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

Targets should also be established for reuse and refurbishment and appropriate metrics for
measurement developed.
Design for Environment
The objective of the design process is to produce a product that is least damaging to the
environment while balancing other relevant considerations, such as function, technical
requirements, quality, performance and safety.
Producers and PROs should undertake research and implement environmental design
improvements for products collected and managed by the EPR program.
Environmental design improvements could include such things as:
• Elimination and reduction of toxic substances as defined by the Canadian Environmental
Protection Act, 1999 and by Environment Canada’s Chemicals Management Plan
• The reduction in the use of substances of concern
• Design for product disassembly
• Design for product recyclability
• Use of recycled materials
• Ease of repair and refurbishment
• Reduced energy consumption during both use and stand by
Jurisdictions should consider requiring producers to report on progress towards improved
environmental design as part of their regular reporting.
Fees
Any fees associated with the program and product management should be directly linked to and
reflect actual costs associated with the program objectives and mandate.
Taxing authority is limited to Crown authorities and agencies.
Costs associated with an EPR program should be internalized as a factor of production and be
incorporated into market price of the product – i.e., the costs for end-of-life management of
products should be treated similarly to other factors of production (such as manufacturing,
distribution, marketing and sales) and incorporated into wholesale and retail product prices.
Jurisdictions may or may not choose to regulate the visibility or non-visibility of such fees at the
point of consumer purchase.
There should be no cross-subsidization of program costs between products. In the case of multiproduct
programs, “common costs” (e.g. compliance, administration, program start up) should be
allocated among products in a way that reflects each product’s share of the overall waste
generation.
Programs should be structured to ensure fees to manage products reflect the actual costs of the
end-of-life management of that product and are designed to provide incentives for improved
environmental product design and performance.
Approved in principle by CCME Council of Ministers October 29, 2009 29