Earlier in October, the Federal government released a discussion paper “A proposed integrated management approach to plastic products”, outlining a proposal to ban single-use plastics starting in 2021. How does the Federal government’s proposed management strategies for single-use packaging align with Ontario’s draft blue box regulation?
To kick off Ontario’s 2020 Waste Reduction Week, Ontario’s Ministry of the Environment, Conservation and Parks released a proposed regulation to govern the blue box program under the Resource Recovery and Circular Economy Act, 2016 (the RRCEA). The regulation will transition Ontario’s Blue Box program, covering paper products and packaging (PPP).
For an introductory review see the October 29 Blog “A first look at the proposed new blue box regulation”.
Ontario adding “single-use packaging-like” products and items
A notable requirement in the draft Ontario regulation was the addition of single-use packaging-like products and items, such as stir-sticks, straws, cutlery, and coffee pods. Over the last decade, the Government of Canada recognized in its discussion paper “A proposed integrated management approach to plastic products”, that the growing use of these items has presented challenges, such as:
- hampering of recycling processes, due to small format, material choice and contamination; and
- causing pollution in the environment and harm to wildlife through litter or accidental releases.
Federal Government steps towards banning single-use plastic products
In the discussion paper, the Government of Canada says it is taking steps toward eliminating plastic pollution in Canada, including potentially banning or restricting certain harmful single-use plastic products under the provisions of the Canadian Environmental Protection Act, 1999 (CEPA). Items identified in the initial analysis to ban included stir-sticks, straws, and cutlery.
Below are the main objectives of the provincial and federal approaches.
Province of Ontario
- address the serious problem of plastic pollution
- improve recycling across the province
Government of Canada
- eliminate or significantly reduce single-use plastics entering Canada’s environment
- reduce the environmental impact of plastic products overall
- conserve material resources by increasing the value recovery of plastics
Generally speaking, these two approaches are complimentary to each other as the proposed federal ban reduces the use and distribution of single-use plastic products and the draft provincial regulation intends to establish a system to appropriately manage items remaining in the system.
Ontario’s choice to include these items aligns with British Columbia’s September announcement to support local bans by municipalities of single-use and packaging-like products, as well as expand its list of these items in the residential recycling EPR program by 2023. This is a clear movement towards more cross-country harmonization on PPP regulation, consistent with the federal initiatives in this area.
Unanticipated consequences for today
One concern raised by municipalities is that the recent announcements made across Ontario may result in residents incorrectly assuming plastic stir sticks, straws, coffee pods, cutlery, etc. are allowed in provincial Blue Box program today. This may lead to additional “similar” plastics being improperly placed in recycling, resulting in higher contamination rates overall. Municipalities are encouraged to monitor their programs for any upticks in contamination and remind residents of what materials are currently accepted.
Feedback due in early December
Ontario’s proposed regulation is posted on the Environmental Registry of Ontario for 45 days, and comments are due no later than December 3, 2020.
The Government of Canada is seeking comments on its proposed integrated management of plastic products by December 9, 2020.