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Letter on EPR offers insights


I thought readers might enjoy this letter from consultant and contributing editor Usman Valiante. It contains some observations about EPR and competition that are worth noting.
Here’s the letter:
Hi Guy,
I had the misfortune of attending Environment Canada’s 6th National Extended Producer Responsibility (EPR) Workshop on the 27th and 28th of April.
Before I talk about the workshop, it is important to note that in the same week, on Friday April 30th , Ford Canada launched a program that provides consumer cash rebates for the purchase of new Ford vehicles where the consumer returns a used car to the Ford dealership for recycling. The Ford program sends the collected used cars to members of the Ontario Automobile Recyclers Association (OARA) who subscribe to the National Car Recycling Code of Practice. This is EPR, and Ford is using EPR “voluntarily” to sell more cars.
Regulated EPR shouldn’t be a lot different than what Ford is up to. EPR is nothing more than a producer having its products or packaging recovered, reused and recycled in accordance with clearly defined, government set environmental standards and diversion targets. The producer in question must also be prepared to verify its waste diversion claims when audited.
In a regulated system the producer either meets the environmental target or fails to meet it and thus suffers set penalties for failure. All that matters is the outcome. How the producer gets to the outcome whether individually, as part of a collective or standing on its head is irrelevant.
But it isn’t that simple in practice because it’s in the interest of many to make EPR really complicated.
EPR has become a bit of a cottage industry for a lot of people that have no practical experience in it. The bulk of folks involved in EPR – the lobbyists, regulators, academics and waste diversion “oversight” bodies such as Waste Diversion Ontario – have built professional careers talking about subjects like “steward fee setting”, “rules for stewards”, “cost sharing”, “cost shifting”, “orphaned products”, “historical waste”, “competing IFOs”, “cost internalization”, “visible fees”, “level playing fields between Industry Stewardship Plans and Industry Funding Organizations”, “harmonization” and other sundry nonsense.
Every time anyone refers to “the European EPR experience” my head swims and I start hearing Falco’s “Rock me Amadaeus.”
Scanning the workshop I’d have been hard pressed to find even a handful of people who have built a business plan, designed an incentive system, negotiated a recycling contract or been responsible for a commercial stewardship program’s profit-and-lost statement.
There were Americans in the audience and it’s scary to think that Ontario’s Blue Box program is being sold to them as true EPR.
There were however a couple of breaths of fresh air.
Jo-Anne St. Godard of The Recycling Council of Ontario finally pointed to the elephant in the corner of the conference room when she called out visible eco-fees as government sanctioned price fixing stating, “…fixed fees which can be easily passed through to customers, this may mean limited direct financial cost or risk impact when all producers are charged the same fee.” This didn’t go well with some in the audience.
That was followed by the Martin Luymes of the Heating, Refrigeration and Air Conditioning Institute of Canada (HRAI) who described WDO’s challenges as HRAI tried (finally with success) to get its pre-existing and successful EPR program for mercury containing thermostasts approved by WDO. WDO didn’t comment but I’m sure it will cook up other bureaucratic and administrative tortures to visit upon HRAI.
The Ontario Government once again delivered its canned Waste Diversion Act review presentation. One can only hope what is being proposed gets enacted before more products are subjected to Ontario’s version of Extended Producer Waterboarding.
To sum up, I won’t be going to Environment Canada’s 7th National Extended Producer Responsibility (EPR) Workshop. I think I’ll go watch the movie Brazil instead.
Usman Valiante, Senior Policy Analyst
Corporate Policy Group LLP


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