Canada-Wide Action Plan for Extended Producer ... - CCME

Appendix A – Model EPR Program – Detailed Elements
The following model program elements are presented to guide the establishment of consistent
and harmonious EPR programs across the country. The model EPR program elements codify
recommended EPR program design and practice for consideration by governments and by
producer responsibility organizations. They clarify program language, identify clear roles and
responsibilities for program stewards and governments, and describe best management practices
in key policy areas. EPR stewards and regulators could take these program elements as a
common platform for EPR regulations and policies and tailor their jurisdictional program design
with regard to the direction laid out as follows:
Scope
The manufacturer or first importer who puts a designated product on the market for sale within
the jurisdiction is the identified responsible producer under the EPR program.
A producer can also be identified as a brand owner, a retailer, a franchisee or a wholesaler.
Producers of a designated product should not sell, offer for sale or otherwise distribute a
designated product unless they operate a product stewardship program either individually,
collectively or through a third party.
The responsibility should be clearly given to the individual producer or first importer (brand
owner, retailer, franchisee, wholesaler). Commonly the producer or first importer has the most
influence over the designated product and has the greatest ability to fund and operate the EPR
program and to improve the environmental design of the designated product.
Responsible producers can be named and be required to register with the responsible
jurisdictional authority.
Small producers with gross sales below a certain minimum amount could be exempted from the
scope of the EPR if it is determined that meeting the program requirements would be too onerous
or too administratively complex and expensive.
Product Definition
The product category and the specific products within the category to be subject of the EPR
program should be clearly identified.
Product category and product definitions should be provided using both commonly used
terminology and accepted industry product terminology as appropriate.
Responsibilities of Designated Producers and Producer Responsibility Organizations
(PROs)
Identified producers should be individually responsible for financing and operating a program to
collect and manage, in an environmentally sound manner in accordance with a stewardship plan,
the end-of-life products they produce or put on the market for sale.
Approved in principle by CCME Council of Ministers October 29, 2009 25