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Canada's botched EPR plans derailing US product stewardship


plastic-bottles-photoWhen I first received the news release on March 24 from the National Waste & Recycling Association — a US trade organization that represents private waste services companies — I was quite shocked and somewhat appalled at the group’s strident position opposing, apparently, any form of product stewardship or extended producer responsiblity (EPR) for printed paper and packaging waste.

It’s unclear from the wording of the release whether the association is talking only of paper and packaging made of paper (with printing on it) or all packaging waste (e.g., plastic bottles, yoghurt tubs, etc.). It seems, however one reads the release, that the group is simply unimpressed with product stewardship and wishes to maintain a kind of status quo of municipal curbside recycling, with private and public crews collecting and processing material.

I both agree and disagree with the NWRA on this matter. I reproduce its news release below without edits so you can read for yourself what they say.

I’ll just clarify what I disagree with and then what I agree, or at least understand.

I believe that the long-term solution to “the waste problem” is for society to eventually not generate waste at all, but fundamentally change how it produces and distributes goods, with “waste” eventually designed out of the system almost entirely. In that world it would be fine for a producer to sell a product in a package, but they’d be individually responsible for end-of-life management of that package (which would often mean recycling it). I am therefore a proponent of individual producer responsiblity (IPR) in which individual companies can set up their own collection systems, join voluntary collectives, and/or contract with municipalities to collect their materials (where that offers the best economies of scale, etc.).

In North America, we really haven’t seen IPR except for a few very limited materials. I usually offer The Beer Store in Ontario as an example of an IPR-type program that achieves excellent results. I’d like to see materials managed in a flow like that for most other packaging. Broader programs for product and packaging stewardship are being introduced in Ontario and (especially) British Columbia. They may have flaws but it will be very interesting to see how they perform and measure the results in the next few years. So, I don’t agree with the NWRA in opposing product stewardship in every form; it’s still early days and some huge success stories may be on the horizon.

That being said, I understand (this is the “agree” part) the NWRA’s position, if it’s looking at Canada for examples of EPR screw-ups. If there’s one statement in its release I relate to, it’s: “Product stewardship programs with third party oversight can potentially violate antitrust law by undercutting fair competition in recycling collection and disposal.” They sure got that one right, and that again speaks to the need for IPR. It’s clear that Canadian fumbling of the issue is giving the whole product stewardship concept a black eye. We need to start getting this right or we’ll not only blow it for our own country but the whole continent!

One more food-for-thought item. The NWRA states: “These programs also create higher costs for consumers, as manufacturers are likely to pass on the costs of mandated stewardship programs by raising their prices.” To which I I reply, “So what?” In a properly designed IPR program, producers have the option to absorb the costs or pass them along to customers in higher prices. Whatever they do, the cost of end-of-llife management of product waste will reside where it belongs, with the “polluters” and their customers, and not on municipal ratepayers where the cost is a subsidy. Until we assign costs where they belong in the economic system, industry will have no real incentive to change, but only to give donations to “feel good” campaigns like Keep America Beautiful even as they continue to produce enough, say, plastic soda and water bottles each year to go (I don’t know how may times) between the Earth and Moon, a large number of which end up in landfill even in the system that the NWRA says is so good.

So I disagree with the NWRA (strongly) but I completely understand why it takes the position that it does. (I suggest, however, that they should look closely at the German system, which in recent years has overcome the kind of anti-comptetiveness problems that plagued earlier versions. Oh, and be warned they’ll have to wade through a lot of misleading nonsense about Germany’s program written by folks to discourage its adoption in North America. And just about anything from Nestle Waters about product stewardship needs to be viewed with similar suspicion.)

Okay, here’s the NWRA release:

Waste Industry Unveils Product Stewardship Policy on Packaging and Printed Paper

Industry opposes product stewardship mandates for paper products over concerns programs will increase costs for consumers, hurt recycling rates and undercut competition

WASHINGTON (March 24, 2014) — The National Waste & Recycling Association (Waste & Recycling) today confirmed a new industry position opposing local and state government mandates governing “product stewardship” for printed paper and packaging.

Waste & Recycling is the trade association representing private sector companies across all 50 states that collect, manage, dispose and recycle waste.

“Advocates may promote legislation mandating ‘product stewardship’ programs for printed paper and packaging as a way to increase recycling rates and make retailers ‘pay’ for recycling—but these kinds of programs are rife with pitfalls and unintended consequences,” said Sharon H. Kneiss, president and CEO of Waste & Recycling.

“Our industry has spent hundreds of millions of dollars building, growing and maintaining our nation’s recycling infrastructure and the curbside collection programs that have contributed significantly to Americans’ generally high recycling rates,” Kneiss said. “Meanwhile, we are already generating less paper waste today than ever before, and packaging recycling rates are higher than ever. Complicating these successes through government mandates is a mistake.”

Among the concerns raised by Waste & Recycling’s position paper on product stewardship programs for printed paper and packaging:

  • Product stewardship programs have not been shown to increase recycling rates for paper and packaging
  • These programs disrupt successful existing recycling programs; displace local government responsibility for solid waste management; and require the insertion of a third party organization comprised of manufacturers with little experience in or passion for recycling collection or processing
  • Product stewardship programs with third party oversight can potentially violate antitrust law by undercutting fair competition in recycling collection and disposal. These programs must be carefully monitored to ensure they do not violate the law
  • These programs also create higher costs for consumers, as manufacturers are likely to pass on the costs of mandated stewardship programs by raising their prices.

“The waste and recycling industry agrees that America’s recycling rates have room for improvement, but mandated product stewardship programs are not the right path,” Kneiss said. “Better options include imposing stronger recycling laws on residents and businesses; increasing the size of curbside recycling carts; encouraging manufacturers to use recycled content; and boosting public education on the importance of recycling.”

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The National Waste & Recycling Association is the trade association that represents the private sector waste and recycling services industry. Association members conduct business in all 50 states and include companies that collect and manage garbage, recycling and medical waste, equipment manufacturers and distributors and a variety of other service providers. For more information about how innovation in the environmental services industry is helping to solve today’s environmental challenges, visit www.beginwiththebin.org

 


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