Attention: Trade Associations Executives, Government Relations, Regulatory Affairs & Policy
Tuesday, October 2, 2012
As you may be aware, the Government of British Columbia has taken steps to transition responsibility for managing end-of-life products from government and taxpayers to industry and its consumers. Under this approach of Extended Producer Responsibility (EPR), producers assume responsibility for the collection and diversion of their products and packaging at end of life. British Columbia amended its Recycling Regulation in 2011 to include Packaging and Printed Paper (PPP). Under this regulation, businesses (producers) that sell products into the B.C. residential marketplace containing PPP are required to either file with the B.C. Ministry of the Environment an individual stewardship program plan for their company or join a collective stewardship organization that will file a plan on their behalf. The deadline for filing a stewardship plan is November 19, 2012.
This communique provides the necessary background information, current status and suggested next steps for you to share with your association members so that they can make an informed decision on how they wish to proceed in order to comply with the B.C. Recycling Regulation. We are encouraging you to share this information with your members along with the attached Letter of Intent that allows them to appoint Multi-Material British Columbia (MMBC) as the stewardship organization that is working to discharge stewardship obligations on behalf of PPP producers in B.C.
In July 2004, British Columbia enacted the Environmental Management Act and in October 2004, the Recycling Regulation. The Recycling Regulation was then amended in May 2011 to include the Packaging and Printed Paper category. This regulation continues the shift by the government toward Extended Producer Responsibility requiring product producers to take end-of-life responsibility for the products and packaging they produce. This regulation represents the first 100% industry-led EPR scheme for PPP in Canada meaning producers are responsible for the cost to provide reasonable access to PPP collection and recycling services across the province. In accordance with the Regulation, producers of PPP must prepare a Stewardship Program Plan, consult with stakeholders and submit the Plan to the Ministry by November 19th 2012. The Program Plan must be implemented by May 2014 and be capable of achieving a 75% diversion rate for PPP within a reasonable time frame.
Multi-Material British Columbia (MMBC) is a not-for-profit agency established under the British Columbia Society Act. The agency was formed in anticipation of the government adding PPP as a new product category under its Recycling Regulation and its intent is to discharge the obligations of PPP producers (brand owners and first sellers) as a collective. The MMBC board currently comprises directors from the following organizations: Retail Council of Canada, Food and Consumer Products of Canada, Canadian Federation of Independent Grocers, Canadian Restaurant & Food Services Association, Loblaw Companies Limited, Overwaitea Food Group, Tim Hortons and McCain Foods.
Since 2011, MMBC has been working to develop a Stewardship Program Plan which will enable it to assume the role of stewardship agency capable of discharging producers’ obligations under the Recycling Regulation. In late 2011, MMBC commissioned a comprehensive review of the current B.C. recycling system including who is doing what – local governments, not-for-profit and private sector recyclers – and system performance. The Current System for Managing Residential Packaging and Printed Paper in British Columbia can be viewed here. MMBC also commissioned an assessment of optional program designs including system requirements and financial transactions with service providers. The Packaging and Printed Paper Stewardship Program Design Options can be viewed here.
MMBC is currently developing a PPP Stewardship Program Plan that: meets the requirements of the B.C. regulation, follows EPR principles, is cost effective and efficient, and where possible, achieves harmonization with existing provincial stewardship programs across Canada. MMBC’s Stewardship Plan will be available for comment during the week of October 22nd and will be followed by a consultation workshop with simultaneous webcast on October 29th (details to follow). Subject to approval of the Plan by the Director, MMBC will prepare to implement the program in May 2014.
The Recycling Regulation provides businesses (producers) with the option of appointing an agency to carry out the duties as listed above. If your members choose to appoint MMBC as their agent to fulfil their obligations under the B.C. regulation they must sign and return the Letter of Intent to MMBC no later than Monday November 5th. If a letter of intent is not received we will assume they intend to file their own Stewardship Plan.
MMBC is creating a new website that will be live soon. Watch for an announcement later this week or early next week. For more information or if you have any questions please e-mail us at firstname.lastname@example.org.
Please note that we will be sending a letter similar to this with the Letter of Intent directly to your members (producers) by Friday, October 5th.
Thank you in advance for sharing this important information with your members.
Chair, Mulit-Material British Columbia