Extended Producer Responsibility

The RCA believes Extended Producer Responsibility is key to advancing a circular economy.

Extended producer responsibility (EPR) is an environmental/economic policy approach in which producers of products and packaging bear responsibility for ensuring those products and packages are properly managed at the end of their life cycle (OWMA, 2013)[1].

Packaging and paper products (PPP) include all packaging and paper materials designated by provincial regulation as PPP. This may include both PPP generated by the residential and the business sectors (e.g., primary packaging, transport packaging, printed and non-printed paper).

The current list of designated materials varies nationally; producers recommend working towards a harmonized national list of materials. Some jurisdictions have or are considering expanding this category to include packaging-like products (e.g., tin pie plates that may be sold as a package or a product) and single-use products (e.g., disposable cutlery), which often end up in the recycling stream.

The RCA has developed a set of key principles that an EPR framework should have:

  1. Drive a circular economy
  2. Be outcomes-based
  3. Have performance standards that are ambitious, measurable and enforceable
  4. Ensure a level playing field
  5. Be implemented alongside complementary regulations

Alberta EPR Update

October 2022

The Recycling Council of Alberta is excited to announce that the newly passed Extended Producer Responsibility (EPR) regulations go into effect on November 30, 2022.

One of the aims of EPR is to give producers an incentive to change product design for reuse as well as make it easier to recycle packaging and shift the responsibility to product manufacturers to recycle their own packaging and divert it from disposal.
 
Alberta will have two EPR systems: single-use products and packaging as well as printed paper and hazardous and special products.
 
Oversight of Alberta’s new EPR systems will be conducted by the Alberta Recycling Management Authority (ARMA), which has managed regulated recycling programs for used oil, paint, tires and electronics in Alberta for more than 30 years.

April 2022

The Alberta government is in the process of developing EPR regulations for Packaging and Paper Products (PPP) and Household Hazardous Waste (HHW). These regulations are anticipated to be introduced by June of this year. Implementation of the system will follow to result in an EPR system for these materials in Alberta.

RCA Releases Response to ECCC’s Plastic Registry and Labelling

On October 7, 2022, the RCA submitted a letter to Environment and Climate Change Canada (ECCC) in response to its proposal to establish a Plastics Registry and regulate plastics labelling for recyclability and compostability.  

The RCA supports the ECCC in its efforts to establish a registry to improve Canada-wide data transparency and consistent and accurate product labelling to restore consumer confidence in the performance of recycling systems.

Some of the feedback RCA provided included how ECCC has defined ‘recyclable’ and ‘end markets’ is problematic in that it’s the same way the industry is defining currently defining them. The definition should be the point at which a recycled raw material needs no further processing to be reincorporated into a new product or package.

RCA ECCC Response -Registry and Labelling

RCA Releases Response to AEP’s EPR Consultation

January 2022: The RCA has developed a response to AEP’s request for input on EPR regulations for packaging, paper products and single-use plastics (PPP-SUP) and hazardous and special products (HSP).

2022-RCA_Submission – PDF DocumentDownload 2022-RCA_SubmissionAddendum – PDF DocumentDownload

We invite our members to provide comments regarding this input. We are also pleased to discuss the submission details either by phone or email. Just reach out to info@recycle.ab.ca or phone 403.843.6563.

A Major Milestone: Alberta Introduces EPR Legislation

On November 15, 2021, Alberta took an important and exciting step forward for Extended Producer Responsibility (EPR) in our province by introducing Bill 83 to enable the creation and implementation of an EPR framework in 2022. An EPR framework would create provincial systems for managing single-use plastics, packaging, paper products and hazardous and special products like household pesticides and solvents.

After years of advocating and creating awareness about this critical policy tool, the RCA is thrilled about this important step. EPR is a key mechanism for building a Circular Economy and captures the private sector’s ability to innovate, resulting in better products and systems, and better environmental performance.

Bill 83, the Environmental Protection and Enhancement Amendment Act officially came into force on December 2, 2021.

AEP Hosts EPR Consultation & Publishes What We Heard Report

In spring 2021, AEP gathered input focused on the design of an Extended Producer Responsibility (EPR) approach to single-use plastics, packaging and paper products, and hazardous and special products (which include household hazardous waste). Stakeholders are now invited to review the “What we heard” summary and provide feedback by Jan. 14, 2022.

RCA Responds to AEP’s EPR Discussion Paper

On March 18, 2021, Alberta Environment and Parks (AEP) released a discussion paper on advancing extended producer responsibility (EPR) policy in the province. The paper focuses on the creation of an overarching EPR regulatory framework for packaging and paper products (PPP), single-use plastics, and hazardous and special products (HSP). The RCA’s response to the discussion paper can be viewed here.

RCA held an EPR webinar series. Webinars took place on March 30, April 13, April 20 and a special member-only Q&A webinar on April 26 about the discussion paper.

Alberta’s Existing Recycling Model vs. An EPR Model

Definition of Recycling — The process of reducing a product all the way back to its basic materials, reprocessing those materials, and using them to make new products, components or materials.

Four Parts of a Recycling System

  1. Collect: Which materials / how they are collected.
  2. Sort: Material is separated and grouped.
  3. Process: Materials are re-processed into manufacturing feedstock.
  4. Make: Feedstock used to manufacture a new good.

Recycling  = all four are complete.

Existing Model – Scope of influence is to manage disposed material

In our current model, producers have no incentive to:

  • use recycled content
  • communicate with other system players
  • keep materials at a high value
  • rethink design (e.g., longevity, recyclability, repair, reuse)

…because both costs and consequences borne by program operators / consumers / taxpayers.

Transition to EPR – scope of influence is cradle to cradle

EPR shifts decision making to producers. Producers have the obligation and authority to coordinate and operate recycling systems that keep materials in use. 

In an EPR model, producers have incentive to:

  • rethink design –recyclability, dematerialize
  • increase product lifespan –repair, reuse
  • invest in new recycling system processes and technologies
  • use recycled content

… because both costs and consequences borne by producers.

Recent News

March 18, 2021 – Alberta Environment and Parks (AEP) has released its discussion paper on advancing extended producer responsibility (EPR) policy in the province. The paper focuses on the creation of an overarching EPR regulatory framework for packaging and paper products (PPP), single-use plastics, and hazardous and special products (HSP). AEP invites stakeholders to review the discussion paper and respond to questions through the online portal or by email to AEP.RecyclingRegulation@gov.ab.ca *AEP has extended the deadline to May 17. AEP will also commence discussions with associations and sector table groups, but will have limited availability for one-on-one meetings. As part of the engagement, AEP has also released a survey for the general public.

December 12 – Alberta Announces Plans to Advance EPR Consultation in Early 2021 – Alberta Environment and Parks (AEP) and Alberta Energy (AE) shared plans on December 7 to undertake an ambitious consultation process on Extended Producer Responsibility (EPR). The announcement was made to the provincial stakeholder group, the Plastics Alliance of Alberta (PAA), co-chaired by the Recycling Council of Alberta (RCA) and the Northern Alberta Institute of Technology (NAIT) and attended by members across the plastics value chain. More details

October 26 – Exciting news on the EPR file in Alberta! A motion was tabled and passed unanimously on October 26 with support from the government and opposition: Be it resolved that the Legislative Assembly urge the Government to examine the feasibility of implementing measures such as extended producer responsibility that balance the environmental and economic needs of Albertans. https://docs.assembly.ab.ca/LADDAR_files/docs/houserecords/vp/legislature_30/session_2/20201026_1200_01_vp.pdf

September 15 – EPR done right means capitalizing on unfinished business that benefits all – An article by RCA President, Jodi Tomchyshyn London and Lisa Grotkowski
Extended Producer Responsibility (EPR) is a mouthful. It’s an industry term often expressed as producers paying the full cost to collect and recycle the products they sell into the marketplace. The benefits of EPR are often trumpeted as reducing the burden on municipalities and, thereby their taxpayers, to collect and find markets for these products once they become waste. When we talk about EPR this way, we’re reducing it to a public sector or taxpayer issue. We’re also missing the point – at its core, EPR is simply unfinished business that, when managed by businesses, benefits all of us. Follow here for the full article.

The RCA continues to be engaged and supportive of advancing EPR in the province and will share news and resources when we hear about next steps.

Reports/Resources

The RCA held webinars on EPR on October 22 and January 26. Visit the event pages for presentation summaries or tune into our podcasts for the recordings from key experts.

A number of recent reports have contributed to the advancement and awareness of EPR in Alberta.

  • The the Alberta Collaborative Extended Producer Responsibility (ACES) Group has produced an EPR backgrounder. Complete with an overview of: what EPR is; how it will support Alberta’s Natural Gas Vision and Strategy for a circular economy for plastics; environmental and economic outcomes for municipalities, the recycling sector, small businesses and consumers!
  • In December 2020 representatives from the ACES Group presented on EPR to the UCP Caucus. Their presentation on EPR and what it could mean for Alberta is available here.
  • Usman Valiante, a senior policy analyst with Cardwell Grove Inc., has provided this response letter addressing statements, comments and recommendations in a review of the Environmental Law Center (Alberta) Society’s report released earlier in 2020 titled Extended Producer Responsibility: Designing the Regulatory Framework. Usman also provides policy design considerations for Alberta’s advancement of EPR for PPP. 
  • The Extended Producer Responsibility for Residential Packaging and Paper Products: Alberta Collaborative Extended Producer Responsibility Study released in March 2020 shows a compelling vision for extended producer responsibility (EPR) for residential packaging and paper products (PPP) with a made-in-Alberta solution. The Recycling Council of Alberta participated with ACES, including municipal and producer representatives, to provide guidance and oversight on the report. For the full announcement visit: https://auma.ca/news/news-release-new-study-makes-strong-case-packaging-and-paper-extended-producer-responsibility-albertaFor the full report visit: https://recycle.ab.ca/wp-content/uploads/2020/03/ACES-Summary-Report-Final-For-release-March-10-2020.pdf

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[1] OWMA, 2013. Extended Producer Responsibility Policy Paper. Available at: https://www.owma.org/articles/extended-producer-responsibility-policy-paper Retrieved August 18, 2020.