April 12, 2006
Consultation Process
RCC is concerned about the level of consultation that has taken place with industry on ARMA's proposal to eliminate the remittance certificate process for Alberta's electronic waste recycling program.
RCC received a copy of the proposed changes one week before the deadline for comments were due; this is not a sufficient amount of time to provide feedback. In the future, RCC respectfully requests a minimum of at least two weeks to provide feedback. Further, when considering significant changes to any of Alberta's recycling programs, there should be an industry consultation to allow stakeholders the opportunity to meet and openly discuss and understand the impacts of the proposed changes. RCC believes this would result in a more transparent and effective process that would benefit and strengthen Alberta's stewardship programs.
Furthermore, it is our understanding that ARMA's proposed changes to the remittance certificate process were not presented to the Electronics Recycling Alberta Industry Council (ERAIC) for review and comment. ERAIC has a vital role to play in providing ongoing input to Alberta's electronics recycling program, and to ensure that the interests of stakeholders are adequately represented; however, the Industry Council is unable to fulfill its commitment if they are not being consulted. In the future, ERAIC should have the opportunity to review and provide input on program changes before they are sent to registered suppliers for feedback.
Retailers have a significant stake in the development of effective stewardship regulations. In addition to being sellers of designated products, RCC's members are increasingly product brand-owners themselves and are responsible for the end-of-life management of those products and packaging. Given the major role that retailers play in product stewardship, retail must be represented in the decision-making bodies. Currently, RCC is represented on many stewardship boards across the country including Stewardship Ontario, Waste Diversion Ontario, Product Care Association, Tire Stewardship British Columbia and the Saskatchewan Scrap Tire Board, among others.
It is imperative that RCC work more closely with ARMA and respectfully requests a retail seat on ARMA's Board of Directors and/or an observer seat for RCC as well. Currently, the retail industry is not explicitly represented on ARMA's existing Board of Directors; previously, a retailer has held the "industry-at-large" seat. Furthermore, RCC requests an additional seat on the Electronics Recycling Alberta Industry Council to provide ongoing input.