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

Environmental audits should review and report on end-of-life market chains to ensure
compliance with program and stewardship plan objectives.
Audit procedures should be established, implemented and maintained to address responsibilities
for planning and conducting audits, reporting results and retaining records, and for determining
audit criteria, scope, frequency and methods.
Audit results should be made available to the jurisdictional authority and to the public.
Audits should review urban/rural service equity and effectiveness.
Offences and Enforcement
Contravention of regulations governing EPR programs will be addressed as provided for under
the governing legislation.
If a producer or obligated steward sells a designated product into a jurisdiction’s market without
fulfilling the obligation to prepare or be part of a stewardship plan or fails to operate or be part of
a product stewardship plan, efforts will first be made to bring the producer into compliance.
Enforcement could result in the producer or obligated steward being prohibited from selling the
designated product in the jurisdiction.
In the face of a failure to meet stewardship plan obligations and established targets, jurisdictional
authorities can specify remedial action by a producer or PRO in areas such as product collection.
Jurisdictional authorities should act to enforce the level playing field provisions of EPR
regulations and product stewardship plans and ensure that “free riders” who could damage
program integrity are brought into the EPR program or prosecuted.
Plan Review
Stewardship plans should be reviewed and revised on a regular basis and at least every five
years.
Producers and PROs should adopt continuous improvement strategies to ensure continued
enhancement of program performance.
End-of-life Management
Recycling and other end-of-life management processes should be conducted in accordance with
the appropriate environmental regulations and recognized environmentally sound management
standard or guidance document.
Producers and PROs should be required to report on the ultimate disposition of materials
recovered by the EPR program and programs must include mechanisms to track the ultimate endof-life
disposition of products, and show that they are managed in an environmentally sound
manner.
Approved in principle by CCME Council of Ministers October 29, 2009 31