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British Columbia's Intentions Paper on Electronic Equipment

RCC appreciates the opportunity to comment on the intentions paper brought forward by the British Columbia Ministry of Environment. Retailers sell, and in many cases import every product designated for waste diversion across the country and are increasingly developing products on their own. Thus, retailers are not only sellers and first importers; they are also brand owners. They are the vital link in the distribution chain that connects manufacturers to consumers and they have a significant role to play in both the development and the implementation of product stewardship programs. Currently, RCC's members are active participants in over 30 such programs across the country and will be called upon to expand their role as new ones are developed.

We are pleased that the government has defined the concept of Extended Producer Responsibility (EPR) as "those who produce, use or sell a product". We believe that waste diversion is a shared responsibility and as such, we all have an important role to play in successful end-of-life waste management. The following represents the initial thoughts of retailers, which may be added to and/or refined as further discussion and consultation takes place.

Types of Electronic Equipment to be Included in the Schedule
The intentions paper proposes to regulate products such as computers; computer monitors; computer accessories; desktop printers; and televisions with a provision to allow the ministry to eventually widen the scope of electronics products at their discretion.

RCC and its members are pleased that a short list of products has been proposed at the introduction of the program and recommend that British Columbia's proposed electronic waste program harmonize with the Alberta program and Saskatchewan regulation respectively. Provincial harmonization with respect to products covered is a key element to ensuring program efficiency in the absence of national stewardship programs. It would also ensure simplicity for the consumer and thereby, increased compliance.

Inter-provincial harmonization of product stewardship programs is a fundamental concern for the retail sector. The need for regulation to encourage harmonization with other provinces cannot be overstated. Approaches to product stewardship across Canada are far from consistent and increasingly place national retailers in the position of having to comply with a patchwork of requirements across the country. Implementing different programs in every province has proven to be costly and administratively burdensome for retailers; and as such, harmonization must be entrenched as a foundation of product stewardship programs.

With respect to the process to include future products, we recommend that industry be given the authority to determine these decisions, with approval from the ministry, as part of their responsibility as stewards for the electronic waste program. While the government does have an important role to play with respect to monitoring success and ensuring accountability, we believe that it should be the stewardship board, once incorporated, who be given the responsibility to conduct consultations and set appropriate timetables for the introduction of new waste electronic equipment products. This allows government to benefit from the knowledge and expertise of industry, and is in keeping with the principles behind moving to an EPR stewardship model.

Timing
When deciding upon the actual start date for these programs, RCC and its members respectfully recommend that retailers be provided with adequate time for implementation. Retailers have expressed concerns in other jurisdictions with the extraordinarily quick pace that governments have allocated for the development of product stewardship programs. Retailers require ample time and opportunity to fully digest any program plan, budget for it, and take the necessary steps to prepare their respective organizations for compliance with the program. This is compounded by the fact that retailers are engaged on the development of other stewardship programs, which can leave them resource challenged as availability of personnel is finite with many working on several stewardship programs at once.

Once a program has been approved, every impacted retailer will need to be informed of their obligation, which may involve a steep learning curve for some retailers, particularly those whose only current base of operations is in the Province of British Columbia. Retailers will have to identify and catalogue all of their branded and imported products, and in many cases, implement data management systems in order to calculate and report on their obligations - not to mention hire and train employees. By providing adequate time, the ability of retailers to implement and comply with a program will increase.

Other Issues
There are certainly other issues that will need to be addressed once a stewardship program for electronic equipment waste is developed and implemented. First and foremost is representation of the retail sector in the decision-making bodies. Retailers have a significant stake in the development of effective stewardship regulations. As noted above, in addition to being sellers and importers of designated products, some of RCC's members are also product brand-owners 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.

Other issues of concern to retailers include, but are not limited to, the following:

• Financing;
• Collection;
• Program Targets;
• Promotion and Education;
• Enforcement and Compliance;
• Dealing with historic and orphan products.