Blue Box Transition to EPR

Blue Box Transition Update and AMO Recommendations, Maria Rodriguez, AMO

Objective: To discuss the transition to Extended Producer Responsibility (EPR) for waste management. Help municipalities understand the shift in responsibilities, share on-the-ground experiences, and identify local challenges. Share AMO's current advocacy focus and concerns. Outline implications for municipalities and next steps.

Background & Timeline

  • Blue Box Regulation introduced June 2021 creating a province-wide residential recycling system based on Extended Producer Responsibility (EPR).\
  • Under EPR, producers assume operational and financial responsibility for Ontario's residential Blue Box program.
  • Transition being led by Circular Materials (Producer Responsibility Organization)
  • Full EPR start: January 1, 2026 - municipalities no longer responsible for residential recycling collection/processing.
  • Recent amendment (last month): defers expansion of required Blue Box service for certain locations to 2031.

What EPR Changes (High Level)

  • Previous model: Municipal programs with cost-sharing by producers.
  • New model: Producer-run residential system (collection + processing), intended to: Shift costs from municipal taxpayers to producers.
  • Recent Deferral to 2031: Producers not required to service multi-residential, K-12 schools, publicly run retirement homes/LTC until 2031. IC&I (industrial, commercial, institutional) locations (e.g., small businesses on residential routes, BIAs, local food banks, arenas, campgrounds, municipal office buildings).
  • Pre-EPR: Many municipalities voluntarily serviced small IC&I (esp. along residential routes) for efficiency. This was possible because, municipalities were already undertaking collection and as such it wasn't much additional costs to service additional locations because they were already collecting from locations in that area. This will be a gap in the areas that the EPR collections will not be servicing, and it will be costly for municipalities to still service those locations since the aren't undertaking recycling collection anymore.
  • Municipalities are still responsible for garbage and organics pick up.
  • Minister directed producers to prepare an offer of service for small IC&I collection at municipal cost by Jan 1, 2026. September: PROs informed the Ministry & municipal sector they cannot fulfill the requested offer due to operational/infrastructure/financial constraints. PROs said municipalities may use producer depots for small IC&I, but municipalities must contract hauling and processing themselves.

Implications for Municipalities (from Jan 1, 2026)

  • Municipalities that had supported small IC&I collection must decide now whether to:
  • Continue collection via own program or private contract, or cease collection (leaving businesses/non-profits to arrange private pickup).
  • Many small businesses & non-profits (e.g., food banks/shelters) report inability to absorb new private collection costs.
  • Procurement challenges: In some areas there may be only one viable provider for a small number of sites, driving prices up.
  • Transparency and reporting on waste diversion rates and material diverted is critical for municipalities to be able to track that data. This data collection was possible when municipalities were managing the collection process, but it remains to be seen how much transparency there will be in this data as EPR collection occurs. Municipalities should keep data needs in mind as the transition occurs.

AMO's Advocacy Position

  • AMO supports EPR and its potential for innovation and a circular economy.
  • Problem identified: A fragmented system-split responsibilities between producers, municipalities, and generators-undermines true producer responsibility and shifts costs back to municipal taxpayers.
  • Call to action: Province should amend the Blue Box regulation to create a clear pathway to full EPR, where producers are responsible for collection of Blue Box materials at all sites, including small and large IC&I.
  • Rationale: Reduce inefficiency, complexity, and financial burden on municipalities/taxpayers, especially in small and northern communities.