December 11, 2025 The Honourable Todd McCarthy Minister of Environment, Conservation and Parks 777 Bay Street, 5th Floor Toronto, ON M7A 2J3 Re: Joint Letter From Chambers Concerning Recycling EPR Transition Dear Minister McCarthy, On behalf of the businesses represented by the Ontario Chamber of Commerce network, we are writing to share concerns about the impacts of Ontario's Blue Box Regulation (Reg. 391/21) on recycling services for businesses and institutions across several regions. We recognize that the transition to a full Extended Producer Responsibility (EPR) model for Blue Box materials has been years in the making, with producers assuming operational and financial responsibility for recycling collection between July 1, 2023, and December 31, 2025. We also appreciate the measures taken to mitigate unsustainable fee increases for businesses. However, as the full EPR program begins January 1, 2026, several municipalities have delivered notice that they will cease collecting recyclable materials from non-residential sources- including local businesses, places of worship, BIAs, non-profits, and municipal buildings- because these sources are not deemed “eligible” under the regulation. This change is already creating challenges in regions that have transitioned. With limited or no private collection services available in some areas, Chambers report significant impacts on local businesses and non-profit organizations, including increased costs, logistical hurdles, and recyclables being discarded as garbage- undermining Ontario’s sustainability and circular economy objectives. These impacts disproportionately affect small businesses and community organizations that lack the resources to manage recycling independently. This unintended consequence risks eroding consistent recycling services across Ontario and exacerbates the province’s severe landfill capacity issues. Addressing this requires collaboration and clarity between the Province, municipalities, and producers to ensure a seamless transition for all non-residential generators who previously relied on municipal service. We urge the Ministry to: •
Review eligibility criteria under the Blue Box Regulation to maintain continuity of service for non-residential sources.
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Explore transitional supports for affected organizations, including funding for municipalities to sustain recycling services for businesses and institutions where private solutions are unavailable or impractical. 1
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Engage with regional chambers and stakeholders to ensure a smooth, equitable transition and share data on implementation progress.
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Provide clear interim guidance to municipalities, businesses, and institutions on expected service levels and available options after December 31, 2025.
Our Chambers remain committed to working collaboratively with the Province and municipal partners to ensure the success of Ontario’s recycling programs and the well-being of local economies. We would welcome the opportunity to meet with you to discuss these concerns and explore solutions with our members. Thank you for your attention to this important matter. We look forward to your response and to continuing our partnership towards a more sustainable Ontario. Sincerely,
Daniel Tisch President and CEO Ontario Chamber of Commerce Cc:
Hon. Andrea Khanjin, Minister of Red Tape Reduction Hon. Nina Tangri, Associate Minister of Small Business
Endorsed by: Angus & Area Chamber of Commerce Aylmer & Area Chamber of Commerce Centre Wellington chamber of commerce Chamber of Commerce Brantford-Brant Fenelon Falls & District Chamber of Commerce Flamborough Chamber of Commerce Geraldton District Chamber of Commerce Greater Barrie Chamber of Commerce Greater Stouffville Chamber Grimsby & District Chamber of Commerce Hamilton Chamber of Commerce Hanover Chamber of Commerce Huron Chamber of Commerce Lennox and Addington Chamber of Commerce Mapleton Chamber of Commerce Muskoka Lakes Chamber of Commerce Niagara Board of Trade & Commerce Niagara-on-the-Lake Chamber of Commerce 2
Oakville Chamber of Commerce Ottawa Board of Trade Paris and District Chamber of Commerce Peterborough Kawarthas Chamber of Commerce Prince Edward County Chamber of Commerce Sarnia Lambton Chamber of Commerce Saugeen Shores Chamber of Commerce Simcoe & District Chamber of Commerce South Grey Chamber of Commerce St. Thomas & District Chamber of Commerce Stoney Creek Chamber of Commerce Tillsonburg District Chamber of Commerce Wallaceburg & District Chamber of Commerce Whitby Chamber of Commerce Wiarton & District Chamber of Commerce
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