Beep! Beep! There goes my pager again. What’s the message this time? Uh oh — Alberta is blundering forth with another questionable product stewardship program.
Readers of this page already know I think Alberta’s used-oil stewardship program is flawed. (See Editorial “Lubricating Public Policy” Dec/Jan. 2004 edition.) It seems others agree — Ontario recently rejected an Alberta-style used-oil plan.
Now the province is screwing up electronics product stewardship, ramming through a simplistic collection/recycling scheme that ignores the 12 guiding principles for electronics stewardship adopted by the Canadian Council for Ministers of the Environment (CCME). (For details, see the Product Stewardship article, page 42.) That’s a real shame since the private sector has shown goodwill on this front and spent millions developing an industry-led solution; one in which brand owners and retailers will take responsibility for electronics waste diversion and recycling, and encourage the mother of all stewardship goals: design for disassembly.
A non-profit organization is developing a national electronics end-of-life program implemented by industry with the support of the provincial and territorial governments. It’s a joint effort of two groups who know a thing or two about electronics: the Information Technology Association of Canada (ITAC) and Electro-Federation Canada (EFC). Its founding members include the Canadian divisions of 16 leading electronics manufacturers such as Apple, Brother, Canon, Dell, Hewlett-Packard and IBM.
Hmm. I think I’d consult with companies like that before I announced an electronics stewardship program. Wouldn’t you? Especially if they already had their own national organization. Maybe the name was too vague for Alberta policymakers. Let’s see now, what is it called? “Electronics Product Stewardship Canada.”
EPS Canada strikes me as a potential island of common sense in a sea of rudderless producer responsibility schemes. Recognizing the balkanized nature of the country, the organization hopes to work with governments as they indicate readiness to move forward with regulation and legislation, looking for “a domino effect with subsequent provinces/territories.”
The organization’s literature states that it seeks flexible, non-prescriptive regulations which place the onus on industry to create an acceptable stewardship program. The organization would set, collect and disburse fees, negotiate the addition of new products to the range of recycled materials, add new members, monitor provincial performance and reporting (including penalties for non-compliance) and determine sunset requirements for visible fees and program administration thereafter.
EPS Canada “gets it” that product stewardship is complex. There’s the need for standard vendor qualification program for recyclers, coordination of R&D projects, feedback to manufactures on design for the environment and recycling, and public education programs.
But Alberta has announced that starting October 1, 2004 (an impossibly short deadline) televisions, computers and related equipment will be recycled. Collection of the used products will be coordinated locally and an environmental fee, ranging from $5 to $45 (depending on the item) will be placed on each product. The fees will be established by a non-profit company, the Alberta Recycling Management Authority (formerly the Tire Board which has run a huge surplus), which will collect the fees from wholesalers, manufacturers, distributors and retailers. (Makes me wonder if the Alberta tire guys simply didn’t like the thought of EPS Canada collecting and handling the fees in a national program.)
One only has to look south of the border to see the folly of rushing, and the prudence of thinking things through.
California tried to jam a program in place and then had to defer it. The sunbelt state chose a peculiar form of stewardship designation to address computer monitors, saying anything with a screen larger than four inches was included. The result? New LCD displays — with dramatically fewer environmental issues than the old-style cathode-ray picture tubes — are included in the fee schedule. LCD screens that are just beginning to permeate the market are heavily levied to cover the cost of managing CRTs coming out of service; a case of taxing the good to pay for the bad!
Contrast that with the State of Maine which made collection of electronics a municipal duty but assigned responsibility for all the back-end consolidation and processing to the brand owners. Maine took several years to develop its sensible program — not six months!
Perhaps the biggest flaw is that Alberta has failed to properly assign “property rights” where they belong (i.e., with the brand owner or first importer as “steward”). Alberta’s proposes that everybody is a steward: manufacturers, importers, retailers, heck, even couriers! Without clear assignment of who owns the problem there will be no upstream effect on the manufacturers.
This is a tricky policy area. For example, Dell does direct business via the Internet. How is Dell going to be assigned liability for Internet sales? How are fees going to be collected? Does anyone know? Does anybody care?
Apparently very little environmental and economic assessment went into setting up what promises to be a costly monopolistic boondoggle. Affected parties were not shown the regulation before it was promulgated; all the goodwill embodied by EPS Canada was simply ignored.
Alberta needs to recharge its policy batteries fast, before the big boys get tired of waiting, pack up their Game Boys and Playstations and go home.