OFA provided comments to the Ministry of Environment, Conservation and Parks regarding amendments to the Resource Recovery and Circular Economy Act (RRCEA).

There is a high level of interest in the Blue Box program transition to the producer responsibility model. OFA’s concerns relate to farms as blue box customers and blue box material producers.

Several of OFA’s farm business members have been removed from collection routes by municipalities and waste collection companies including residential properties on their farmland. Small businesses, multi-unit residential buildings, institutions, and public spaces should be eligible collection sources. OFA supports enabling legislation to require Producer Responsibility Organizations (PROs) to offer to service small businesses and institutions yet to be included in the expanded Blue Box Regulation. PROs must also exert the effort to service residential homes on farms.

As material producers, farmers do not have and cannot gain control of the packaging materials that are dictated by the retail buyer. OFA continues to recommend that the retailer should be the party responsible for reporting and end of life management of non-processed or minimally processed agri-food packaging regardless of any branding on the packaging material.