By Rachel Kagan
The critical importance of getting Extended Producer Responsibility right for Canadian businesses, consumers and the environment
As the national voice for the Canadian paper-packaging industry on environmental issues, the Paper and Paperboard Packaging Environmental Council (PPEC) has long been actively engaged in exploring the issue of Extended Producer Responsibility (EPR) programs and performance data, as well participating in by monitoring consultations about new or changing programs.
In basic terms, EPR is a government policy approach in which a producer—i.e. a business—is made financially and physically responsible for ensuring their packaging is properly managed at the end of its life, meaning that it is diverted from landfill and responsibly recycled.
The EPR legislated programs can either be full producer-responsibility models, where producers fund and operate recycling programs, or they can be cost-share models, where producers fund a portion of costs of programs that are run by municipalities as part of their overall waste-management services.
Businesses obligated by these legislated programs are required to submit annual reports containing the weights of materials put into the marketplace in that province and to pay fees for those materials, which are used to fund the costs of recycling.
In Canada, legislated EPR programs are provincially regulated and have been mostly applied to managing recyclables in the residential sector, while paper and packaging from the IC&I (Industrial, Commercial, and Institutional) sector—which includes office buildings, factories, malls, etc.—is managed separately in business-to-business relationships.
But these programs are changing. We are currently in the midst of a shift from the cost-share, municipally-operated model to a full producer-responsibility model.
Under a full producer-responsibility model, municipalities are no longer the go-to operator of these programs.
If they wish to continue their role as a service provider, they will have to agree to the terms set by industry.
If not, industry will negotiate with collectors, processors, and recycling facilities directly.
The map infographic displayed here shows the status of provincial packaging and paper EPR recycling programs: specifically where a legislated program is in place, and if it is in fact changing.
Ontario, Quebec, Manitoba, and Saskatchewan, which all currently have cost-share models, are in the process of changing to full producer-responsibility models.
Only one province—British Columbia—currently has a full EPR model where obligated businesses pay 100 per cent of the costs of recycling paper and packaging, but they also manage and operate the program.
The map also shows which provinces are developing new programs—which include Alberta, New Brunswick and Nova Scotia—and which are in the pre-regulation phase, where the government is consulting with stakeholders on their plans to develop new EPR regulations.
The latter includes Yukon, Northwest Territories, and Newfoundland and Labrador.
With so many programs transitioning to new program models, it is important to keep a close eye on what is happening.
The PPEC monitors EPR programs because recycling is a key issue for the paper-packaging industry, since recycled paper-based materials are an important supply of our industry’s feedstock.
The term Extended Producer Responsibility is not new. It essentially means producers taking responsibility for their packaging at the end of its life, making sure it is diverted from landfill and recycled.
These are all things that the industry is doing already. It is no coincidence that the average recycled content of the major paper-packaging grades—containerboard and boxboard—made in Canada is over 80 per cent.
Our industry is actively seeking out those recycled materials, which keeps valuable raw materials out of landfill and reduces the need to extract virgin materials.
Generally speaking, much of the paper packaging generated by Canadian households is not only collected in Blue Box recycling programs, but is also actually recycled, allowing PPEC member mills to use it for producing new paper packaging products.
But there are challenges with EPR programs.
While PPEC advocates for several positions regarding EPR, the one we believe needs to be highlighted most urgently one is the role of the consumer.
While PPEC understands that EPR involves producers taking responsibility for the management of their packaging, it is critical to acknowledge that waste management is a shared responsibility.
We all have an important role to play—especially consumers.
It cannot be overstated how important the role of the consumer is to recycling programs, which will only be successful if they are aware of and understand their role to properly prepare and separate the recyclables from their waste and from their organic materials at the source.
In our submissions and discussions with government, we explain that it is ultimately the consumer who makes the decision of how to dispose of their waste and recyclables, and the more aware and educated they are, the more likely they are to clean and empty their recyclables—helping increase diversion rates and reduce contamination.
The higher the contamination, the less material gets to be recycled—leading to more waste. We believe that residents that are informed and engaged will produce the best quality recycled product with the least amount of contamination.
It is critical for our industry that consumers do their part and recycle, as our member-companies heavily rely on recycled materials to make their paper-based packaging.
Another significant challenge is getting the right data, as key data are not always readily available, consistent, or comparable.
Provincial stewardship organizations are required to publish performance data of their programs each year.
While some organizations provide general information about paper packaging as a whole category, while others provide more detail including the composition and type of materials —i.e. OCC (old corrugated container) or boxboard.
Meanwhile, some organizations only provide the collection data—i.e. what’s picked up at the curb—rather than what actually gets recycled.
It is our hope that the current evolution of EPR will result in improvements to recycling, and that the pending moves to full producer responsibility will result in:
- Harmonization of programs and greater economies of scale.
- Improved consumer education, awareness and participation.
- Better recycling, cleaner materials, and much less contamination, resulting in an improved quality of feedstock.
- The establishment of consistent, reliable and local end markets.
- Improved data quality and reporting from stewardship organizations, so that we have more transparency into how much is collected and what is actually recycled, by material type, across all provincial programs in a consistent and reliable way.
In many ways, EPR for residential paper and packaging is still in its infancy in Canada. Currently, only B.C. has an EPR approach, while other provinces who have had programs in place for years are now transitioning to new producer-responsibility models.
It will take time to see if these shifts result in higher recycling rates and more efficient and effective systems.
The Ontario Blue Box program will be the first to begin its transition to a new producer responsibility framework starting this fall, which will see producers take over 100 per cent of the operational and financial management of the program by Dec. 31, 2025.
There is no doubt that paper-based packaging will continue to be an important component of the Ontario Blue Box program, and all provincial recycling programs, but we will be watching that transition closely with the hope that Ontario and other provinces get it right.
Getting it right means that consumers understand their important role in properly recycling.
Getting it right means focusing beyond just collection, and recycling more of what is being collected.
And, finally, getting it right means having end markets consistently available to ensure the materials are being recycled.
Rachel Kagan is the executive director of the Paper and Paperboard Packaging Environmental Council (PPEC) in Brampton, Ont.