Learning ExCHANGE

Extended Producer Responsibility (EPR), once called manufacture take-back, was developed in Europe in 2000 as an environmental policy to reduce challenges for municipalities managing growing quantities of waste. The program extends the responsibility for managing consumer products at end-of-life to the producers who make the products. BC has about 20 EPR programs in place. Oversight is provided by the BC Ministry of Environment and Climate Change Strategy.

 

 

How does EPR work?

​

Extended Producer Responsibility programs are funded by consumers. When a consumer buys a product, an eco-fee is charged at point of purchase. These fees are collected by producers and used to cover costs for end-of-life collection, transport, and recycling or other management of the product according to the pollution prevention hierarchy. That is why recycling depot drop-off of these products has to be free: the consumer has paid the cost up front.

 

The economic rationale behind EPR programs is to have producers internalize end-of-life costs so they have incentive to design products that are easily managed after use. This is polluter pay theory that incentivizes good (reusable, recyclable) design, and dis-incentivizes poor (non-reusable, costly to recycle, non-recyclable) design. Good design costs less to manage at end of life. Bad design costs more to manage at end of life, to the extent that prohibitive management costs should cause elimination of that product.

 

The theory should work.

 

Achieving polluter pay depends on the True Cost Principle, meaning that the eco-fee paid reflects as faithfully as possible all true costs for end-of-life management at the highest level of the pollution prevention hierarchy. Fees would be high for products with bad design and low for the products with good design. Polluters (producers and consumers) would make choices based on this “bonus-malus” system of eco-fees: if costs are too high, consumers would limit or stop purchasing that product, and producers would eliminate or re-design the costly product. The result should be a marketplace reduction in products that cause pollution.

 

There are no such fee schedules in EPR.

 

There is no recommendation, approval process, or reporting criteria that includes a bonus-malus fee system in Canada. EPR is industry led, and industry has designed the fee system based on minimal costs of management for recycling, or recovery, or disposal, with no funds made available to increase reusability, repairability, or waste prevention. The fee schedules are not structured to encourage producers to design recyclable, reusable products or eliminate products that can’t be managed by the 3R’s. Truth is, EPR programs have reduced eco-fees over the years.

 

If the True Cost Principle were applied to eco-fees, consumers would have the choice to reject and refuse the purchase based on real costs to recycle, or reuse, or repair.

​

​

​

​

​

​

​

Within EPR, management of products is governed by a chosen or defined pollution prevention hierarchy. Efforts to manage waste at each level are meant to be exhausted before managing waste at a lower level. There are a number of hierarchies to choose from: at the federal and provincial level, Canada has adopted a hierarchy of Reduce, Reuse, Recycle, Recover, Landfill. In BC, the EPR hierarchy is somewhat modified. In order of preference, the BC EPR hierarchy has seven levels.

1. Reduce the environmental impact of producing the product by eliminating toxic components and increasing energy and resource efficiency,

2. Redesign the product to improve reusability or recyclability,

3. Eliminate or reduce the generation of unused portions of a product that is consumable,

4. Reuse the product,

5. Recycle the product,

6. Recover material or energy from the product, and

7. Otherwise dispose of the waste from the product in compliance with the Act.

 

EPR annual report criteria must include

• efforts taken by or on behalf of the producer to reduce environmental impacts throughout the product life cycle and to increase reusability at the end of the life-cycle

• a description of how the collected product was managed in accordance with the pollution prevention hierarchy

Note: This report uses excerpts from BC Recycling Regulation. NRES recommends becoming familiar with the Recycling Regulation found at the Ministry of Environment and Climate Change website.

 

 

Is EPR successful?

​

EPR as a concept is progressive and should bring success.

 

In BC, collection systems are largely successful. There are well-established recycling channels that manage a good portion of products at end of life. What happens to those products that can’t be reused or recycled? What happens to the products that are only partially recylcable in BC? Can we account for what happens to the remainder?

 

Are producers really responsible for taking back their waste? 

 

Do we expect too much from EPR?