Skip to content
Specialized Packaging Market Intelligence and Strategic AdvisoryPackaging Intelligence. Clearer Decisions. Stronger Growth.

SPI NewsCanada · Ontario Blue Box

Ontario weighs dropping flexible plastic from the Blue Box and would make PROs publish fees; comments close 26 November

Ontario’s ERO notice 026-1058 would give producers itemised PRO invoices and 90 days’ notice of mid-year fee rises, and weighs exempting flexible plastic, which Environmental Defence puts at 80,000 tonnes; comments close 26 November 2026.

By the SPI teamPublished 15 min read

Ontario producers have 16 days to the RPRA audit consultation close and 26 days to the ERO 026-1058 close Unit: days from 31 October 2026
Ontario producers have 16 days to the RPRA audit consultation close and 26 days to the ERO 026-1058 close4 bars. Largest: Flexible plastic requirement rises to 15%, 1 Jan 2028, 427.RPRA audit and supply reportingconsultation closes, 16 Nov 2026RPRA audit and supply reporting consultation closes, 16 Nov 2026: 16 days from 31 October 202616ERO 026-1058 comments close, 26 Nov2026ERO 026-1058 comments close, 26 Nov 2026: 26 days from 31 October 2026262026 supply and performance reportsdue, 31 May 20272026 supply and performance reports due, 31 May 2027: 212 days from 31 October 2026212Flexible plastic requirement rises to15%, 1 Jan 2028Flexible plastic requirement rises to 15%, 1 Jan 2028: 427 days from 31 October 2026427Ontario producers have 16 days to the RPRA audit consultation close and 26 days to the ERO 026-1058 close4 bars. Largest: Flexible plastic requirement rises to 15%, 1 Jan 2028, 427.RPRA audit and supply reporting consultation closes,16 Nov 2026RPRA audit and supply reporting consultation closes, 16 Nov 2026: 16 days from 31 October 202616ERO 026-1058 comments close, 26 Nov 2026ERO 026-1058 comments close, 26 Nov 2026: 26 days from 31 October 2026262026 supply and performance reports due, 31 May 20272026 supply and performance reports due, 31 May 2027: 212 days from 31 October 2026212Flexible plastic requirement rises to 15%, 1 Jan2028Flexible plastic requirement rises to 15%, 1 Jan 2028: 427 days from 31 October 2026427

Source: ERO 026-1058, 27 Oct 2026; RPRA consultation of 2 Oct 2026 as reported by SPI on 28 Oct; RPRA, flexible plastics targets, 18 Nov 2025; days by SPI's calculation, checked 31 Oct 2026.

Days counted from 31 October 2026 by SPI's calculation. The 2028 performance year is when the flexible plastic management requirement rises from 10% to 15% under the current regulation; the new proposal could change that.

Show the data
Ontario producers have 16 days to the RPRA audit consultation close and 26 days to the ERO 026-1058 close (days from 31 October 2026)
DateDays (days from 31 October 2026)
RPRA audit and supply reporting consultation closes, 16 Nov 202616
ERO 026-1058 comments close, 26 Nov 202626
2026 supply and performance reports due, 31 May 2027212
Flexible plastic requirement rises to 15%, 1 Jan 2028427

Key takeaways

  • ERO notice 026-1058, posted by Ontario’s environment ministry on 27 October 2026, proposes changes to the Resource Recovery and Circular Economy Act, 2016 and the Blue Box Regulation, with comments due by 11:59 p.m. on 26 November.
  • The ministry’s consultation paper would require PROs to post proposed and final fee schedules publicly and itemise system costs on quotes, invoices and receipts, and to report each year on shared costs and cost drivers.
  • Producer contracts, existing and future, would follow regulated fee principles, with in-year increases limited to once a year and 90 days’ notice before any mid-year rise, the paper says.
  • The paper asks whether flexible plastic should stay in the province-wide system, with options from exemption and an end to collection to regional or depot collection; Environmental Defence says 80,000 tonnes of packaging would be affected.
  • SPI analysis: the fee rules and the flexible plastic question pull in opposite directions for film users. Visible fees would show what flexible packaging costs to collect; an exemption could remove that cost and the recycling route with it.
Ontario gives 30 days to comment on 90-day fee notice rules for the four PROs that share one collection system

30

Comment period

days, 27 October to 26 November 2026, closing 11:59 p.m.

ERO 026-1058

90

Notice before a mid-year fee increase

days, with increases limited to once a year

Plain Language Description

4

PROs under the System Access Agreement

Circular Materials is System Administrator

Plain Language Description; RPRA

Source: ERO 026-1058, 27 Oct 2026; Plain Language Description, Oct 2026, checked 31 Oct 2026.

Ontario’s environment ministry posted ERO notice 026-1058 on 27 October 2026, proposing to amend the Resource Recovery and Circular Economy Act, 2016 and the Blue Box Regulation, O. Reg. 391/21, with comments open for 30 days to 11:59 p.m. on 26 November.

The proposal turns the outline the ministry gave on 23 October, which SPI covered in its report on the PRO fee plan, into named measures. Producer responsibility organisations (PROs), the companies that run recycling on producers’ behalf, would have to post fee schedules publicly, itemise costs on every quote and invoice, and give 90 days’ notice before a mid-year increase. The ministry also asks whether flexible plastic, the film, bags and pouches that are hardest to sort, should stay in the provincial system at all.

For a board or a buyer, two things are now on the table at once: the right to see what the Blue Box costs, and the possibility that a whole packaging format leaves it. The statute changes sit in Bill 140, the Building Ontario Faster Act, 2026, which the Legislative Assembly’s bill page lists at second reading with a closure motion moved. The ministry intends the new requirements to be in place in 2027 if the bill passes as drafted.

How Ontario's Blue Box is run and paid for

Ontario completed its move to a fully producer-run Blue Box on 1 January 2026, the ERO notice says. Under the legacy system, the ministry’s consultation paper notes, producers funded 50% of residential collection costs; they now carry all of them2.

Each producer has its own recovery duty. Producers must meet resource recovery targets for six categories of materials, the paper says, and the SPI Regulation Tracker sets out those targets under record PR-CA-003. Most producers meet the duty by contracting with a PRO.

Four PROs share one collection system. RPRA’s PRO page, updated on 26 October 2026, lists Circular Materials, EnvironFocus Inc., Landbell Canada and Ryse Solutions Ontario Inc., and says they share a System Access Agreement that sets administrative, operational and procurement practice6. Circular Materials is the System Administrator.

The structure dates from the Blue Box Regulation of 2021 and the 2025 amendments, which the notice says extended recovery target timelines, refocused the program on residential material, removed some planned expansions and added flexibility for hard-to-recycle materials.

Day-to-day running sits one layer down. The consultation paper says Circular Materials hired RLG as a third-party System Operator, which oversees collection, allocates collected material to each PRO and invoices the PROs. Producers see none of that chain directly: they see the fee their own PRO charges.

The ministry says that fee has become the problem. The notice reports that producers and PROs told it the Blue Box is costing more than anticipated, citing inflation, labour shortages and supply chain issues for infrastructure, and that producers describe rising fees and a lack of transparency.

The ministry says in its consultation paper that more needs to be done to create the conditions for cost stability.

ERO 026-1058 sets out seven proposals in three groups, from public fee schedules to small business collection
RefProposalWhat it would doInstrument
1AFee transparency and cost disclosurePublic fee schedules, itemised quotes and invoices, annual cost reportsRegulation
1BNew authorities over contracts, fees and costsLet regulations govern Part IV contracts by any person, existing and futureAct, Schedule 22 of Bill 140
1CFair and predictable contract termsRegulated fee principles; once-a-year increases; 90 days' noticeRegulation
1DPRO collaboration on cost savingsOperating Committee, independent audit and dispute processes, System Operator reporting to RPRARegulation
2AFlexible plastic in the province-wide systemExempt, end collection, or allow regional or depot collectionRegulation
2BService requirementsPhase out overflow collection where alternatives exist; criteria for extra boxesRegulation
3ASmall IC&I collectionMaterial from small businesses can count toward producer targetsRegulation

Source: Ministry of the Environment, Conservation and Parks, Plain Language Description, Oct 2026; ERO 026-1058, checked 31 Oct 2026.

Summary of the consultation paper. Proposals only; statute changes apply only if Bill 140 passes and regulations follow. Not legal advice.

What changed between 23 and 31 October

23 October: the outline. The ministry announced it would seek power to regulate contract terms and fees between PROs and producers, and would consult on fee reporting, service levels and flexible plastic. It gave no bill number or ERO notice at the time, as SPI reported on 26 October10.

27 October: the notice and the bill. The ministry posted ERO 026-1058 with a 30-day comment period to 26 November 20261. The consultation paper says the statute amendments were introduced in the Legislature the same day in the Building Ontario Faster Act, 2026.

Schedule 22 of Bill 140. The Legislative Assembly’s page for Bill 140 shows the bill sponsored by the Minister of Red Tape Reduction, with Schedule 22 amending the Resource Recovery and Circular Economy Act3. Its explanatory note says the schedule amends Part IV, adds regulation-making powers on providing information and entering into agreements, and allows a regulation to apply to agreements made before it is filed, if it says so.

Commencement on several dates. The same note says some provisions take effect on Royal Assent, some on a day named by order, and some are deemed to have taken effect on the bill’s first reading. On 31 October the bill page listed Bill 140 at second reading, with closure moved.

28 October: the government bulletin. The Ministry of Red Tape Reduction posted ERO bulletin 026-1114, which says Bill 140 amends 26 Acts and proposes two new ones, and lists the Resource Recovery and Circular Economy Act among them4. The bulletin carries no comment period of its own and points to 026-1058 for the Blue Box changes.

27 October: a parallel waste notice. On the same day the ministry posted ERO 026-1056 on landfill capacity, also closing on 26 November5. It says Ontario relies on U.S. facilities for about 25% of its waste and proposes to modernise IC&I recycling rules under O. Reg. 102/94 and 103/94.

The flexible plastic question. The consultation paper’s section 2A asks whether flexible plastic belongs in the province-wide system at all. It lists exemption and an end to collection as one route, and collection matched to regional sorting capacity, or at local depots, as another. The ministry says it would decide as soon as possible if it pursues the change.

“This could include exempting these materials from the Blue Box Regulation, ending their collection outright.”

Ministry of the Environment, Conservation and Parks, Government of Ontario, ERO notice 026-1058, 27 October 2026

28 October: first outside reaction. Environmental Defence, a Canadian environmental group, said the proposal would remove obligations for companies to manage 80,000 tonnes of flexible plastic packaging they put on the market8. The figure is Environmental Defence’s own; neither the notice nor the paper gives a tonnage, and the statement does not say whether it is an annual figure.

ERO 026-1058 was posted on 27 October and closes on 26 November, ten days after RPRA's audit consultation
  • past
  • next
ERO 026-1058 was posted on 27 October and closes on 26 November, ten days after RPRA's audit consultation10 dated items from 18 Nov 2025 to 2028.20252026202720282029Today18 Nov 2025: RPRA publishes phased flexible plastic requirements of 10%, 15% and 25%1 Jan 2026: Ontario Blue Box fully producer-run23 Oct 2026: Ministry outlines PRO fee, reporting and flexible plastic plans27 Oct 2026: ERO 026-1058 posted; Bill 140 introduced with Schedule 2228 Oct 2026: ERO bulletin 026-1114 on Bill 140; Environmental Defence statement16 Nov 2026: RPRA audit and supply reporting consultation closes26 Nov 2026: ERO 026-1058 and ERO 026-1056 comments close, 11:59 p.m.2027: Fee, contract, committee and reporting rules intended to apply31 May 2027: Supply and performance reports on 2026 data due2028: Flexible plastic requirement due to rise from 10% to 15%ERO 026-1058 was posted on 27 October and closes on 26 November, ten days after RPRA's audit consultation10 dated items from 18 Nov 2025 to 2028.20252026202720282029Today18 Nov 2025: RPRA publishes phased flexible plastic requirements of 10%, 15% and 25%1 Jan 2026: Ontario Blue Box fully producer-run23 Oct 2026: Ministry outlines PRO fee, reporting and flexible plastic plans27 Oct 2026: ERO 026-1058 posted; Bill 140 introduced with Schedule 2228 Oct 2026: ERO bulletin 026-1114 on Bill 140; Environmental Defence statement16 Nov 2026: RPRA audit and supply reporting consultation closes26 Nov 2026: ERO 026-1058 and ERO 026-1056 comments close, 11:59 p.m.2027: Fee, contract, committee and reporting rules intended to apply31 May 2027: Supply and performance reports on 2026 data due2028: Flexible plastic requirement due to rise from 10% to 15%
  1. RPRA publishes phased flexible plastic requirements of 10%, 15% and 25%past
  2. Ontario Blue Box fully producer-runpast
  3. Ministry outlines PRO fee, reporting and flexible plastic planspast
  4. ERO 026-1058 posted; Bill 140 introduced with Schedule 22past
  5. ERO bulletin 026-1114 on Bill 140; Environmental Defence statementpast
  6. RPRA audit and supply reporting consultation closesnext
  7. ERO 026-1058 and ERO 026-1056 comments close, 11:59 p.m.next
  8. 2027Fee, contract, committee and reporting rules intended to applynext
  9. Supply and performance reports on 2026 data duenext
  10. 2028Flexible plastic requirement due to rise from 10% to 15%next

Source: ERO 026-1058; ERO 026-1056; ERO 026-1114; Bill 140; RPRA; Environmental Defence; SPI News, checked 14 Oct 2026.

Show the data
ERO 026-1058 was posted on 27 October and closes on 26 November, ten days after RPRA's audit consultation
DateLabelCategoryLink
2025-11-18RPRA publishes phased flexible plastic requirements of 10%, 15% and 25%pasthttps://rpra.ca/?p=94108
2026-01-01Ontario Blue Box fully producer-runpasthttps://ero.ontario.ca/notice/026-1058
2026-10-23Ministry outlines PRO fee, reporting and flexible plastic planspast/news/ontario-blue-box-pro-fees-rpra-penalties/
2026-10-27ERO 026-1058 posted; Bill 140 introduced with Schedule 22pasthttps://ero.ontario.ca/notice/026-1058
2026-10-28ERO bulletin 026-1114 on Bill 140; Environmental Defence statementpasthttps://ero.ontario.ca/notice/026-1114
2026-11-16RPRA audit and supply reporting consultation closesnext/news/rpra-blue-box-audit-supply-reporting-consultation-november-16/
2026-11-26ERO 026-1058 and ERO 026-1056 comments close, 11:59 p.m.nexthttps://ero.ontario.ca/notice/026-1058
2027Fee, contract, committee and reporting rules intended to applynexthttps://ero.ontario.ca/notice/026-1058
2027-05-31Supply and performance reports on 2026 data duenext/news/rpra-blue-box-audit-supply-reporting-consultation-november-16/
2028Flexible plastic requirement due to rise from 10% to 15%nexthttps://rpra.ca/?p=94108

What the proposed rules would require

The paper’s fee section has five parts. PROs would post proposed and final fee schedules on a public website, on timelines the government sets, and any information that lets a producer compare costs across PROs would count as a fee schedule. The ministry says this would align with or build on RPRA’s existing fee methodology reporting, and PROs would keep discretion over the fees themselves2.

Invoices would carry the cost build-up. Quotes, invoices and receipts would itemise each producer’s share of common collection costs, broken into collection, consolidation and transfer, promotion and education, administration and reserve funds. Each PRO would also report yearly on its own processing and administration costs, aligned with cost-per-tonne reporting it already makes.

Contracts would follow set principles. The paper lists five: fees reflect full compliance costs net of revenues, differ by material, reflect recyclability, avoid cross-subsidy between materials and recognise the different capacities of large, medium and small producers. The ministry says it does not intend to prescribe how PROs set costs or fees.

The new statute powers reach further than fees. Under proposal 1B, regulations could govern Part IV contracts entered into by any person, including PRO and producer, PRO and service provider, and inter-PRO contracts such as those for the System Administrator and System Operator. They could set payment limits, contract terms on services, notice, termination, dispute resolution, exclusivity and renewal, eligibility to contract and when parties must contract, for existing and future agreements2.

The governance rules target the System Access Agreement. Any inter-PRO agreement for the common collection system would need an Operating Committee open to all PROs regardless of market share, at least 90 days’ notice and consultation before material cost changes, and independent audit, review and dispute processes with prescribed timelines.

Producers would get public fee schedules, itemised invoices, once-a-year increases and 90 days' notice under the proposed rules
RequirementApplies toWhat it means for producers
Post proposed and final fee schedules publiclyEvery PROFees can be compared across the four PROs before signing
Itemise costs on quotes, invoices and receiptsEvery PROA producer sees its share of collection, transfer, promotion, administration and reserves
Annual public report on shared costs, cost drivers and savingsPROs, filed with RPRAReasons for increases are on the record each year
Fees net of revenues, by material and recyclabilityExisting and future producer contractsFilm and other hard-to-recycle formats could be priced higher
No cross-subsidy between materialsExisting and future producer contractsEach material carries its own cost
In-year increases once a year, itemised, with 90 days' noticeExisting and future producer contractsBudget surprises are capped to one notified change
Operating Committee open to all PROsSystem Access AgreementSmaller PROs gain a formal say on design and procurement
Annual reporting to RPRA on prescribed costs and performanceSystem Operator agreementThe regulator and ministry see operating costs directly

Source: Ministry of the Environment, Conservation and Parks, Plain Language Description, Oct 2026, checked 31 Oct 2026.

Proposed requirements as described in the consultation paper. Rules for contracts apply to existing and future contracts if Bill 140 receives Royal Assent and regulations follow. Not legal advice.

The service rules change what households can leave out. The paper proposes to phase out the duty to collect bagged or baled overflow set beside a receptacle where alternatives exist, such as extra or larger free receptacles or depot access. PROs would always deliver carts, and could be required to deliver extra boxes to residents with accessibility needs, without depot access, or who have not already received more than two.

Small business material could count. Under proposal 3A, Blue Box material collected from small industrial, commercial and institutional (IC&I) sites would count toward producer targets without separate reporting or audit, where collection runs under an agreement with a municipality or First Nation community.

The paper poses 17 consultation questions across the seven proposals, by SPI’s count. The PRO collaboration section carries the most, four, including whether safeguards are needed where PROs are owned by or linked to waste service providers.

The ministry asks 17 questions, four of them on how the four PROs govern the shared collection system Unit: consultation questions, by SPI's count
The ministry asks 17 questions, four of them on how the four PROs govern the shared collection system7 bars. Largest: 1D PRO collaboration, 4.1A Fee transparency1A Fee transparency: 3 consultation questions, by SPI's count31B New contract authorities1B New contract authorities: 2 consultation questions, by SPI's count21C Contract terms1C Contract terms: 2 consultation questions, by SPI's count21D PRO collaboration1D PRO collaboration: 4 consultation questions, by SPI's count42A Flexible plastic2A Flexible plastic: 2 consultation questions, by SPI's count22B Service requirements2B Service requirements: 2 consultation questions, by SPI's count23A Small IC&I collection3A Small IC&I collection: 2 consultation questions, by SPI's count2The ministry asks 17 questions, four of them on how the four PROs govern the shared collection system7 bars. Largest: 1D PRO collaboration, 4.1A Fee transparency1A Fee transparency: 3 consultation questions, by SPI's count31B New contract authorities1B New contract authorities: 2 consultation questions, by SPI's count21C Contract terms1C Contract terms: 2 consultation questions, by SPI's count21D PRO collaboration1D PRO collaboration: 4 consultation questions, by SPI's count42A Flexible plastic2A Flexible plastic: 2 consultation questions, by SPI's count22B Service requirements2B Service requirements: 2 consultation questions, by SPI's count23A Small IC&I collection3A Small IC&I collection: 2 consultation questions, by SPI's count2

Source: Ministry of the Environment, Conservation and Parks, Plain Language Description, Oct 2026; count by SPI, checked 31 Oct 2026.

SPI's count of the numbered feedback questions under each proposal in the paper. Order follows the paper.

Show the data
The ministry asks 17 questions, four of them on how the four PROs govern the shared collection system (consultation questions, by SPI's count)
ProposalQuestions (consultation questions, by SPI's count)
1A Fee transparency3
1B New contract authorities2
1C Contract terms2
1D PRO collaboration4
2A Flexible plastic2
2B Service requirements2
3A Small IC&I collection2

Industry reaction

“Ontario is proposing to amend the Resource Recovery and Circular Economy Act, 2016 and the Blue Box Regulation.”

Ministry of the Environment, Conservation and Parks, Government of Ontario, proposal summary in ERO notice 026-1058, 27 October 2026

The notice frames the package around transparency, cost growth and keeping the Blue Box working for resource recovery, and says the impacts on business, including cost and burden, will be assessed as regulations are drafted.

“The government understands that more needs to be done to create the conditions for cost stability.”

Ministry of the Environment, Conservation and Parks, Government of Ontario, Plain Language Description for ERO 026-1058, October 2026

The notice ties that aim to the 2025 amendments, which phased in flexible plastic targets and refocused the program on residential material, and presents the new measures as the next step.

“Companies vowed they could manage the packaging recycling program better and cheaper than municipalities.”

Environmental Defence, statement on the proposed Blue Box changes, 28 October 2026

Environmental Defence said companies had lobbied to shift responsibility for their packaging back to residents and municipalities, and urged the province to keep producer obligations and extend deposit return to all beverage containers.

“This will mean more waste, more litter and more plastic pollution in Ontario.”

Environmental Defence, statement on the proposed Blue Box changes, 28 October 2026

The group also objected to ending overflow collection, saying that material would go to landfill and leave municipalities to pay. SPI has not yet confirmed published responses to ERO 026-1058 from the four PROs, municipal associations or producer trade bodies on their own websites by 31 October.

Who gains and who pays under the proposal

Flexible packaging producers. Brand owners using film, pouches and wraps carry a flexible plastic management requirement of 10% for 2026 and 2027, rising to 15% for 2028 to 2031 and 25% from 2032, RPRA said in November 20257. An exemption could remove that duty and its fee line. The paper asks whether exempted producers should still pay toward collection costs, so as not to reward greater use of flexible plastic.

Producers of other materials. The paper says any flexible plastic change should avoid raising costs for producers of other materials or creating free riders. Its fee principles, including no cross-subsidy between materials, point the same way. Paper, rigid plastic, glass and metal producers would see their own costs itemised rather than blended.

Circular Materials. As System Administrator of the shared system, Circular Materials would operate under an agreement that must include an Operating Committee open to all PROs and independent audit and dispute processes. The paper also proposes independent adjudication of disputes between the System Administrator and PROs.

EnvironFocus, Landbell Canada and Ryse Solutions. The three other registered PROs would gain committee seats regardless of market share, at least 90 days’ notice and consultation before material cost changes, and information on performance, cost drivers and procurement6.

RLG. The System Operator would report to RPRA each year on prescribed costs and performance under its agreement, which the paper calls an independent reporting relationship. It would give the ministry direct sight of operating costs.

Waste and recycling service providers. Contracts between PROs and service providers fall within the new statute powers, the paper says, covering fees, terms such as notice, termination, exclusivity and renewal, and eligibility to contract. It also says any flexible plastic change should minimise impacts on existing PRO and service provider contracts and on planned sorting and processing investment.

Municipalities and First Nation communities. Overflow collection would phase out where alternatives exist, a change Environmental Defence says shifts cost to municipalities. Their agreements would also become the route by which small IC&I material counts toward producer targets.

Flexible plastic producers face the biggest change, while four PROs and their system operator face new reporting and governance duties
PartyExposure under the proposalFigureSource
Flexible plastic packaging producersPossible exemption, end of collection, or regional or depot collectionRequirement 10% in 2026 to 2027, 15% in 2028 to 2031RPRA, 18 Nov 2025
Flexible plastic packaging (all producers)Obligations Environmental Defence says would be removed80,000 tonnes, Environmental Defence's figureEnvironmental Defence, 28 Oct 2026
Circular MaterialsSystem Administrator under new committee, audit and dispute rules1 of 4 PROsPlain Language Description; RPRA
EnvironFocus, Landbell Canada, Ryse SolutionsCommittee seats regardless of market share; cost change notice3 PROs; 90 days' noticePlain Language Description; RPRA
RLGAnnual reporting to RPRA on prescribed costs and performance1 System OperatorPlain Language Description
Residents and municipalitiesOverflow collection phased out where alternatives existExtra boxes for those with no more than 2 alreadyPlain Language Description
Small IC&I sitesMaterial can count toward producer targets6 target categoriesPlain Language Description

Source: Plain Language Description, Oct 2026; ERO 026-1058, 27 Oct 2026; RPRA Blue Box PROs page, 26 Oct 2026; RPRA, 18 Nov 2025; Environmental Defence, checked 31 Oct 2026.

Figures are on different bases: percentages are management requirements, counts are of parties or receptacles, and the tonnage is Environmental Defence's own claim with no stated period. Do not add or compare rows.

Producer profiles by market and packaging format are in the SPI Buyers Database. SPI has not yet confirmed how many Ontario producers report flexible plastic supply, or the share of PRO fees it represents.

SPI analysis

The tonnage claim and the fee rules meet at one point. If flexible plastic stays in, itemised invoices would show its share of collection cost for the first time; if it leaves, the paper’s own question about a continued contribution decides whether film users save money or merely change the bill.

The fee data producers cannot yet see

Ontario is the largest Canadian market and the least transparent on price, SPI’s Canada Ledger on provincial EPR found: Circular Materials shares Ontario fees with registered producers through its WeRecycle Portal and a producer advisory group, not a public schedule12. Producers can see their own bill but cannot compare it with what another PRO would charge.

That is the gap proposal 1A aims to close, and the paper’s first question shows the tension. It asks how to balance transparency with protecting commercially sensitive information among competing PROs. Four PROs share one collection system, so posting the shared cost lines publicly also reveals much of each competitor’s base cost.

Timing adds pressure. Producers are already answering RPRA’s consultation on supply reporting and audits, which closes on 16 November, as SPI reported on 28 October11. The fee rules would not apply until 2027, after 2027 fees have been set; the Ledger notes Ontario’s 2027 fees have already gone to producers through the advisory group and portal.

The paper also limits how far the ministry will go. It says the government does not intend to prescribe how PROs set costs or fees, and that the new statute powers are enabling, so each requirement needs its own regulation, enforced by RPRA. The notice adds that business impacts, including cost and burden, are still being assessed and gives no figures.

That leaves the conflict of interest question open. The paper asks whether safeguards are needed where a PRO is owned by or associated with a waste service provider. A producer reading an itemised invoice would know what it pays for collection and transfer, but not whether the contracts behind those lines were let at arm’s length.

SPI analysis

A 2027 start means the first year of public schedules would most likely cover 2028 fees. Producers negotiating or renewing PRO contracts now should ask for the itemised breakdown the paper describes, since the rules would apply to existing contracts too.

How Ontario's fee openness compares with other provinces

Other provinces already publish producer fees, on their own bases. Recycle BC publishes cents per kilogram for 23 material lines and SK Recycles for 19, Éco Entreprises Québec publishes dollars per tonne, and Circular Materials posts fee budgets and average rates for Alberta, New Brunswick, Nova Scotia, Manitoba and Yukon, SPI’s Ledger found12. Ontario’s proposal would bring it toward that practice without moving to a single body.

Flexible plastic is a weak point everywhere. The Ledger records Recycle BC’s 2025 recovery for flexible plastic at 23%, against 92% for paper, and Circular Materials New Brunswick’s at 2% against a 4% baseline target. Québec’s ministry page lists a 50% recovery rate for flexible plastics in 2027, though SPI has not yet confirmed whether that rate still applies after Québec announced lower rates.

Ontario’s alternative routes, regional collection matched to sorting capacity or depot drop-off, would leave it with a narrower flexible plastic service than British Columbia’s.

Ontario would move to public PRO fee schedules, while British Columbia, Québec and New Brunswick already publish fees on their own bases
ProvinceHow producer fees are publishedFlexible plastic figureBasis
OntarioShared with registered producers through portal and advisory group; proposal would make schedules public10% management requirement, 2026 to 2027Requirement, % of prior-year supply
British ColumbiaRecycle BC publishes cents per kg for 23 material lines23% recovery in 2025Program recovery rate
QuébecÉEQ publishes dollars per tonne50% listed for 2027; SPI has not yet confirmed it still appliesRegulated recovery rate
New BrunswickCircular Materials publishes fee budget, 88 c/kg average in 20262% in 2025 against a 4% baseline targetProgram result against plan

Source: SPI Ledger, Canada's packaging EPR province by province, 20 Oct 2026, citing Recycle BC, ÉEQ, Circular Materials and RPRA; Plain Language Description, Oct 2026, checked 31 Oct 2026.

CAD where shown. Fee bases, recovery measures and years differ by province; recovery rates and requirements are not comparable and must not be ranked or averaged.

The size of the regulator’s own fee shows how small the visible part of Ontario’s bill is. RPRA proposes a 2027 revenue requirement of CAD 9,549,539 on about 867 million kg of supply, the Ledger records, while PRO fees for collection sit on top and are not public12. The ERO 026-1058 rules would put the larger number, the PRO fee, on the record for the first time.

SPI analysis

Ontario is converging on its neighbours for fees while diverging on flexible plastic. A brand selling film across Canada could face full collection in British Columbia and a reduced or exempt service in Ontario from 2027, which complicates national recyclability claims. Track the provinces in the SPI Regulation Tracker for Canada.

What it means for you

SPI analysis

These points follow from the sources above and are not legal advice.

  • Brand owners: decide by 26 November whether to file on flexible plastic. The paper asks whether exempted producers should still contribute to collection costs, which decides the saving, if any.
  • Flexible packaging converters: expect customers to ask what an exemption means for recyclability claims and pack choices. A regional or depot model could leave film recyclable in some Ontario areas but not others.
  • Retailers and importers: where you are the obligated producer, request itemised breakdowns now. The proposed contract rules would cover existing contracts as well as new ones.
  • Procurement and finance teams: plan 2027 budgets on the fees already notified, and treat 2028 as the first year of public schedules and once-a-year increases with 90 days’ notice.
  • PRO contract owners: watch the Operating Committee rules. A PRO with a small market share would gain a formal voice on system costs, which may change the case for switching PROs.
  • Sustainability teams: review on-pack recycling claims for film and pouches sold in Ontario. A regional or depot model would make a single provincial claim harder to support from 2027.
  • Small business suppliers: if your customers sell through small IC&I sites, their material could count toward producer targets where a municipality or First Nation runs collection.

See Ontario’s record PR-CA-003, the Canada EPR Ledger and obligated buyers in the SPI Buyers Database.

What to watch next

  • 16 Nov 2026: RPRA’s consultation on Blue Box supply reporting guidelines and the audit procedure closes11.
  • 26 Nov 2026: comments on ERO 026-1058 and the landfill notice ERO 026-1056 close at 11:59 p.m.1.
  • 2027: fee, contract, committee and System Operator reporting rules intended to apply, subject to Royal Assent and regulations.
  • 31 May 2027: supply and performance reports on 2026 data due to RPRA.
  • 2028: the flexible plastic requirement is due to rise from 10% to 15% unless the new rules change it7.
  • Date not set: third reading and Royal Assent of Bill 140, now at second reading with closure moved3.
  • Date not set: the ministry’s decision on flexible plastic, which it says it would take as soon as possible if pursued.

FAQ

What does ERO notice 026-1058 propose?

It proposes amendments to the Resource Recovery and Circular Economy Act, 2016 and the Blue Box Regulation, O. Reg. 391/21. The seven proposals cover PRO fee transparency, contract rules, governance of the shared collection system, flexible plastic, service levels and small business collection.

When do comments close?

At 11:59 p.m. on 26 November 2026, after a 30-day period that opened on 27 October. Comments can be made through the Environmental Registry of Ontario notice page.

Would flexible plastic leave the Blue Box?

Not yet decided. The paper lists exemption and an end to collection as one option, and regional or depot collection as another, and asks whether exempted producers should still pay toward collection. Environmental Defence says 80,000 tonnes of flexible plastic packaging would be affected.

What would change on PRO invoices?

Quotes, invoices and receipts would itemise each producer’s share of common collection costs, including collection, transfer, promotion and education, administration and reserves. Mid-year increases would be limited to once a year with 90 days’ notice.

When would the new rules apply?

The government intends them to be in place in 2027, if Bill 140 passes as drafted and receives Royal Assent. Regulations would then set the detail.

Which law carries the statute changes?

Schedule 22 of Bill 140, the Building Ontario Faster Act, 2026, introduced on 27 October 2026. It amends Part IV of the Resource Recovery and Circular Economy Act, 2016.

Sources

  1. Environmental Registry of Ontario (Ministry of the Environment, Conservation and Parks), Proposed Amendments to the Resource Recovery and Circular Economy Act, 2016 and the Blue Box Regulation (ERO 026-1058), 27 October 2026 (consulted 2026-10-31)
  2. Ministry of the Environment, Conservation and Parks, Plain Language Description: Amendments to the RRCEA and Blue Box Regulation (PDF), October 2026 (consulted 2026-10-31)
  3. Legislative Assembly of Ontario, Bill 140, Building Ontario Faster Act, 2026, introduced 27 October 2026 (consulted 2026-10-31)
  4. Environmental Registry of Ontario (Ministry of Red Tape Reduction), Bill 140, the Proposed Building Ontario Faster Act, 2026 (ERO 026-1114), 28 October 2026 (consulted 2026-10-31)
  5. Environmental Registry of Ontario (Ministry of the Environment, Conservation and Parks), Proposed Actions to Address Landfill Capacity (ERO 026-1056), 27 October 2026 (consulted 2026-10-31)
  6. RPRA, Blue Box PROs, updated 26 October 2026 (consulted 2026-10-31)
  7. RPRA, Changes to the Blue Box Regulation: Updated flexible plastics targets, and new timelines for eligible facilities and First Nation communities, 18 November 2025 (consulted 2026-10-31)
  8. Environmental Defence, Ontario’s proposed Blue Box changes leave residents holding the bag, 28 October 2026 (consulted 2026-10-31)
  9. SPI Regulation Tracker, PR-CA-003: Ontario Blue Box Regulation (O. Reg. 391/21), record data as of 26 October 2026 (consulted 2026-10-31)
  10. SPI, Ontario moves to regulate Blue Box PRO fees as RPRA proposes C$1.2 million in reporting penalties, 26 October 2026 (consulted 2026-10-31)
  11. SPI, RPRA’s draft rules would make Blue Box producers back 50% of supply weights with evidence by 2029; comments close 16 November, 28 October 2026 (consulted 2026-10-31)
  12. SPI Ledger, Canada’s packaging EPR, province by province: who pays, how much, and when, 20 October 2026 (consulted 2026-10-31)

Go deeper

More from SPI News

All articles
  1. Europe · Consumer board and corrugated packaging

    Stora Enso lifted Q3 adjusted EBIT 28% to EUR 161 million on higher board deliveries as its forest demerger advanced

    Stora Enso's adjusted EBIT rose to EUR 161 million from EUR 126 million in the third quarter as containerboard deliveries rose 18%; an extraordinary general meeting on the Bergslagets Skogar demerger is…

    15 min read

  2. European Union · Heavy metals in packaging

    EU gives lead crystal bottles and flacons a final PPWR exemption. Manufacture ends in 2028, sales in 2029

    The Commission's delegated decision lets lead crystal packaging exceed the PPWR's 100 mg/kg heavy metal cap only until 31 December 2029, with manufacture ending on 31 December 2028; it applies from the…

    15 min read

  3. United Kingdom · Plastic Packaging Tax

    HMRC will require certified mechanically recycled plastic for Plastic Packaging Tax from April 2030; pre-consumer scrap stops counting in 2027

    HMRC's response to 116 consultation submissions sets mandatory certification for mechanically recycled plastic from 1 April 2030, while chemically recycled plastic needs certification and pre-consumer scrap stops counting from 1 April 2027.

    14 min read

ClosingAsk the SPI team

Ask the SPI team

What changes for your packaging next quarter?

Tell us your markets and materials. The SPI team walks you through the rules and buyer commitments that affect them.

Prefer email? Write to sales@strategicpackaginginsights.com.

Questions people bring
  1. Q1

    Which packaging rules apply to us in each market we sell in?

    We map each market's EPR, tax, ban, recycled-content, labelling and deposit rules against your materials and formats, and show which are in force, adopted or only proposed.

  2. Q2

    What could EPR fees and plastic taxes cost us next year?

    We apply published fee tables and tax rates to your tonnages and recycled content, and show the result as scenarios with every rate sourced.

  3. Q3

    Can you tell us when a rule changes?

    Yes. The free tracker alerts cover rule changes by country; a monitoring retainer adds monthly notes on what the changes mean for your portfolio.