British Columbia's New EPR Handbook for Consumers

By Bill Sheehan, Executive Director

I just received the new updated British Columbia’s Recycling Handbook.  It provides a fascinating glimpse, for Americans, of how discarded products will be managed when those who design, market and use products and associated packaging – producers and consumers – are responsible for managing them at end of life.  It's called extended producer responsibility, or  EPR for short.

The booklet is for consumers.  As the subtitle states, this is A Simple Guide to What Can Be Recycled Under BC's Stewardship Programs.  Industry stewardship agencies, also known as producer responsibility organizations (PROs), are organizations established by manufacturers, distributers or brand owners to discharge their responsibility for ensuring that their products are recycled when customers are done with them.  In British Columbia, such programs are "100% industry funded," meaning that program costs are internalized in the price of the product, at no cost to taxpayers or local government.

British Columbia has more stewardship agencies covering more product categories than any other jurisdiction in North America.

The first edition of the Recycling Handbook, issued two years ago, was 20 pages and covered the 8 stewardship agencies operating at the time.  The new edition is 28 pages and includes 17 stewardship agencies (see list at end). 

Some of the new product categories that have been added since the last version of the Handbook include toys, small appliances and power tools, a vast array of electronics, outdoor power equipment, lighting products, and alkaline batteries. (A stewardship program for residential packaging and printed paper is under development.)

One thing that is striking about the Handbook is the diversity of return channels available for different products.  A chart lists, for each product type, whether it can be taken to depots, retailers, collection events, regional drop-off sites or put in curbside bins.  Each of these return avenues creates opportunities for entrepreneurs and jobs, since stewards pay to have their products collected and sorted.

A nice touch for a consumer guide is a graphic showing what kinds of new things each of 15 product categories are made into.

The Handbook is published by the Stewardship Agencies of British Columbia.  You can find it, and an informative video, Evolution of Industry led Product Stewardship Model in British Columbia, on their website at http://www.bcstewards.com/

Here’s a list of industry stewardship agencies operating in B.C., from the Recycling Council of British Columbia website (see also this summary table of programs):

AlarmRecycle | BC Used Oil Management Association | Brewers Association of Canada | Call 2 Recycle |Canadian Brandowners Residual Stewardship Corporation | Electrical Equipment Manufacturers Association | Electronic Products Recycling Association | ElectroRecycle Small Appliance Recycling Program | Encorp Pacific (Canada) | Light Recycle | Post-Consumer Pharmaceutical Stewardship Association | Outdoor Power Equipment Institute of Canada | Product Care | Recycle My Cell | Switch the 'Stat | The TELUS Return and Recycle Program |  Tire Stewardship BC | 

The Handbook portrays a commonsense world in which the costs of managing products at end of life are included in product prices and not off-loaded onto government, taxpayers or general garbage ratepayers.  While EPR programs in British Columbia have their warts, they give those of us in other jurisdictions a lot to learn from as we develop more rational materials management systems.

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PPI-PSI Response to the Grocery Manufacturers Association (GMA)

Product Policy Institute (PPI) and Product Stewardship Institute (PSI) today released a white paper responding to a recent GMA report that concluded that Extended Producer Responsibility (EPR) should not be applied to packaging, and that government, not themselves, should be responsible for their packaging when consumers are done with it.

The PPI-PSI white paper, Grocery Manufacturers Seek Government Aid to Recycle Their Packaging, identifies four areas in which the GMA report “gets it wrong:”  (1) Limited data, poorly interpreted; (2) False conclusions about cost-effectiveness; (3) Misleading recycling rates; and (4) Premature conclusion on packaging design. 

The Grocery Manufacturers Association is a trade association representing large consumer packaged goods brands, such as Procter and Gamble, General Mills, Kraft, and Pepsi.  The conclusion of the GMA report is that the recycling collection system status quo, in which local governments and taxpayers pay to collect and sort packaging waste, is viable and only needs some tweaking. America is different, they argue, from the many countries in which EPR for packaging is established policy and has been delivering superior results.  In essence, GMA proposes more government aid and higher taxes to deal with their packaging waste.

What’s wrong with this picture?  The PPI-PSI white paper points out that local governments cannot afford to maintain or expand recycling infrastructure—or do so at the expense of vital services; local governments are not optimal participants in  a global commodity supply system; and internalizing recycling costs in products and packaging is inherently fairer than taxpayer-funded recycling.

The PPI-PSI paper concludes:  

“An underperforming recycling system is a long-term threat to U.S. consumer packaged goods companies. Many companies have made sustainability or sustainable packaging statements; however, what is often missing is the articulation of strategic or tactical plans to achieve the stated goals. Rather than fighting what its members already do in 47 other countries, companies could work to create superior producer-led EPR systems in the U.S., develop predictable supplies of raw materials, and earn positive public recognition from assuming this level of corporate social responsibility.   Those companies within GMA that eventually come to the realization that EPR may deliver benefits toward their sustainability goals might start to question their trade organization’s opposition.”

European Businesses Advocate 10 Golden Rules for EPR

By Bill Sheehan

Eight multi-national corporations operating in the European Union have released a 2-page position paper on Extended Producer Responsibility.  The companies are Procter & Gamble – Unilever – 3M – GE – Microsoft – Philips –Suez /SITA – Umicore.  

Note the language accepting EPR as a “useful business model to promote sustainable production and consumption,” and constructive proposals on  how to make it work better.

Compare the statements in this position paper with those of the U.S. trade associations opposing producer responsibility, including the Product Management Alliance and the recent report dismissing EPR by the Grocery Manufacturers Association (P&G, Unilever, 3M are members of GMA)

Excerpts

• Extended Producer Responsibility (EPR), if well applied in combination with other policy instruments, is a useful business model to promote sustainable production and consumption, enhance waste management performance, and thus move towards a resource-efficient society.

• EPR has delivered positive outcomes, notably through a better understanding of the product and waste management chain, taking into account the whole life-cycle of a product, while introducing investment to develop separate collection and effectively increase recycling and recovery rates of under-performing waste streams. However, EPR has also had adverse impacts - for example the development of low quality recycling, scheme failures due to the involvement of too many and/or mismanaged EPR organizations, and the development of freeriding behaviours due to poor enforcement - which should be designed out through the application of EU golden rules.

On Competition:

•  An optimal number of EPR organizations per material or product should be found to guarantee sound competition: not too many EPR organizations to keep the overall system manageable by the competent authority, but sufficient to avoid a monopoly position developing in the market.

On Enforcement:

• Control and enforcement mechanisms enabling effective and strengthened public oversight, should be set up by EPR.

GMA conclusions disputed by Ramsey County MN

By Bill Sheehan, Executive Director

Extended Producer Responsibility for packaging is getting the attention of consumer packaged goods companies.  Some are using their trade associations to argue  for bigger government and higher taxes to increase packaging recycling.

The Grocery Manufacturers Association (GMA) released a report (written by the consulting  firm SAIC) in September highly critical of EPR for packaging.  On October 26, the new trade association AMERIPEN adopted an internal policy:  “We are committed to increasing recycling and recovery rates in the U.S. through collaboration and teamwork among key stakeholders, by bringing more efficiency into our existing system, and incorporating best practices, all without the financial and administrative burden of an EPR system.”

More on both of these positions in coming weeks.  For now, you should know that the GMA report’s analysis and conclusion that “U.S. communities and states that have instituted non-EPR policies can achieve high recycling rates within a reasonable cost…” is based  on a single data point – from Ramsey County MN – and Ramsey County does not concur with GMA’s conclusions. 

Some highlights from the Ramsey County analysis:

• The report only cites recycling rates for three jurisdictions -- Ramsey County, Minnesota, and California -- and only cites one cost figure, the $156 net cost for residential recycling in communities in Ramsey County.
• Ramsey County does NOT concur with the conclusions, which are not adequately supported in the report.
• Ramsey County Board of Commissioners has made support of product stewardship/EPR its top priority in solid waste policy.

One thing the GMA report does admit:   EPR is about fairness, putting responsibility on those who profit from and use products and associated packaging:  producers and consumers.  And EPR is “inherently fairer” (than making taxpayers pay).

[For a copy of Ramsey County's 8-page response, email info@productpolicy.org ]

Extended Producer Responsibility Job and Economic Impact Studies

Guest Blog By Duncan Bury

Duncan Bury currently provides consulting services in producer responsibility and waste diversion and formerly worked with Environment Canada where he led files in areas including Extended Producer Responsibility (EPR), electronics, product focused policies and international waste policy.  In 2011 he co-founded EPR Canada, a not-for-profit association with a mission to help ensure the continued growth and improvement of EPR policies, programs and practices in Canada.   

The potential job creation impacts of extended producer responsibility and recycling polices were the topic of a recent report I prepared for the Western Product Stewardship Collaborative (WPSC).  The WPSC is an informal collaborative consisting of representatives from the Province of British Columbia Ministry of Environment, the California Department of Resources, Recycling and Recovery (CalRecycle), the Oregon Department of Environmental Quality, and the Washington State Department of Ecology. The statements and conclusions contained in this report are mine and not necessarily those of the WPSC.

With the growth of both product stewardship and Extended Producer Responsibility (EPR) programs there has been growing interest in understanding and assessing the job and economic impacts of such programs. Ten major studies conducted between 2008 and 2012 were reviewed.

While specific metrics vary and are hard to compare, the studies reviewed confirm that increasing the diversion of wastes, materials and products is more employment intensive and has a greater economic impact than simply collecting these materials and products as wastes and disposing of them. The adoption of EPR or any other kind of product stewardship program increased recycling and increased material throughput. 

This may have some minor negative impacts on jobs in the waste collection and disposal sector but these job loses will almost assuredly be more than offset by a growth in jobs in the collection of a greater number of waste streams, more processing for recycling and more jobs in the use of the secondary materials recovered.

Here’s what was found:

·       Landfill disposal is not job intensive and generates a small number of jobs compared to waste recycling and waste diversion.

·       Recycling and the use of secondary materials create significantly higher net value added and jobs at higher income levels than waste disposal.

·       Recycling businesses create jobs closer to home and have a smaller environmental footprint than businesses that rely on raw material extraction and manufacture.

To review the report in depth, please visit: http://www.env.gov.bc.ca/epd/recycling/resources/reports/pdf/wpsc_dbc_job_economic_impact_study.pdf

Remembering Pat Franklin

By Bill Sheehan, Executive Director

I mourn the passing of my good friend and colleague Pat Franklin.  She single-handedly kept the issue of unconscionable beverage container waste alive through the 1990s. Bottle bills were enacted in 10 US states in the 1970s and 80s. By 1994, when Newt Gingrich introduced his Contract On America to repeal all manner of environmental legislation and regulation, most environmentalists moved on from trying to pass more bottle bills.  Not Pat. She, virtually alone, kept the flame alive through the organization she founded, Container Recycling Institute. 

I learned so much from Pat.  One of the first papers I read on EPR was written by Pat: Extended Producer Responsibility: A Primer, presented at Michelle Raymond’s 1997 Take it Back! Producer Responsibility Forum.  Pat was an early adopter who understood that producer-managed bottle bills were the original EPR laws in North America.

I worked alongside Pat on numerous projects and campaigns, first as the Executive Director of GrassRoots Recycling Network, then as Executive Director of Product Policy Institute. Her house was always open to me when I came to DC, and also to my family. Most of all, I miss Pat’s warmth, clarity of focus, and indomitable spirit.  She was a true pioneer and hero to all of us working to make products and packaging more sustainable.

To read a tribute to Pat from Container Recycling Institute, please click here. 

Understanding British Columbia's EPR Regulation

Guest Blog by Sue Maxwell

Sue Maxwell is a zero waste and sustainability consultant who has worked on developing several new EPR programs in British Columbia and other provinces. She has been an active volunteer promoting zero waste solutions with the Recycling Council of BC and other organizations.

British Columbia’s Extended Producer Responsibility (EPR) system is an interesting one to look at in more detail as it has been used as a model for the Canada-wide Action Plan for EPR. The action plan was created by the Canadian Council of Ministers of Environment (CCME). All provinces and territories in Canada agreed to it in 2009. They agreed that by 2015, each jurisdiction would have EPR programs for a common set of products (mercury containing lamps and other mercury-containing products, household hazardous and special wastes, automotive products, packaging and printed materials, electronics and electrical equipment) and a further set of products by 2017 (construction and demolition materials, textiles and carpet, furniture and appliances including ozone depleting substances).^[1]

The Action Plan specifies principles and goals, many of which were based on the BC model. The goals of the Action plan are to have programs that:

·         Move towards full life-cycle cost accounting

·         Treat costs similarly to other factors and are incorporated into prices

·         Shift the expenses from taxpayers to producers and consumers

·         Reduce the amount of waste generated and going to disposal

·         Reduce the toxicity and environmental risks from products and product waste

·         Improve the overall life-cycle performance of products, including GHG

BC has a framework regulation model that for the most part, addresses these goals. The BC Recycling Regulation outlines general requirements for programs with specific schedules for particular product categories. Most programs are held to the same standards but there can be unique requirements for product categories. Beverage containers, for example, are limited to refillable or recyclable containers and have deposits attached. When the province wishes to add another category, it adds a schedule to the existing regulation rather than needing to develop a new, separate regulation. This simpler process allows for quicker implementation for new product categories and more consistency in program requirements which also provides more certainty for the producers.

Producers are essentially the first sellers of the product in BC –ideally the manufacturers, but if not them, then the brand owners and then the distributors and retailers. For most product categories, producers have a choice to develop and submit for approval a program plan (usually as a group, often facilitated by industry associations and resulting in programs run by Producer Responsibility Organizations) or to meet strict regulatory requirements for product stewardship services as an independent producer. The BC regulation allows for more than one program for the same product category, allowing for competition or the creation of producer-specific programs.

With the BC model, it is up to the producers to develop a program that will meet the regulatory requirements. By focusing on the outcomes of the program, it allows producers flexibility in how they achieve those goals and they can better tailor their program to their specific products. For example, the Post Consumer Pharmaceutical Stewardship program has a collection network of most of the pharmacies in BC. This works well for these returned products as there are considerations for toxicity, risk of theft and privacy of individual’s information that are handled by pharmacists already and pharmacies are a natural point of contact for the consumers of those products.

The Recycling Regulation requires new programs to submit a program plan that addresses the following:

·         Stakeholder Consultation

·         Collection System and Consumer Access

·         Consumer Awareness

·         Program Performance Measurement

·         Management of Program Costs

·         Dispute Resolution

·         Product Life Cycle Management

·         Pollution Prevention Hierarchy

Once a program plan is submitted, the Ministry of Environment reviews it for completeness and may ask for revisions before approving it. The Regulation is intended to be outcomes based, rather than prescriptive so the plan should show how the program will meet the intended outcomes. The Regulation requires programs to provide publicly available annual reports and spells out what must be included in the reports. These reports must include a third-party audited financial statement for programs charging fees to members and recently the Ministry has been asking for third party audits of other aspects as well. Every five years, the program plan must be renewed in a process that includes further stakeholder consultation. Programs that do not meet their obligations can have their plan approval revoked.

The BC EPR system, while not perfect, provides a strong model for producer responsibility as was recently affirmed by EPR Canada’s recent report card where it was graded A-, the highest ranking of all jurisdictions in Canada.

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[1] The territories agreed to slightly lower requirements to recognize some of the unique challenges that they have regarding population density, transport, infrastructure and supply chains.

Public Interest Groups Call on P&G to Help End Packaging Waste

Bob McDonald

Chairman, CEO

Proctor &Gamble

1 Procter & Gamble Plaza
Cincinnati, Ohio 45202

RE: P&G’s Sustainability Commitments Regarding Packaging Waste

Dear Mr. McDonald,

We the undersigned, represent organizations from around the United States, concerned about the widespread impacts of packaging waste on our environment and economy.  We commend Procter & Gamble’s “sustainability vision” to use “100% renewable or recycled materials for all products and packaging, having zero consumer waste go to landfills and … maximizing the conservation of resources.”  However, we are deeply troubled by the lack of a plan or context for achieving such a sweeping vision.  We would like to further understand how the company intends to establish metrics, actions and timelines to meet this pledge.  We are interested in working together on solutions to reduce post-consumer packaging waste.

In the U.S., local governments have long subsidized the costs of waste, by assuming full responsibility for recycling and disposal of virtually everything consumers deliver to their curb.  But unfortunately, when costs like these are subsidized, they keep increasing.  The practice where producers privatize the profits of waste, but socialize the costs, can’t be sustained forever. 

According to EPA, products and packaging account for 44% of US greenhouse gas impacts – more than heating and cooling of buildings, local passenger transportation, or food production. Packaging is about a third of the waste stream, and over half of all consumer packaging winds up in the garbage.  If you exclude corrugated cardboard, which is collected at high rates by retailers, the recovery rate for post-consumer packaging falls to an abysmal 26%.  And it only gets worse with plastic, where only 12% of plastic packaging is collected for recycling.  Waste packaging ends up as roadside litter, dioxin emissions from incinerators, the unnecessary depletion of natural resources, and marine debris that fouls our beaches, kills wildlife and leads to the toxic garbage patches throughout the world’s oceans.

Beyond the environmental implications, packaging waste is a lost opportunity to grow American jobs at a time when we desperately need them.  The commodity market value of wasted glass, plastic, paper and metal packaging has been estimated at $11.4 billion dollars.  If the overall US recycling rate grew from 33% to 75% - a rate achieved in European Countries with mature producer responsibility systems – we could create 1.5 million new jobs, according to a report recently issued by the Blue-Green Alliance.  Recycling creates 20 times more jobs than waste disposal.

As the world’s largest consumer and packaged goods company, which is deeply implicated in the problem of packaging waste, we believe you have a moral imperative to help solve it.  We call on you to embrace your responsibility to lead the industry in addressing these challenges.  Increased recycling of packaging can have a significant impact on decreasing the unsustainable extraction of virgin natural resources, reducing marine debris and diminishing air and water pollution.

We therefore urge you to commit to the following:

·       Engage in stakeholder discussions to explore areas of common ground and identify opportunities for P&G to recycle post consumer waste.

·       Explore Extended Producer Responsibility (EPR), which is being advanced by a growing network of businesses and public interest organizations, as a viable public policy option to achieve your stated sustainability goals.

Please direct responses to Mr. Matt Prindiville with the Product Policy Institute at 207-902-0054 or matt (at) productpolicy.org.

Sincerely,

Associated Recyclers of Wisconsin
Karin Sieg, Executive Director
Stevens Point, WI

Austin Zero Waste Alliance
Stacy Guidry, Chair
Austin, TX

California Product Stewardship Council
Heidi Sanborn, Executive Director
Sacramento, CA

Clean Water Action, Massachusetts
Lynne Pledger, Solid Waste and Recycling Project Director
Boston, MA

Clean Water Action, Rhode Island
Jamie Rhodes, Executive Director
Providence, Rhode Island

Center for Health, Environment& Justice

Mike Schade, Campaign Coordinator

Falls Church, VA

Clynk
Clayton Kyle, CEO
South Portland, ME

Colorado Association for Recycling

Darla Arians

Boulder CO

Colorado Product Stewardship Council

Darla Arians

Boulder, CO

Conservation Law Foundation
Sean Mahoney, Executive Director
Portland, ME

Central Texas Zero Waste Alliance
J.D. Porter, Chair
Austin, TX

CRADLE2 Coalition
Matt Prindiville, National Coordinator
Rockland, ME

Don’t Waste Massachusetts
Lynne Pledger, Chair
Springfield, MA

Electronics Takeback Coalition
Ted Smith, Chair
San Francisco, CA

Eureka Recycling
Tim Brownell, CEO
Minneapolis, MN

Full Circle Environmental
David Stitzhal, Director
Seattle, WA

Institute for the Development of Educational and Ecological Alternatives Inc. 

Eilee Sison, Director

Marin Recycling and Resource Recovery
Devi Peri, Education Coordinator
San Rafael, CA

Mother Earth Foundation
Sonia S. Mendoza, Chair

Natural Resources Council of Maine
Abby King, Clean Production Project Director
Augusta, ME

Northwest Atlantic Marine Alliance
Boyce Thorne Miller, Science Coordinator
Gloucester, MA

New York Public Interest Research Group
Laura Haight, Senior Environmental Associate

Albany, NY

Nothing Left to Waste
Susan Hubbard, Director
Saint Paul, MN

Ocean State Action

Kate Brock, Executive Director

Providence, RI

Oceans Recovery Alliance
Doug Woodring
Hong Kong

Plastic Disclosure Project
Doug Woodring
Hong Kong

Plastic Pollution Texas
Mary Wood, Joe Lengfellner, Patsy Gillham
Houston, TX

Product Policy Institute
Bill Sheehan, Executive Director
Athens, GA

Product Stewardship Institute
Scott Cassell, Executive Director
Boston, MA

Seventh Generation Advisors
Leslie Tamminen
Santa Monica, CA

Texas Campaign for the Environment
Robin Schneider, Executive Director
Austin, TX

Vermont Public Interest Research Group
Lauren Hierl, Policy Advocate
Montpelier, VT

WeTap
Clean Seas Coalition
Evelyn Wendell, Executive Director
Los Angeles, CA

Women's Voices for the Earth
Erin Switalski, Executive Director
Missoula, MT

Zero Waste Washington
Suellen Mele, Executive Director
Seattle, WA