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

Fees should be linked to material and product-specific costs, adjusted regularly to reflect actual
costs and shifted to poorer-performing materials and products to achieve program objectives.
Producers operating individual producer responsibility programs should have incentives to
reduce costs and should structure their programs to encourage waste reduction and improved
product environmental performance.
PROs should structure their program management and use differential internalized fees to
encourage waste reduction and improved product environmental performance by adjusting
internal fees/levies/costs to reflect such things as reduced special handling of toxic materials,
disassembly efficiencies and changes in the values of recyclable material.
No fees or service charges should be levied at drop off depots or other places where consumers
are requested to return end-of-life products.
Fees should be designed to provide a financial incentive to:
1) increase product recovery rates
2) avoid penalizing producers for success in achieving high recovery rates
3) select products with low recycling costs
Funds should be raised for promotion and education, research and development and for capital or
new infrastructure to divert materials.
Historic and orphan products
Historic products that were put onto the market prior to the implementation of the EPR program
and orphan products that were put on the market by producers no longer in business at the time
of the program implementation should be received and managed by the producer or the PRO if
delivered to the program regardless of their provenance.
Costs for managing historic and orphan products delivered to a collectively operated EPR
program should be borne collectively by the members of the PRO based on either a return share
or a current market share calculation.
Auditing
Programs should be audited for financial performance and required to publicly file an annual
audited financial statement.
Programs should be required to conduct independent third-party audits each year to ensure
compliance with relevant regulations and with the environmental objectives of the program.
Environmental compliance audits should be conducted to ensure compliance with environmental
and occupational health and safety and any other applicable legislation and regulations.
Environmental conformance audits should be conducted to ensure conformity with the program
mandate and objectives and to ensure the EPR program conforms to specific criteria, such as an
identified ISO or other standard.
Approved in principle by CCME Council of Ministers October 29, 2009 30