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.