In British Columbia, Extended Producer Responsibility (EPR) for Printed Paper & Packaging (PPP) is driven by the producer’s obligation to achieve 75% diversion of the PPP that they sell into the Province. To further elaborate, this obligation was created in May of 2011 when the BC Recycling Regulation was updated to include printed paper & packaging. I have tried to translate what this obligation really means:
Translation …obligation means that the producer will pay for 100% of the costs associated with recycling PPP in BC.
Translation…producers will be mandated to get 75% of their product recovered and sent to a viable and real end market where it can be reprocessed into something new. Producers will not be able to collect and send materials to landfill.
Translation …the BC Recycling Regulation has real "teeth" and officially and legally transfers the costs and the performance obligations to the producers by the BC Ministry of Environment (MoE).
To further complicate matters, the MoE wants producers to start with PPP produced in the residential sector, not in the commercial sector. The commercial sector will also be targeted at a later date.
All these EPR concepts and terms seem like big words to me that don’t always explain or tell the whole story of this producer obligation. More simply, the obligation will require the producer to pay 100% of the costs for:
- collection
- transportation
- processing and
- marketing
… of 75% of their PPP that is sold in the province of BC.
Sounds simple, right? Actually, I believe that it is not as straightforward as it seems for several reasons:
Firstly, printed paper and packaging 100% producer pay has never been done anywhere in North America.
Secondly, there is an integrated and complex supply chain in place to deal with a lot of the materials that are printed paper and paper packaging. In particular, in a recent study, it is believed that BC is currently recycling or diverting 60% plus of all the printed paper and packaging created in the Province.
Thirdly, there are complex commercial relationships in place for much of the collection and processing of residential recycling.
I believe that the most challenging of the four parts of the chain are the final two, processing and marketing. Although collection and transportation in my view are the simpler of the steps, they certainly have their challenges as well, such as: appropriate truck technology to collect efficiently at the curb, appropriate scheduling and collection containers, call centres that process customer questions, requests and comments, etc.
Because EPR is a complex issue, I have decided to break up this blog post into separate discussions. The first one today, has been titled as Background to EPR Challenges in BC and I will endeavour explain the main challenges I see with EPR. I feel that I have a good grasp on the key issues with respect to EPR in BC. It is my intent through this blog, to try and demystify EPR for the consumer, businesses and interested parties. Perhaps, as I continue to explore and explain further separated posts will evolve.
At the end of each blog post I will define each of the bigger terms I refer to throughout this commentary. My intention is not to be repetitive but to include these definitions as part of the commentary and to further explain the issues.
I appreciate and welcome comments, so please do not hesitate to do so.
Definitions
Extended Producer Responsibility – where the producer of the material or product is required to pay the costs of collection, transport, processing and marketing of the product that it imports.
Material Recovery Facility – facility where the recyclables are delivered, sorted and processed, baled and finally shipped off to market.
Market – in this context market is a viable end purchaser of the feedstock or product produced at a MRF. The end market would be expected to further process the recyclables and make a new package or consumable with them.
Marketing – actively communicating and interacting with end users or re-processors of the recyclable material. Marketing would include ensuring that there are viable freight costs to the end processor, and to review credit worthiness of the end processor.
Ministry of Environment – the provincial ministry that is responsible for the Recycling Regulation.
Printed Paper and Packaging (PPP) – all printed paper such as newspapers, magazines and marketing materials, and packaging such as plastic, paper, metal, glass or multi composite materials.
Processing – receiving, grading, sorting, baling and shipping of recyclable materials
Recycling Regulation in BC – the legal framework that gives producers the obligation to handle and properly dispose or recycle the products that are sold within the boundaries of the province.
