Adding a Schedule for Tires to the Recycling Regulation
November 15, 2005
British Columbia's Intentions Paper on Tires
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.
Retailers support the principles of waste diversion as a whole. In August 2003, RCC worked with The Rubber Association of Canada and the Western Canada Tire Dealers Association to establish Tire Stewardship British Columbia (TSBC). TSBC is an industry not-for-profit organization created for the purpose of accepting the transfer of the Financial Incentives for Recycling Scrap Tires (FIRST) program to industry stewardship and to thereafter manage the scrap tire diversion program in the province.
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.
Definition of Producer
As noted above, retailers are increasingly not only sellers and first importers; they are also brand owners and producers themselves. It is our understanding that the Ministry of Environment is willing to explore ways that may place the responsibility for regulatory compliance at the retail level through a framework yet to be determined, and we look forward to actively participating in those discussions in order to ensure the most effective and efficient tire stewardship program.
Consultations
The recycling regulation contains a requirement for public consultations, and the intentions paper refers instead to stakeholder consultations. Given that the proposed model is effectively a transfer of an existing retail-based program, we respectfully recommend that the public consultations be included as part of an educational campaign post-implementation in order to ease administrative costs and accelerate the implementation timeframe. Stakeholders directly affected by the program, that is, processors, haulers, retailers and so on, should be consulted beforehand.
Types of Tires Included in the Schedule
The intentions paper proposes to regulate those types of tires that are currently being recycled under the existing FIRST program, with a provision to allow the ministry to eventually widen the scope of tire products at their discretion. With respect to both the current list of tires covered and 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 tire 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 who be given the responsibility to conduct consultations and set appropriate timetables for the introduction of new waste tire products. This allows government to benefit from the input, 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. Given that this is a transfer of a pre-existing program, we feel that a mid to late 2006 timeframe to have a program fully operational is reasonable, providing the few outstanding issues referenced above are addressed. RCC is committed to working with our industry partners through TSBC and other affected stakeholders towards a timely and orderly transfer.