ILSR has reviewed three recent documents that clarify the profound differences between contending approaches to the theory, practice and evaluation of the Extended Producer Responsibility (EPR). These are:

  • British Columbia Bottle and Depot Association (BCBDA), “Re Encorp Pacific Canada Container Stewardship Plan – Draft 2020-2024”
  • Zero Waste Canada, “Comment: EPR for Packaging and Paper Products Practices, Policies and Performance”, 14 September 2020, commissioned by the Institute for Local Self-Reliance
  • The Product Stewardship Institute, ”Extended Producer Responsibility (EPR) for Packaging and Paper Products (PPP): Policies, Practices and Performance, March 2020 (amended September 2020).

British Columbia Bottle Deposit and Recycling Association (BCBDRA) to the BC Ministry of Environment, September 15, 2020

At the same time as the Zero Waste Canada assessment was completed, the BCBDRA published its letter to the Ministry of Environment expressing their concerns about EPR practices and future plans of Encorp, the steward of the BC EPR system.

The letter is respectful of government intentions but questions the thoroughness with which the government has considered the environmental, and ecological impacts of the EPR Encorp system. Among the these impacts are a stagnant recovery rate for beverage containers, no added encouragement for producers to redesign, lack of transparency about the use of consumer funds — such as using those funds to outcompete and replace small businesses — and achieving little or no additional environmental benefits.

Effectiveness of British Columbia Bottle Returns as Compared to other Jurisdictions

Extended Producer Responsibility in Europe starts with beverage container legislation and requires ever-increasing quotas of refillable containers to be available in the marketplace and provides incentives to businesses to attain goals. In British Columbia Extended Producer Responsibility undermines container deposits.

Oregon  91%

Norway  90%

Saskatchewan  88%

Alberta  85%

Nova Scotia  81%

British Columbia 78%

Further, the Encorp system has the power to put small entrepreneurs out of business with six months notice (without consultation or negotiation), which devalues 50 years of small businesses’ investments and eliminates green jobs and community services.

The letter goes on to explain a number of problems with the 2020-24 plan by Encorp, including that it:

•Emphasizes producers’ license to achieve the lowest cost-recovery system possible and, in doing so, dismantles 50 years of Depots’ small business capital, infrastructure, and community investments, green jobs, services to the marginalized, and frontline community services and education by threatening to replace us (without fair compensation) with Encorp-owned facilities.

•Downloads costs to consumers and small businesses

•Evades its primary responsibility of increasing collection and recycling rates across all its beverage container streams (even when other jurisdictions have long since surpassed Encorp’s proposed 5-year results)

•Sets an objective for a positive customer experience, while at the same time, setting up BC’s frontline service providers to fail to achieve this objective. It also devalues 50 years of Depots’ business and community relationships

To read the full story, visit https://ilsr.org/critiques-of-different-approaches-to-extended-producer-responsibility-in-canada/.
Author: Neil Seldman, Institute for Local Self-Reliance
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Institute for Local Self-Reliance

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