director, PPEC - Regular posts on environmental and sustainability issues impacting the Canadian paper packaging industry

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Will plastics problem spur the eventual return of deposits to Ontario?

Pile of plastic trashI love fish. Plastic not so much. This puts me in good company, it seems, with Prime Minister Justin Trudeau, who recently told the World Economic Forum that the “plastics issue” will be the main theme at the G7 leaders’ summit in Charlevoix, Quebec in June.

Trudeau’s announcement follows in the footsteps of Coca-Cola saying it intends to make bottles with 50% average recycled content by 2030 (12 years away). And Unilever calling for the consumer goods industry to step up its efforts to tackle the mounting challenge of ocean plastic waste and create a circular economy for plastics.

All good and stirring words. But how are they going to get there? Not using plastics in the first place is one option, of course. British frozen food retailer, Iceland, has just done that, committing to become the first major retailer globally to eliminate plastic packaging from all its own brand products by the end of 2023. But elimination aside, you need the most effective and efficient, not to mention the most “environmentally friendly” way to get plastics back. And what would that be?

Only 29% of plastics packaging is currently being recovered in Ontario’s multi-material Blue Box system. The Stewardship Ontario “recovery” rate for PET and HDPE bottles does the best of the plastics at 53%, followed by the mixed resins of “Other Plastics” at 32%, with plastic film lagging way behind at only 12 per cent. Nothing much has changed on the bottle front over the last 13 years of Blue Box EPR or “industry-pay” stewardship; the recovery rate for plastic bottles improving a paltry 3% over that time.

Is the answer throwing millions of dollars in promotion and education money at the good people of Ontario, to try and persuade them to increase the Blue Box plastics recovery rate from its current 29% to 50% or higher? It won’t work. Especially when there are no penalties for non-performance in the amended Blue Box program that Stewardship Ontario has passed on to the new Resource Productivity and Recovery Authority for approval. The plan indicates there will be a lot of talk about “problem materials” and maybe some research and development and “collaborative forums,” but no actual penalties for not performing.

So, what about the deposit option? Ontario is one of the few Canadian provinces not to have a full deposit/return system alongside its Blue Box. Traditionally, the Coke and Pepsi folks have been opposed to deposit schemes because they single out beverages, and the retailers have been opposed because they don’t want to become return-to-retail depots.

But maybe things are changing. Coca-Cola recently said it would consider “well-run” deposit systems. What exactly does that mean? Does it mean globally? Does it mean anything in the Ontario context? While those big questions remain unanswered, Coke is saying that it wants to get to a 50% recycled content average within 12 years. To do that you need recycled plastic feedstock, and a lot of it. Deposit schemes certainly provide that.

The recovery of plastic bottles and aluminum cans in Canada’s many provincial deposit/return programs is quite respectable. BC’s Encorp Pacific, for example, reports a 74% recovery rate for plastics and 82% for aluminum cans. In Ontario’s multi-material Blue Box, by comparison, the recovery rate for PET and HDPE bottles is 53% and aluminum food and beverage cans, a mere 42 per cent. (In fact, if you take out the non-PET (HDPE) from the bales, the real Ontario recycling rate is even lower. A direct aluminum comparison is a little tricky too. Deposit programs take only used beverage cans (UBCs). Non-deposit programs are more comprehensive, including cat food and other aluminum containers).

The plastic, steel, aluminum and glass industries may not say it publicly for fear of offending some of their major customers, but privately they are not at all opposed to deposit/return systems. And the reason is simple. They get far more material (economies of scale matter), and it’s in far better (less contaminated) condition. Quantity and quality count. On the other hand, deposit programs are known to be very expensive, with the transportation of light-weight, high-volume containers being a major cost.

A key question, of course, is what impact a deposit scheme would have on the major material remaining in the Blue Box. Paper today supplies 63% of the generated material, 75% of the recovered material, and 52% of Ontario Blue Box revenues. Basically, the Blue Box is a paper box. Would paper quality (and revenues) increase enough to make a difference?  Maybe if the stewardship body (or bodies) kept pounding on the collectors to reduce contamination, it might have some impact.

Any supportive decision by Coca-Cola, Pepsi and the retailers would clearly boil down to economics and avoided costs. We estimate that to get plastic bottles alone to a 50% recovery rate under the current Blue Box system in Ontario would cost stewards around $185 million, based on reported costs and revenues.

If you threw those plastic bottles instead into a deposit/return scheme and added other containers and factored in the avoided costs of contamination for all materials at both collection and processing stages, plus increased revenues for better quality product, including perhaps paper, then a deposit/return system with the Blue Box for paper might make sense, maybe. But you would still need the Blue Box for non-deposit containers. In British Columbia, for example, it’s understood that about 25% of the Blue Box is plastic, glass, aseptic/polycoated containers and metal material that’s not on deposit.

There are so many variables in this discussion and competing objectives. Lots of fish hooks too.

John Mullinder

John Mullinder, Executive Director, PPEC - Regular posts on environmental and sustainability issues impacting the Canadian paper packaging industry

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Packaging stewards should be rewarded for using recycled content

Recycled content is central to the “Circular Economy” approach that Ontario and some other provinces say they want to adopt. It keeps raw materials flowing through the economy longer, reduces the pressure to extract more virgin materials from the earth, and delays their eventual disposal as waste. It’s something which governments say they want to encourage, and for which stewards of paper products and packaging should be rewarded.

The Canadian paper packaging industry has spent millions of dollars over the years investing in cleaning and screening machinery so that it can re-use and recycle recovered paper. Packaging mills in Southern Ontario led North America in recycling old boxboard for the first time back in the 1990s. Today, some 94% of Canadians can recycle it. And today, most of the corrugated boxes and boxboard cartons made in Ontario are continuously made from 100% recycled content, a circular achievement in and of itself.

The paper packaging industry gets no credit for this effort, while in the commercial marketplace it competes against mostly virgin packaging alternatives. We have suggested the province level the playing field by setting a target of 40% average recycled content for all packaging sold in Ontario by 2020 and an average of 70% within 10 years. This would place Ontario firmly on the path to the circular economy it says it wants, and create a more level playing field between materials at the same time.

An alternative to provincial regulation is a recycled content credit within the Blue Box funding formula itself. This is not a new suggestion. The producer responsibility organisation in Quebec, Éco Entreprises Québec, already has one. And while Stewardship Ontario does float the idea of a recycled content credit in the draft outline of the new Blue Box plan it is currently working on, its support seems rather tepid.

That’s because some Ontario stewards have objected to the concept in the past. Here are three historical objections, and our responses to them.

  1. That assessing recycled content is an administrative burden and costly to track and report.

We think this objection is way overstated. For paper materials we have independent third-party certifiers and chain-of-custody certifications as to where paper materials are coming from, whether from virgin or recycled sources, or a mix of the two. Chain-of-custody certification is an environmental metric supported by the global Consumer Goods Forum, of which most leading Canadian brands and retailers are members.

Making suppliers prove that they have internationally accepted chain-of-custody certification would seem to reduce the administrative burden on stewards and provide a good kick-start to the circular economy at the same time. It would also force other materials to develop chain-of-custody certification programs if they haven’t already done so.

Or stewards could use independently certified industry averages. PPEC has been tracking its members’ use of recycled content for over 25 years and it’s quite willing to open its books to a confidential third-party review. A sliding scale of recycled content usage would reward a lot more stewards and probably be more palatable and make any administration easier. Besides, won’t the new body Ontario has created to bring in the Circular Economy (the Resource Productivity and Recovery Authority) be monitoring this anyway?

  1. The funds to credit stewards using recycled content must come from other stewards (i.e. it is cross-substitution).

Well yes, it is. That’s why you do it, to encourage other stewards to be more circular, to reduce the overall environmental burden of the basket of goods that is the Blue Box, for the common benefit. This is the very same principle that’s supposed to apply to those materials that are recycled through the Blue Box versus the ones that are not. What’s the difference? It’s the same principle of rewarding preferred behaviour.

  1. Federal regulations limit the use of recycled content in food-contact packaging. Making recycled content a requirement would be unfair to those stewards.

First, federal regulations on food-contact packaging apply to all materials (i.e. it is material-neutral). Second, recycled content is not excluded. Food safety is the key issue and the onus is on the brand owner to guarantee food safety, whether through Health Canada “No Objection Letters” or through FDA approvals. It comes down to the material’s direct and indirect contact with the food and the element of risk to humans.

Is it unfair to single out “food” stewards?  No. They choose to be producers of foods and the safe delivery of food is part of that. Just as a producer of a washing machine or a microwave is “forced” to use a large package to have his or her product delivered. Or a perfume manufacturer with an elaborately designed stand-out boxboard carton. All choose of their own free will to be in those lines of business. That’s the game they’ve chosen to be in. Whether they can use recycled content or not in their delivery packaging is part and parcel of that original choice.

In summary, rewarding those who use recycled content is a good, fair, and effective way to achieve a circular economy and to level the playing field between “circular” and “non-circular” performers. Isn’t that what we’re supposed to be doing?

John Mullinder

John Mullinder, Executive Director, PPEC - Regular posts on environmental and sustainability issues impacting the Canadian paper packaging industry

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Ontario Blue Box recovery rate slips, but paper steady

Draft Blue Box Recovery Rates 2016

The reported recovery rate of Ontario’s residential Blue Box system has fallen to its lowest level since 2005. The draft recovery rates, to be finalised by Stewardship Ontario in December, show a 2016 recovery rate of 62.4%, down 2% on the previous year. This will make the recent “request” by Ontario’s minister of environment and climate change for a new Blue Box recovery rate of 75% rather interesting.

Some 75% of what’s currently being recovered is paper of one kind or another, the same as it was back in 2003. Printed paper (newspapers, magazines and catalogues, telephone books and printing and writing paper) has the highest recovery rate overall (81%), followed by glass packaging (70%), paper packaging (67%) and steel packaging (63%).

Paper packaging is the only material grouping whose recovery rate has either stayed at the same level or improved in every category (boxboard up 9%), with corrugated boxes again the recovery leader overall at a hard-to-believe 98 per cent.

The glass recovery rate has dropped significantly from 2015 but the Blue Box laggards continue to be aluminum and plastics packaging at 38% and 29% recovery respectively. Plastics packaging recovery has gone down in almost every category and now represents 43% of what ends up going to disposal (on a weight basis). It’s also by far the most expensive material to recover (the net cost of recovering plastic film, for example, is listed at $2,646 a tonne).

Here are the latest (draft) numbers for 2016 with a comparison to 2015 and way back to 2003.

Estimated Recovery Rates 2016

John Mullinder

John Mullinder, Executive Director, PPEC - Regular posts on environmental and sustainability issues impacting the Canadian paper packaging industry

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Recycled content must be recognised in setting circular economy targets

The Ontario Ministry of Environment and Climate Change (MOECC) is in the process of considering what it calls specific material “management” targets for Ontario Blue Box recyclables such as paper, plastic, glass, steel and aluminum. It has already stated that it wants to see a collective 75% Blue Box diversion rate, up from the current 64 per cent.

But before we get into the details of specific targets for materials, there’s a major issue that we need to address that has everything to do with the circular economy that the minister and the province say they want to embrace. And that’s the issue of recycled content. The use of recycled content keeps materials flowing around in a circular loop for as long as possible.

Most corrugated boxes and boxboard cartons made in Ontario, for example, are already 100% recycled content: made from used boxes and paper collected from the back of factories and supermarkets, from offices and hospitals, and from curbside (Blue Box) collection and depots. The Ontario paper packaging industry achieved this milestone over many years with the expenditure of millions of dollars in new cleaning and screening equipment. Indeed, the mills of Southern Ontario led North America in incorporating residentially collected old boxboard into their recycling mix back in the 1990s. Today some 94% of Canadians can recycle it.

Ontario Blue Box chartThe industry’s environmental council, PPEC, has been very public in tracking and reporting on the industry’s progress towards a more circular economy. But now its members find themselves competing in the marketplace against virgin materials that have made minimal or little progress towards higher recycled content or “circularity.”

The plastics industry, for example, does not publish any numbers on average recycled content that we can find, and plastics’ overall Blue Box diversion rate is frankly poor (32%). Plastic film diversion has gone from 6% to 12% over the last 13 years, and polystyrene from 3% to 6% over the same period.

If we are going to have a level playing field between materials, we need public policy that encourages the greater use of recycled content and/or some recognition of recycled content achievement in the Blue Box funding formula and/or performance targets. We don’t see it at the moment, and yet paper packaging faces increasing competition from cheaper virgin plastics. How about the province set a target of 40% average recycled content for all packaging sold within Ontario by 2020 and 70% by 2027 ? That would put us on the path to a more circular economy and create a more level playing field at the same time.

John Mullinder

John Mullinder, Executive Director, PPEC - Regular posts on environmental and sustainability issues impacting the Canadian paper packaging industry

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