In April 2022, I wrote about the evolving landscape for carton recycling in Canada. In 2023, we continue to see changes, and I have highlighted them for you in this blog.
In Ontario, a number of developments have taken place to prepare for the first phase of the Blue Box system’s transition to full producer responsibility happening in less than three months. In January, Circular Materials Ontario and Ryse Solutions announced the execution of the System Access Agreement to operate the common collection system (CCS) in Ontario. The Agreement supports producer compliance and sets out the administrative, operational and procurement policies and practices by which the common collection system will be operated. We spoke about this in our summer newsletter.1 Moreover, as administrator of Ontario’s common collection system, Circular Materials finalized an agreement with the City of Toronto for the collection of Blue Box Materials across the city. Under the agreement, the City of Toronto will continue to provide blue box collection services to its residents during the transition (2023 to 2025). The other large programs to transition on July 1 are the cities of London and Ottawa. Finally, the Canadian Beverage Container Recycling Association (CBCRA) released its program plan for the expansion of its Recycle Everywhere program in Ontario as well as its Container Recycling Fee (CRF) schedule (the CRF is the amount beverage producers are charged to cover the cost of recycling the beverage containers they produce) and announced June 1 as the new launch of its program in Ontario.2 For a refresher of what this program, which has been successfully operating in Manitoba since 2010, entails read our April 2021 blog.
In Quebec, the final Regulations modernizing both the curbside EPR system and the deposit return system (DRS) were released in July, 2022.3 On the deposit side, the system is to begin roll out on November 1 of this year. Cartons are to be added two years later (November 2025). The Quebec Beverage Container Recovery Association (QBCRA), the new PRO formed to operate the modernized DRS, announced its Board of Director December 16 of last year. Pilots have been running in different locations of the province, with the latest round focused on testing “bag-drop” return type approaches in unstaffed locations. These pilots are set to wrap-up at the end of this month.
Cartons holding non-beverages e.g., soup and cream, will continue to be managed via the province’s curbside system. To this end, Eco Enterprises Quebec (EEQ) received official designation as the PRO responsible for the new industry-led EPR system for curbside recycling in October of last year. We wrote about this in our Winter newsletter. As a reminder, the new system will be effective January 1st, 2025. To this end, EEQ has partnered with Reseau Environnement to deliver webinars intended for municipalities ahead of the transition (available in French only). The first one, held February 21st, focused on municipal agreements and groupings. EEQ indicated they were looking to reduce the number of municipal entities that procure collection services to about 150, from the current 411. It also provided the minimum threshold of 14,500 doors/30,000 inhabitants for optimized collection services. The second webinar focused on the contents of the framework agreement for collection with municipalities.
Under the new framework, EEQ will be directly responsible for all post-collection-related activities. On this front, in early December it launched a tendering process for a new sorting center serving the east end of the island of Montreal.
One aspect that differentiates Quebec’s new EPR framework from Ontario’s is its scope, as it includes all generators (not just the residential, public space, and school sectors). This obligation is phased over time, with all schools, CEGEPs,4 and exterior public spaces and ICI locations that are already serviced in 2025; universities, all institutional and commercial generators, and two thirds of public spaces identified in EEQ’s plan in 2027; the remaining of the public spaces identified in EEQ’s plan in 2028-29; and all industries in 2030 and beyond. On the industry side, EEQ has indicated it is leaning towards a hands-off approach similar to the one in place in Belgium through Valipac, which relies mostly on reporting.
In New Brunswick, Circular Materials Atlantic submitted, on behalf of producers, its stewardship plan for approval in October 2022. Once approval is granted, CMO will have six months to prepare for launch. Milk, milk substitute, and non-beverage cartons will be included in this new system while other beverage cartons will continue to be managed in the deposit system.
Speaking of which, the amendments to the Designated Materials Regulation under the Clean Environment Act to convert the beverage containers waste diversion program to an extended producer responsibility (EPR) model came into force on April 1, 2023. Producers will be required, via their PRO (the former Encorp Atlantic Inc. has transformed from a for-profit entity into the not-for-profit Encorp Atlantic / Atlantique) to submit a stewardship plan by August 1st of this year which sets performance measures and targets, by material type, amongst other things. They will also have to enter into agreements with return facilities (i.e., depots, known in New Brunswick as “redemption centres”). Effective April 1, 2024, the PRO will be able to set a non-refundable Container Recycling Fee (CRF) and increase the refundable portion of the current 10 or 20 cents deposit paid by consumers to a full refund. The non-refundable CRF will be used to fund the operation of the system, similar to what is in place in the Alberta and BC deposit systems. Currently, a half-back system is in place, whereby half of the deposit is returned to the consumer when containers are redeemed. Up until now, only half of the un-returned deposit (i.e., one quarter of the total deposit value) was used by Encorp to fund the system, and the other half was handed over to the province’s Environmental Trust Fund. Finally, Encorp will be responsible for deploying province-wide promotion and education pertaining to the beverage container waste diversion program and will be providing tools and technologies to depot operators with the aim of improving access and convenience for consumers returning and redeeming deposit-bearing beverage containers.
Newfoundland began consulting on an EPR approach to packaging & paper products recycling in the first half of 2022. Two “What We Heard” reports have been released: the first one in June, 2022 and the other one in March, 2023.
On April 3rd, Saskatchewan announced it had completed the amendments to The Household Packaging and Paper Stewardship Program Regulations, 2023. The new regulations were posted on April 6. Key changes include transitioning to a program fully funded and operated by producers through a phased-in approach, defining the waste management hierarchy, and establishing requirements for material-specific recycling and diversion targets, amongst other things. Producers are required to develop a plan, which will be submitted for approval by September 27, 2023. More information, including Product Stewardship Program Development Guidelines, is found on the Ministry’s web page.
Lastly, in Alberta the EPR Regulation came into force on November 30, 2022. Producers of single-use products, and packaging and paper products from residential sources have two years to plan and implement the system, in which non-beverage cartons will be obligated, to start April 1, 2025. Similar to Ontario’s new Blue Box regulatory framework, Alberta’s Regulation does not require the development of a stewardship plan, but rather relies on minimum service standards, such as frequency of collection.
In summary, a great deal of activity continues to take place on the Canadian waste diversion and EPR landscape, with many jurisdictions advancing on the developments that we initially reported on in 2022. We are hopeful that these will continue to support our goal of growing the collection and recycling performance of food and beverage cartons across the country.
 At the time of writing the article, the Resource Recovery Alliance was one of three full-service PRO, it has since been acquired by Circular Materials. Moreover the PRO H2Compliance has since registered with RPRA under the Blue Box Regulation.
 Initially, the launch date had been set for April 1, 2023.
 The acronym CEGEP stands for “Collège d’enseignement général et professionnel”, which are publicly funded colleges providing technical, academic, and vocational programs in Quebec.