The power of extended producer responsibility (EPR) is its potential to harness the forces within the marketplace to drive improvement in the environmental performance of products. To be successful in this objective, EPR programs must be rooted in a clear understanding of the product marketing process. They must foster fair competition and not inadvertently disadvantage certain competitors for reasons that have nothing to do with environmental protection. They must also foster accountability, so that governments can track the producers’ performance and require modifications to improve performance.
British Columbia’s product-by-product approach to EPR comes as close as any in North America to meeting these criteria, and it contains critically important lessons as it applies to packaging. In BC, all producers (brand owners/first importers) within a designated product category are subject to the same rules. Producers have full control over the design and operation of their programs subject to approval by government on the basis of clear criteria. Brand owners bear the full costs of environmental management with no public subsidy and they are obliged to report regularly on their programs’ performance.
BC’s programs are all rolling out relatively smoothly. They have fostered collaboration and information-sharing towards environmental improvement within the product sectors that are involved (electronics, beverage, paint, used oil, tires, etc.). The producers, government and public can all pinpoint with precision where programs need adjustments. Most important, EPR programs are relieving local governments in British Columbia of costs and risks incurred through municipally-operated diversion programs for products and packaging waste.
A product-by-product approach will bring similar good results for packaging, but only if rooted in a clear understanding of where packaging fits in the product marketing process. To catch a rabbit, think like a rabbit. Intuitively, we think of “packaging” as a product category, with subcategories defined by material type (e. g., glass, plastic, composite, etc.). This is the waste manager’s “end of pipe” perspective, based on seeking end-users for collected materials. But from the marketing perspective (the beginning of the pipe) packaging is not a “product” in itself but an indivisible part of the product it contains. Brand owners carefully specify their packaging as an important component in their “marketing mix” (along with price, promotion, positioning, etc.).
What does this tell us about EPR for packaging? From the industry perspective, product packaging falls into natural categories (called “applications”) that reflect the characteristics and needs of different kinds
of products. Within each application, several different packaging suppliers may compete to provide packaging solutions for different marketing purposes. A good example is the beverage packaging application, which utilizes aluminum cans, PET bottles, glass bottles, aseptic boxes, etc., as specified by the brand-owner. Canada’s most successful and long-standing “stewardship” program for packaging regulates packaging by
application. BC’s Recycling Regulation requires all brand owners (except milk) within the beverage
application to provide stewardship of their packaging regardless of the material it is made with. More recently, two additional packaging applications have been regulated under the BC Recycling
Regulation (paint and used oil).
Last year the Recycling Council of BC (RCBC) called for housekeeping changes to the Recycling Regulation so that all product categories would include “associated packaging.” RCBC also recommended to BC
Environment Minister Barry Penner that a new packaging application — soaps, cleaners and detergents — be brought under the regulation. The recommendation was supported by the Metro Vancouver (formerly GVRD) Board. This application includes bulky plastic jugs and bottles, boxboard boxes and plastic sacks. The domination of this application by a small number of well-known brand owners will facilitate compliance and performance tracking. It makes sense for EPR to be structured around product segmentation system that reflects the industry’s own segmentation. As EPR is expanded, product by product and application by application, municipal waste management will no longer need to deal with packaging of any type.
Helen Spiegelman is coordinating a new independent citizen’s initiative called Zero Waste Vancouver. Contact Helen at firstname.lastname@example.org
See www.zerowastevancouver.blogspot.comThis article first appeared in Ben Bennett’s Product & Packaging Stewardship Review, January 2008 edition.