Watch this space: How will ineligible sources be impacted by transition to IPR?

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In the June 3 article published by the Globe and Mail, Environment Minister Yurek has been quoted as saying that despite the pandemic, Ontario’s draft residential Packaging and Printed Paper (PPP) program regulation(s) are still on track to be made public in the coming months. While details are not yet known, municipalities can begin to anticipate what the initial regulation(s) may contain and start preparing for the impact of transition. One example of this could be building out a plan to address ineligible sources of PPP.

Ontario’s current regulation does not require local municipalities with less than 5,000 people to provide Blue Box recycling services, however it does not prevent these communities from voluntarily establishing a Blue Box program and receiving funding. The Blue Box Program Plan excludes non-residential sources such as schools, municipal buildings, public spaces, and Business Improvement Areas (BIA). The Globe and Mail article highlighted concerns with the fact that, over the decades since O.Reg 101/94 was passed, many communities below the population threshold have voluntarily opted to deliver Blue Box recycling services to residents. Under the new regulation(s), Producers may no longer be obliged to provide service to these communities. Many municipalities also collect from non-residential sources, which similarly producers may not be obliged to service under the new IPR arrangement.

Photo courtesy of the City of Cornwall.

Under current system, some small communities and non-residential sites receive service

While not currently required, some municipalities with a population of less than 5,000 offer recycling services to help preserve local landfill space. Often, municipalities that provide recycling services for local parks, schools, public spaces and BIAs do so as it provides the opportunity to deliver consistent servicing and messaging to the resident whether they are at home, school, work or play. It is viewed as an important part of promotion and education (P&E) efforts and a chance to reinforce good recycling habits.


A potential change to service levels

If the new regulation(s) do not require provision of recycling service by Producers to smaller communities or to non-residential sites, municipalities will need to decide whether to continue servicing them at their own cost or to transfer the costs where possible. Given the strain on municipal budgets in the aftermath of COVID-19, local governments will want to understand the financial impact and diversion opportunities now in order to ready themselves for the choices they may need to make as a result of transition. Starting the planning process now will give municipalities time and opportunity to collaborate with all affected parties to help determine potential new collection opportunities.


Engage with stakeholders now to prepare for potential change

Charlotte Ueta, Project Director of Business Transformation (EPR), for City of Toronto, and Erwin Pascual, Manager of Waste Planning for the Region of Peel recommends initiating the planning process as soon as possible to engage with stakeholders to a) make them aware of the potential for change and b) begin developing potential solutions. Their ‘action plan’ advice, while straight forward, requires time to implement. Here’s are some of their tips to help municipalities get started:

  • Ensure the municipality has an accurate count of sources that might be excluded.

    For small communities ensure the number of households served by your curbside program or depot is up to date. All program operators should also ensure the count and locations are updated for parks, schools, BIA stops, and public spaces (e.g., community centres or bins lining the streets in the downtown core). A review of current collection contracts will help with this task. Check to see how your municipality handles their administration buildings (e.g., City Hall), nursing homes, service groups (e.g., Lion’s Club), and churches.

  • Develop a stakeholder engagement strategy.

    A stakeholder engagement strategy will ensure a) all potentially ineligible sites are aware of what’s happening and b) provide an opportunity to discuss potential alternative collection options.

  • Explore cooperative procurement opportunities where possible.

    For smaller communities, explore cooperative procurement for services across municipal boundaries. For non-residential sources, encourage libraries, police and fire stations, post-secondary institutions and other small to mid-sized organizations to work together to build back some of the economies of scale lost by separation from the residential programs. The goal in is to build a ‘milk run’ of sites to service to create a volume that promotes operational efficiencies that allow for better pricing.

  • Solicit input on potential new collection arrangements now to determine the most cost-effective collection options.

    Strategize with your municipal colleagues from other communities. Consider talking with your current collection operator about options to break out these stops and collect them under a separate contract.

  • Ensure senior management and council are made aware of the potential impacts.

    Communicate with leadership teams and council about the number of sites that will be affected, the financial impact and the diversion tonnage that could be lost.


Seeking help with planning issues like these? The CIF still has limited funds available through the 2020 REOI for transition related initiatives of a collective benefit, on a first come first served basis. Please contact Carrie Nash to discuss your needs.

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