Amendments to the BC Recycling Regulation announced in September 2020 included changes to the materials to be included in the Recycle BC program beginning January 1, 2023.
Producers should begin to track 2021 sales data of Single-Use Products and Packaging-Like Products (SUP/PLP) to prepare for the 2022 reporting cycle. Reports submitted in 2022 will need to include 2021 SUP/PLP sales data to inform 2023 fee rates and invoices. Recycle BC will begin collection of designated SUP/PLP in 2023.
Current definitions and examples of SUP/PLP are included in an Explanatory Note to the Regulation. PLP are typically purchased as products and are often indistinguishable from packaging when recycled. SUP items may not always be thought of as packaging but, similar to PLP, serve a single or short-term purpose (e.g. straws, stir sticks, utensils, plates, bowls and cups). Further examples are provided below.
To address the regulatory addition of SUP/PLP, stewards will need to start tracking these items in 2021. The obligated party required to report and pay fees for these additional SUP/PLP items will be determined in accordance with the “Designation of Producers” section of Appendix D in the Recycle BC Program Plan, namely either the brand owner, first importer, or franchisor.
Change in Designation of Producer for Service Packaging
Service Packaging is packaging which may or may not bear a brand that is supplied at the point of sale by retail, food-service or other service providers to facilitate the delivery of goods. Service Packaging includes all bags, boxes, and other items for the containment of goods at point of sale.
Starting with the 2022 reporting year (2021 data) the obligated party required to report and pay fees for Service Packaging will shift from the “filler” who supplies such packaging to consumers at point of sale, to either the brand owner, first importer or franchisor of the packaging that is ultimately supplied to consumers in British Columbia.
As a result, retailers, food service or other service providers may no longer be obligated to report and pay fees for Service Packaging they use to facilitate the delivery of goods at point of sale, unless they are the brand owner, first importer or franchisor of such items.
CSSA’s National Steward Services team will be reaching out to newly obligated stewards and to stewards whose obligation may have shifted as a result of this change. The planned revision to Service Packaging obligations ensure the regulatory change results in a level playing field for all designated SUP/PLP materials, Service Packaging materials and obligated producers.
The following examples of SUP/PLP are from currently available information and should not be considered exhaustive. It should also be noted that some items can be considered either SUP or PLP.
- Food bags and films purchased as a product
- Food storage, sandwich and freezer bags
- Mylar, vacuum seal, or aluminum foil lined food storage bags
- Paper lunch bags (Kraft or laminated paper)
- Aluminum foil wrap
- Plastic shrink film wrap
- Paper wrap (e.g. wax paper, parchment paper)
- Disposable food storage containers purchased as a product, i.e. containers intended for short-term use
- Non-durable plastic, paper or other food containers (e.g. hard plastic lunch containers)
- Aluminum foil pie plates and baking trays, etc.
- Household items purchased as a product
- Corrugated cardboard moving boxes, banking boxes and cardboard boxes
- Purchased gift or loot bags, boxes, etc.
- Recycling bags (i.e. bags used to collect recyclables)
- LDPE/HDPE film (e.g. used as drop sheets for painting, covering items like furniture or equipment)
- Bubble wrap
- Plastic plant pots and saucers
PLP is not intended to include durable storage containers such as glass or metal food storage containers or long-term general storage containers such as heavy-duty plastic boxes.
In addition to straws, utensils, plates and other items noted above, SUP also include “party supplies” that can be managed in the current residential recycling system, such as paper party décor, including streamers, banners, pinwheels and piñatas. Party supplies do not include items such as costume wear, balloons, ribbons or other items that would contaminate the recycling stream.
Questions and Assistance
As producers prepare to report SUP/PLP and Service Packaging in 2022, Recycle BC will provide further updates and clarifications as required. For assistance with any questions, please contact CSSA’s National Steward Services team: 1-888-980-9549 or firstname.lastname@example.org.