Food & Consumer Products of Canada (FCPC) has responded to Rob Cook, CEO of the Ontario Waste Management Association (OWMA) and the letter he circulated recently to Ontario provincial members of parliament and other stakeholders, which was published on this website last week.
In his letter, Cook took exception to what the OWMA believes are alarmist claims from the FCPC about economic damage from Ontario’s proposed Bill 91, Waste Reduction Act, which would see industry “stewards” made individually responsible for the full end-of-life management costs of their products and packaging. (Currently, certain industries pay only 50 per cent of the net costs of those materials that make their way into the province’s municipal Blue Box curbside recycling program.)
OWMA member companies — which collect, process and dispose of consumer and commercial byproduct materials — have a keen interest in seeing Bill 91 take effect, subject to certain tweaks of the regulation that they and other groups have suggested. Conversely, FCPC member companies (the stewards) have an interest in delaying the bill and reducing the economic impacts upon their companies.
The FCPC letter below states the position of its members and needs no editorializing, other than to say that this is what one would expect of industry, as it’s being forced to internalize the costs of its packaging and product waste. It will be interesting to follow the outcome of the arguments and see if they become an election issue, and if the Ontario Liberals move forward with Bill 91 in the current term. If they do, Ontario will certainly become North America’s leading jurisdiction for extended producer responsibility (EPR). We hope modifications are made to the bill as have been discussed on this website. (See earlier entries by contributing editor Usman Valiante.)
Here’s the FCPC letter:
November 20, 2013
Mr. Robert Cook
Chief Executive Officer
Ontario Waste Management Association 2005 Clark Blvd., Unit 3
Brampton, ON L6T 5P8
Dear Mr. Cook,
I would like to take this opportunity to respond to your letter dated November 13, 2013. FCPC has pursued constructive, respectful dialogue in advocating for its members on Bill 91 and the Waste Reduction Strategy. In this vein, I offer you the following comments:
- FCPC stands by its estimates of the overall costs to industry of $300-500 Million if Bill 91 and the Waste Reduction Strategy come into effect. These will be borne by manufacturers, workers, consumers and ratepayers.
- FCPC has repeatedly asked the government to expedite its own comprehensive economic impact analysis, and not leave it until the regulation making phase, which we feel will be too late. We believe these costs must be transparent and known, particularly to those they will most impact.
- As you well know, members of Food and Consumer Products of Canada (FCPC) fund and support stewardship programs across the country, and currently fund 50% of Ontario’s Blue Box program. Far from seeking to avoid financial responsibility, we shoulder it.
- FCPC and its members support full producer responsibility that is fair and competitive. We support the lifting of the 50% funding cap on the Blue Box, if that responsibility is accompanied by commensurate program authority and decision making.
- FCPC and its members have been and are engaged in dialogue with elected officials, public servants, municipalities, businesses, associations and NGOs. We have engaged and continue to meet with individual municipalities, the Recycling Council of Ontario, AMO, RPWCO, and WMA in the pursuit of common ground and solutions.
The tone and aggression of your letter were very disappointing. FCPC will continue to engage in productive and factual dialogue as we advocate on behalf of our members.
President & CEO
Food & Consumer Products of Canada (FCPC)