In May 2011 the Government of British Columbia amended the BC Recycling Regulation, including the addition of Schedule 5 Printed Paper and Packaging (PPP). The changes make BC the first jurisdiction in North America to hold industry stewards fully responsible for materials typically managed via municipal blue box programs under a “shared cost” model for end-of-life management.
Highlights of the amendments include:
1. Expands the definition of “producer” to “a person who manufactures the product and sells, offers for sale or distributes or uses in a commercial enterprise the product in British Columbia…”; (emphasis added)
2. Requires a stewardship plan for PPP generated by the residential sector from “residential premises” and from “municipal property that is not industrial, commercial or institutional”;
3. Requires a 75 per cent recovery rate for PPP; and
4. Provides a three-year timeline for stewards to implement a PPP program; 18 months following May 19 2011 producers of PPP must submit a stewardship plan to the Director (by November 19, 2012) and in 36 months must implement the plan (by May 19, 2014).
Consistent with the treatment of other designated materials under the BC Recycling Regulation, PPP producers can choose to either discharge their obligations individually or by joining a stewardship agency. Where stewards choose an agency, the agency must file a stewardship plan with the BC Ministry of Environment. Interestingly, the relationship between PPP stewards and municipalities is not preordained in BC regulation; program design options could engage both private and public players to achieve the producers’ performance obligation in the most efficient and effective way possible.
Stepping into the role of stewardship agency is Multi-Material British Columbia (MMBC), comprised of various commercial stakeholders. MMBC is currently developing its PPP stewardship plan through a two-phased approach: Phase 1 involves analysis of the current waste diversion system and the development of program options; Phase 2 involves development of the program using the selected option.
Based on observations of other EPR programs, the program that MMBC could deliver on behalf of stewards could include such actions as: taking direct control of collection and processing services; contracting with municipalities and private companies to provide collection and processing services; stimulating collection and processing activities through the use of financial incentives; or, various combinations of these marketplace activities.
Different program design options could have significantly different economic and environmental outcomes, and in many cases involve trade-offs. In order to explore these trade-offs, a study team has been assembled that will apply an objective evaluation framework to identify the strengths and weaknesses of the various options.
A number of factors need to be considered in the design of a program for BC’s unique regulatory, economic and geographic profile.
The BC Environmental Management Act, Recycling Regulation and Local Government Act create a specific set of existing provincial recycling programs (most notably, a beverage-container deposit-refund system) and local government authorities for the management of waste (and licensing of waste management services).
This BC regulatory framework has shaped the recycling infrastructure and commercial relationships that exist “on the ground” today. Some local governments have recycling programs for PPP while others do not. Where local governments aren’t active, some residential areas have access to privately-operated depots or receive PPP collection as a subscriber service from private providers; some areas have no access to recycling (other than beverage-container depots). Some bottle depots provide PPP collection services in addition to beverage container redemption, while most do not.
Processing and marketing services are primarily provided by the private sector. Processors receive beverage containers from the provincial deposit-refund system as well as PPP from existing local government programs and private sector depots and subscriber collections from the residential and commercial sectors. Processors have developed significant volumes and economies of scale, and have an established network of domestic and out-of-province materials markets.
The study team is working to map and understand the existing commercial relationships that drive the collection and flow of PPP in BC. This understanding will inform the evaluation of the program design options and, in particular, the identification of strengths and weaknesses of the various options.
While discussions on possible program design options are underway, the requirements of BC’s Recycling Regulation Schedule 5 and the work of MMBC and its study team will lead to a unique approach to delivering an EPR program for PPP in North America.
Glenda Gies is Principal of Glenda Gies and Associates in Bowmanville, Ontario and is the MMBC Phase 1 project team leader. Contact Glenda at email@example.com Usman Valiante is a Senior Policy Analyst with Corporate Policy Group LLP in Orangeville, Ontario and a member of the project team. Contact Usman at firstname.lastname@example.org