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