NGOs urge Ontario province in Canada to adopt a regulation that supports non-toxic circular economy

HEJSupport is part of the NGO group calling on the Government of Ontario, Canada to adopt a regulation that supports the province’s transition to a low-carbon non-toxic circular economy where products and services
are fundamentally redesigned to prevent waste, and where companies are financially and operationally responsible for their products at end-of-life through Extended Producer Responsibility (EPR).

The current Resource Recovery and Circular Economy Act (RRCEA), reduce toxic substances in printed paper and packaging (PPP), and ensure
provincial regulations are aligned with federal and international obligations, producers should be required to disclose any use and presence of toxic substances in their PPP as part of reporting requirements to RPRA.

These should include, and not be limited to, substances such as polybrominated diphenyl eithers (PBDEs); cadmium; lead; short-chain chlorinated paraffins (SCCPs) commonly used as softeners
in plastics; bisphenol A (BPA) used in polycarbonate bottles, as well as tin lining; and PFAS used to resist water and grease in food packaging.

These, and other targeted substances, should be kept out of the recycling stream to avoid their transfer into production cycles. The absence of recognizing the impacts of toxic substances and additives found in Blue Box
materials and measures to address them will:
a) perpetuate toxic substances (even those already banned globally) and their impacts to the environment and health through recycling processes; manufacturing of products with recycled contents; and final disposal processes of products;
b) undermine the circular economy framework on the safety of materials to be circulated through the system; and
c) undermine an effective EPR approach if producers do not take responsibility for toxic contents of their materials, and prevention and precaution through product innovations.

Recommendations:
– Add new obligations in the proposed regulation for mandatory requirements for labelling, disclosure, restrictions, and phase-out of toxic substances and additives as noted. Put list in designated materials as part of the registration and procurement requirements.
– Restate an objective of the draft regulations that aims to reduce and prevent toxic substances and additives for designated materials in support of the RRCEA.
– Develop, adopt, and regularly revise a legally binding phase-out list of hazardous chemicals in goods, including packaging, to be used by provincial procurement units and producers as a regulation to be completed within six months.
– Conduct regular monitoring of compliance with the phase-out list and active dialogue with industry representatives prior to procurement so that suppliers agree to requirements to phase-out toxic chemicals from their products and packaging.

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