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Should Ontario make producers pay for filling up our landfills?

Updated: Mar 29, 2021

Policy Brief by Lauren McCoy

On October 19, 2020, the Government of Ontario proposed a new regulation to transition the responsibility of blue bin management to producers, or those responsible for waste generated from products and packaging, from the provincial government (1). But what does this change mean, and will it truly be as helpful as it is made out to be?

Currently in Canada, waste management and recycling services are primarily administered at the provincial level and carried out by local municipalities (2). Within this system the contents placed in blue bins are brought to sorting facilities to be separated into broad categories of paper, plastic, and glass. From there, the materials are commodified and sold as raw materials with the revenue used to partly cover the cost of operating these recycling facilities (3).

This model has proven insufficient in recent years. Despite Canada’s emphasis on recycling initiatives, it is estimated that less than 7% of Ontario’s waste is recycled (4), while 70% of Canada’s total waste ends up in landfills (5). This is the result of several issues in our current recycling system. Once blue bin materials are collected the waste is sold to private recycling companies, and as a result, municipalities lose their jurisdiction over where it ends up (6). Due to Canada’s minimal processing capacities for recycled materials the Canadian blue bin system relies on international corporations, principally from China, to purchase most of its waste. Once exported, the recycled materials are again sorted, where the invaluable plastic is burned in landfills overseas.

The issue with this system beyond the financial and environmental cost of transporting that volume of waste is that the majority of exported waste is worthless (7). Much of what Ontarians place in their blue bins is unusable - either contaminated by food residue (8), soiled by the time it is collected, or simply not recyclable materials to begin with. It is no surprise then that most of what is placed in the blue bin ends up in landfills to be burned or dumped regardless, either in Canada or overseas (9). The increasing cost and complexity of sorting that results from the mixing of waste with recyclable materials has led China in to impose strict regulation on recycling imports in January 2018, banning contaminated recycling imports and effectively ending Canada’s waste exports (10). With no means of processing recycling locally and no source to sell internationally, tonnes of waste are piling up in Canada (11).

Under the new proposed regulation, the Ontario government will replace our current recycling management system with an Extended Producer Responsibility model (EPR) where producers will have full operational and financial responsibility for managing the disposal and reuse of the materials they sell to Ontarians. The regulation also aims to set a minimum threshold of the amount of recyclable waste producers must generate compared to nonrecyclable waste. Through an EPR model, the Government of Ontario aims to increase product recovery while minimizing the environmental impact of waste (12).

There are several ways in which an EPR model intends to reach these goals. By ensuring producers take on the operational and financial responsibility for the end-of-life of their products, EPR will incentivise producers to design their packaging with recycling targets in mind – minimizing their material management cost which in turn reduces the amount of waste that goes to landfills. By operating the collecting and sorting infrastructure necessary to manage Ontario’s recycling system, an EPR model also encourages producers to both invest in the recycling infrastructure that helps them meet their quotas (and therefore develop more efficient and effective technologies to reuse our waste), and for producers to then create markets and innovative uses for these materials (13).

In addition to the shift into an EPR model, the proposed regulation aims to expand recycling services to communities currently without blue bin programs (14). Communities excluded from blue bin services such as communities in Northern Ontario, interested Indigenous communities (15), and rural towns with populations under 5,000 will now have access to recycling services (16). The regulation also aims to expand the list of accepted materials in the blue boxes to include single-use plastics that are already commonly placed within blue bins including foil, wraps, trays, straws, plastic cutlery, and stir sticks (17).

Although on the surface this approach seems to address the current recycling crisis, there are shortcomings to the EPR model that have so far been disregarded. There is no doubt that the blue bin proposal is a welcome new change and a step towards the right direction, especially considering the failure of our current recycling program. Environmental groups are largely in favour of this move; however, much concern remains with the policy’s implementation and scope (18).

For one, environmentalists have been quick to point out that the new blue bin program only targets residential waste (19). In Ontario’s waste management systems, waste is generated in two areas – residential waste produced by households and members of the Industrial, Commercial, and Institutional (IC&C) sector (20), which include hospitals, hotels, office buildings, shopping complexes, restaurants, schools, and large manufacturing establishments (21). While residential waste is not unsubstantial, this new regulation does not address the nearly two thirds of Ontario’s waste produced by the IC&C sector (22).

Others critique that the base targets proposed by new blue bin regulations are too limited in scope (23). While Ontario municipalities have already begun planning their personalized transition towards an EPR model, the official move will occur in three stages between 2023-2025. Only in 2026 will producers be required to provide their services to eligible communities and meet their recycling quotas (24). For many, this 3-year transition period is too long a delay to enforce binding targets (25). Ontario’s Green Party Leader Mike Schreiner echoes these concerns – applauding the proposal but urging these changes to happen faster and in tandem with other environmental-safe policies, such as banning plastic water bottles and coffee cups (26).

The prospect of increasing the list of accepted materials to the blue bin collection is also a concern to those familiar with recycling systems. By adding more items to the blue bin collection, there is concern that the complexity and cost of a system already struggling to manage recyclable waste would be exacerbated. It should be noted as well that not all recycled materials are equally valuable – while some items can be easily recovered and sold for a profit, the cost of recovery for other items override the worth gained from recycling. Rather than adding more items, some environmentalists are suggesting that efforts should be made to limit what goes into the blue bin so that materials can be profitably sold (27).

There are also concerns that this current proposal inadequately addresses how complex the EPR model will be to properly implement. Some have accused the proposal as being focused on earning public appeal with minimal focus on actual implementation, leaving the complex but critically important work for later. By delaying the creation of a proper plan, there is concern that this policy will be unable to enforce its targets and goals on top of existing complications concerning the integration of new lightweight, composite packaging from producers into the current recycling system (28). The material manufactured by producers often differs from the typical materials recycled, making it difficult to collect, challenging to sort, and nearly impossible to sell (29). Although the EPR model is intended to craft innovative solutions to manage and create a market for their lightweight waste, the realities of shipping often places constraints on how producers design their packaging. Other factors, including material transport, product protection, shelf life, and branding, often come before environmental concerns (30).

However, the brunt of criticism falls to the actual goals and purpose of the EPR model. With the EPR model, the focus lies entirely in improving and increasing recycling rates. This falls in line with the rationale of many Canadians, which according to a 2019 York University study, view recycling as the most desirable and environmentally friendly end-of-life scenario for waste (31). However, this emphasis on recycling largely disregards actual environmental outcomes. While recycling is certainly better than filling landfills, it is far from the most effective approach to living sustainably. Limiting the waste we produce should be our primary focus and would solve many of our current environmental and waste management concerns - reducing both the waste piling up in landfills and the cost of sorting through recycled materials (32). The true battles lie with meaningfully altering our economy of waste, and many are concerned that focusing on marginally effective recycling programs drives focus away from impactful change (33).

So what can you do now? For one, it is important to reduce the amount of waste you and your household are producing. Recycling as it stands is not nearly as effective as we need it to be, nor does it have the environmental impact we think it does. Recycling is not bad, but it simply is not enough to tackle our current environmental crisis and must be supplemented with other strategies to reduce environmental degradation.

Secondly, when you do recycle it is critical to be mindful of how you organize and dispose of your waste. All information on recycling services in your municipality can be easily found on your town’s websites. Before throwing something away, be sure to check what materials go into each designated bin and what condition the materials need to be in to be properly disposed of. Simply washing our plastic containers before throwing them away is a simple way to ensure that the plastic you recycle is recycled. This may seem tedious, but this small step goes a long way to help ease the process of sorting and organizing recyclables.

Lastly, it is important as Ontarians to hold our government accountable. The environmental changes that have begun to be implemented are the result of your activism and hard work. It is necessary to continue to place that pressure to ensure meaningful change in building a sustainable way of life. Implementing the EPR model in Ontario is an important first step towards creating a green future, but much more work needs to be done to address the environmental crisis that we currently face. Contacting your regional office on environmental concerns is a great way to voice your concerns and ensure your interests are being acknowledged by the province. Below I have provided some links to the Government of Ontario website to help you locate who to contact if you wish to voice environmental concerns regarding the new EPR model or any other green initiatives. I also encourage you to check out Climate Action Carleton’s (@climateactionCU) current campaign to divest Carleton University from the fossil fuel industry, where they provide resources to help you get involved in fighting for a sustainable future.


The first link will take you to a search engine which will help you figure out which Ministry of the Environment your town or city is located within.

Once you know your district, the second link will list the different regional offices and which districts and municipalities they cover. From there you can find the list of the regional or district offices and employees to contact to discuss environmental concerns in your area:

Finally, this last link is the contact information and organizational directory of the Ontario’s Ministry of the Environment, Conservation and Parks:

  1. A proposed regulation, and proposed regulatory amendments, to make producers responsible for operating blue box programs,” Government of Ontario, last updated October 19, 2020,

  2. “How Waste is Regulated in Ontario,” Recycling Council of Ontario, accessed November 2020, -regulated/.

  3. Matt Gurney, “Ontario’s blue-bin program is in serious trouble,” TVO, October 19, 2020, program-is-in-serious-trouble.

  4. “Banning plastics is just a start on reducing our mountain of waste,” Star Editorial Board, Toronto Star, October 26, 2020,

  5. Gurney, “Ontario’s blue-bin program is in serious trouble.”

  6. Simpson, “The blue bin charade.”

  7. Gurney, “Ontario’s blue-bin program is in serious trouble.”

  8. Simpson, “The blue bin charade.”

  9. Gurney, “Ontario’s blue-bin program is in serious trouble.”

  10. Laura Parker, “China's ban on trash imports shifts waste crisis to Southeast Asia,” Natural Geographic, November 16, 2018, -malaysia/.

  11. Simpson, “The blue bin charade.”

  12. Government of Ontario, “A proposed regulation.”

  13. Calvin Lakhan, “The whole package?” Resource Recycling, October 26, 2020, package/.

  14. Government of Ontario, “A proposed regulation.”

  15. Ibid.

  16. John Rieti, “Ford government reveals proposed changes to blue box recycling program,” CBC News, October 19, 2020,

  17. Government of Ontario, “A proposed regulation.”

  18. Rieti, “Ford government reveals proposed changes to blue box recycling program.”

  19. Rieti, “Ford government reveals proposed changes to blue box recycling program.”

  20. “How Waste is Regulated in Ontario,” Recycling Council of Ontario, accessed November 2020, regulated/.

  21. York University. “IC&I.” Waste Wikipedia.

  22. “Concerns raised about changes to Ontario’s blue box programs,” CBC News, filmed October 2020,

  23. CBC News, “Concerns raised about changes to Ontario’s blue box programs.”

  24. Government of Ontario, “A proposed regulation.”

  25. CBC News, “Concerns raised about changes to Ontario’s blue box programs.”

  26. Rieti, “Ford government reveals proposed changes to blue box recycling program.”

  27. Gurney, “Ontario’s blue-bin program is in serious trouble.”

  28. Star Editorial Board, “Banning plastics is just a start on reducing our mountain of waste.”

  29. Lakhan, “The whole package?”

  30. Ibid.

  31. Lakhan, “The whole package?”

  32. Ibid.

  33. Star Editorial Board, “Banning plastics is just a start on reducing our mountain of waste.”

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