Call2Recycle Positioning Letter to its Industry Stewards

June 11, 2013

Dear Call2Recycle® Program Supporters,

You may have recently heard about the new proposed waste reduction framework, Waste Reduction Act, which was introduced in the Ontario Legislature on Thursday, June 6. We are writing to share Call2Recycle’s position on the Act and what this means to the Call2Recycle program in Canada.

Call2Recycle enjoys the support of battery stewards, retailers, municipalities, including Ontario-based suppliers, and in other jurisdictions across North America. If passed, this new legislation will impact extended producer responsibility (EPR) and individual collection and recycling programs, like Call2Recycle; however, we believe the Act will only allow us to build on our successful track record as an established, nationally-recognized consumer brand.

As written, the new Waste Reduction Act will impact Call2Recycle, its industry stewards, and program participants in the following manner:

  • Recycling Requirements: individual producers will be responsible for waste reduction outcomes set by the government, including waste reduction standards, service standards, and requirements for promoting public awareness for designated wastes. Similarly to other provinces in which Call2Recycle serves as the preferred battery stewardship program, like British Columbia and Québec, Call2Recycle will consult with the government on setting achievable and clear standards, and implementing collection and strategies to support such.
  • Individual Producer Responsibility: the Act will let producers decide how to meet their recycling requirements, whether individually or through a product stewardship program, like Call2Recycle. Since Call2Recycle has not been formally sanctioned as the battery stewardship program in Ontario, we are pleased the proposed legislation will allow a more-level playing field within the province.
  • Visible Fees: the Act would require diversion costs to be part of the product price – an all-in pricing structure, removing any eco-fees at point of sale. This requirement will not affect our program.
  • Increase Support for Municipal Recycling: a compensation system will be introduced for instances where a municipality collects a designated waste. Call2Recycle relies heavily on municipalities to assist in the collection of batteries across North America and recognizes the need for a fair compensation structure. While we remain generally supportive of this approach, we are mindful that it could potentially impact our program costs.
  • Strong Oversight & Compliance Authority: Waste Diversion Ontario (WDO) will be transformed into a new body, the Waste Reduction Authority (WRA), who will provide an independent, robust oversight and compliance framework of producer responsibilities. Call2Recycle is confident that this new reporting body will provide more clarity to requirements; however, it is likely that if not calculated correctly, diversion rate enforcement and performance penalties could affect the program. Based on our provincial experiences, we will provide target guidance to WRA to minimize any program interruptions or imposed penalties.

The proposed framework is open for a 90-day consultation period through September 4, 2013. To ensure continued success for the Call2Recycle program, its industry stewards, and program participants, we encourage you to submit your comments to the government, supporting both EPR and the ability for your company to have a choice in which program it will use to meet its recycling requirements. You may submit comments electronically or via postal mail, details can be found on the Government of Ontario’s website.

Our goal has been, and will continue to be, to run a successful battery collection program in Ontario on behalf of all stakeholders. While we don’t expect a ruling on the Act until Fall, we will follow this closely and will keep you abreast of legislative updates and continue to guide you through any requirements that may affect the program. To read more about the proposed Act, please visit call2recycle.ca/ontario or ontario.ca/wastereduction.

Thank you for your continued support of Call2Recycle.

Sincerely,

Joe Zenobio
Executive Director
Call2Recycle Canada, Inc.

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