OFA acknowledges the challenges of the transition to an individual producer responsibility framework and supports the proposed actions to ensure residential collection costs remain manageable and to stabilize residential recycling services. From an agricultural perspective, OFA’s concerns relate to farms as blue box customers and as blue box material producers.

OFA raises concerns about the potential exclusion of farm residences from municipal recycling services, as small businesses and farms may lose access as the transition is completed in 2026. This could compromise waste management and sustainability in rural areas.

Current producer responsibility regulations may unfairly burden farm businesses whose total revenue exceeds regulatory thresholds, even when their packaging related revenue is minimal.

OFA remains concerned about farm businesses being responsible for food packaging waste. Farmers do not have and cannot gain any control over packaging materials that are dictated by the retail buyer. In theses situations, either the manufacturer of the packaging and/or the retailer should be deemed as the “producer” and therefore accountable for its waste and recovery management.