Extended producer responsibility (EPR) for waste or post-consumer materials has been a reality in most of Canada’s ten provinces and three territories in one form or another for decades.
However, more recently, Canada’s EPR programs are shifting from a shared financial and operational model with municipal governments to full 100% producer responsibility for both costs and operations.
Prompting the transition to EPR
While many factors have contributed to this extension of producer responsibility, the trade association representing the BPC industry, Cosmetics Alliance Canada (CAC), notes there are two that have been the most influential in prompting the transition of EPR programs in Canada.
1. Operations, volumes and costs
Firstly, the existing process’s operational and pricing challenges have played a leading role in the need to implement a better performing system.
Detailing the core challenge facing the industry, a spokesperson for CAC explains how it is impacting the change in EPR models: “Increasing operational difficulties and costs for municipal governments in operating the current system—even within a shared cost model with producers—due to increasing volumes and material complexity.”
“Decisions by China and other Asian countries to ban imported waste have also reduced options for disposal as well as eliminated sources of revenue, while domestic options for sorting and recycling have not yet been able to fill this gap,” adds the CAC.
Over the past 18 months, the impact of the Covid-19 pandemic has also contributed to the industry’s need to access alternative waste-based solutions.
“The significant number of people working from home has led to substantial increases in the curbside collection through the municipal collection systems,” states the Canadian trade association. Shifting towards curbside pickups along with a rise in e-commerce purchases and the accompanying packaging ending up in the municipal system has further increased the amount of wastage and the resources required to tackle them.
The outcome, the CAC notes is that it has “exacerbated the rising volumes and costs experienced by municipalities, which have been as high as 40% in some areas”.
2. Environmental consciousness
The second significant factor is growing public concern with environmental issues, including the management of post-consumer waste and recycling.
Increasingly, the view of consumers, municipal taxpayers, and governments, the CAC shares is that the responsibility for the increasing amount of waste, its complexity, and the lack of significant recycling of many materials such as plastics, belongs to beauty producers.
“Producers are best positioned to address these issues particularly if they are responsible for the costs,” shares the CAC.
“EPR continues to be an important policy topic in Canadian politics and in our current federal election campaign,” the trade association in Canada reveals. Uncovering how integral EPR policies are to the political landscape in Canada, the industry representatives revealed: “All the Canadian political parties have included some provisions or policies to support EPR initiatives in their platforms.”
How EPR programs are transitioning
To date, as a federal nation, the CAC notes how Canada has had the responsibility for waste management systems falling mostly in provincial jurisdiction. Therefore, EPR has been primarily managed with individual provincial and territorial jurisdictions enacting their own regulations and systems.
The Canadian Council of the Ministers of the Environment (CCME) which announced projects to promote harmonization through guidance and best practices continues to undertake a coordination effort. “This goal of harmonization has yet to be achieved as provinces continue to enact their own programs, regulations, and timeframes,” notes the CAC.
For consumer product companies, whose products are manufactured for a national or global marketplace, there is now the opportunity to achieve coordination, consistency, efficiencies of scale, and common administrative services such as the calculation and collection of fees, through a harmonized system.
Earmarked as the preferred system due to increased effectiveness and efficiency, harmonization mirrors the reality that consumer products are rarely manufactured for individual jurisdictions.
“Although the federal government does have some ability to make regulations in this area using the constitutional authority on which the Canadian Environmental Protection Act (CEPA) is based, it is limited,” shares the CAC. It was used to ban plastic microbeads in exfoliating products and is currently being used to ban six single-use plastics products. It is anticipated that CEPA will be used to further regulate the use of plastics, including introducing requirements for recycled content in containers.
Creating a circular economy
The EPR program model is designed to contribute to improving recycling initiatives and creating a circular economy in the beauty sector in Canada.
The CAC has seen how experience with global EPR programs to date has varied considerably. “Consequently, it will be crucial that the rules and regulations that are eventually implemented across Canada will incentivise the actions, behaviors, and innovations that result in the desired environmental outcomes and truly lead to the circular use of materials,” the trade association stresses.
For a number of years, environmental sustainability has been on the agenda of beauty companies’ strategies, initiatives and communications.
“Many of the latest cosmetic product innovations in Canada have been related to packaging and the recyclability of the materials used,” shares the CAC.
Moving forward, the industry will be working with Canadian regulators to ensure the development of any needed standards or guidance to support the increasing use of refillable and multi-use containers for its products.