An industry lobby is asking New Brunswick’s environment minister to alter Bill 15 — the province’s new product stewardship legislation. As drafted, Bill 15 would prohibit separate stewardship fees from being shown to consumers and, in effect, make it difficult for brand owners to pass on recycling and waste diversion costs to a third-party stewardship board, as occurs in some other provinces (notably Alberta).
In their letter dated February 1st, Damian Bassett , president & CEO of CSR, Diane Brisebois, president & CEO of the Retail Council of Canada, and Gemma Zecchini, Senior VP — Public Policy for FCPC, ask Trevor Holder, environment minister for New Brunswick, to remove paragraph r.26 from Bill 15, “An Act to Amend the Clean Environment Act.”
Bill 15 has received Second Reading and is expected to pass final reading in the New Brunswick legislature. Paragraph r.26 is a bold step in product stewardship program design because it blocks the ability of brand owners (and “first importers”) of such things as electronics waste to impose advance disposal fees (ADFs) on their customers. Critics say that ADFs allow brand owners to avoid direct responsibility for their discards and any strong incentive to re-engineer products to facilitate ease of recycling (the Extended Producer Responsibility model).
Bill 15 and the industry letter are posted as downloadable pdf files under Posted Documents. Please also read Editor’s Blog for further analysis of this issue, and for another copy of the letter.