CESA Response to Saskatchewan Solid Waste Management Strategy

About Canadian Electrical Stewardship Association

The Canadian Electrical Stewardship Association (CESA) is a federally-incorporated, not-for-profit organization that is led by the very industry whose products are stipulated in the ever-expanding EPR regulations around electrical equipment in Canada. Members of the small household appliance industry came together in 2011 when the BC Ministry of Environment expanded regulations to include small household electrical appliances and then in 2012, added power-tools, exercise equipment and crafting machines.

CESA was incorporated as a national entity with the foresight and understanding that our membership consists of large multi-national and national manufacturers and retailers of small appliances and power tools who are seeking a harmonized and national strategy to managing their EPR obligations. As regulations expand across Canada, it is the desire of CESA’s membership to reduce costs, achieve economies of scale and most importantly harmonize wherever possible with existing programs. It is imperative to CESA’s members that as manufacturers and retailers of products that have a dramatically different life-cycle than electronics, that a unique and stand-alone program be allowed.

CESA currently provides residents of BC easy access to recycle more than 400 products across the province at depots, municipal transfer sites, regular and convenient round-up collection events and participating retailers. The Environmental Handling Fees (EHFs) are collected at point-of-sale, and CESA’s members report and remit on a monthly basis. The EHFs cover collection, transportation and recycling of electrical products, as well as marketing efforts to ensure British Columbians are aware of an environmentally-responsible and convenient way of disposing of their old electrical small appliances and tools.

CESA has produced audited financial statements and annual reports since 2011. The latest reports and financial statements (2013-2016) can be found on our website: https://www.electrorecycle.ca/stewards/resources/

CESA’s Mandate

To assist manufacturers, brand owners and other legally obligated parties in discharging their obligation to provide end-of-life recycling solutions under applicable provincial extended producer responsibility (EPR) legislation.

Introduction

The Canadian Electrical Stewardship Association (CESA) is pleased to respond to the Saskatchewan Solid Waste Management Strategy. Since 2011, CESA has worked with the Government of British Columbia, industry, municipalities, not-for-profits and the public to divert small appliances and power tools away from British Columbia landfills. In that time, we have raised the awareness of our small appliance diversion program from zero to 79.3%. Tens of thousands of tons of small appliances have been diverted away from BC landfills.

We bring that experience to the table with an eye to helping the Saskatchewan government move closer to its stated goal of being a national leader in responsible waste management. We contend that to get close to that goal, each waste stream will require a dedicated strategy, an engaged industry association and motivated stakeholders.

The Future of Solid Waste Management in Saskatchewan

The strategy has the potential to impact the members of CESA, directly through legal obligations for product stewardship, but indirectly through increased costs of doing business in the province. Knowing the regulatory environment and the timing with which any new regulatory requirements will be introduced, keeps industry and its stakeholders informed. Being informed is critical to long-term success, of the businesses as well as the regulated programs.

CESA is impressed by the government’s realization that action plans will require both flexibility and a gradual implementation schedule. CESA wants to remind the Ministry that new EPR programs take time to develop and implement. CESA’s members would strongly encourage the Ministry of Environment to take ample time in collecting and reviewing feedback on a draft regulation, in addition to the draft strategy. It is within the minutiae of the regulation that industry will have the greatest value and input. As the operators of and those financially responsible for stewardship programs, industry can properly and accurately advise as to feasibility of execution and potential snags and snares, only once a draft regulation is shared for consultation purposes.

Strategic Priority #1: Landfill Management

CESA has limited commentary to provide on how the province manages its current slate of landfills, including those proposed to be built and those targeted for closure. However, it is important to note that any good stewardship program should include a phased-in landfill ban of any EPR regulated products from any private or municipal landfill. Landfill bans should be seen as a complimentary policy consideration to work alongside expanded EPR programs, waste diversion targets and public campaigns.

Strategic Priority #2: Waste Stewardship and Recycling

  1. CESA commends the government of Saskatchewan for recognizing the opportunity for improvement in the development and execution of product stewardship in the province. Saskatchewan currently diverts approximately 13% of its waste from landfill. Expanding extended producer responsibility regulations to new product categories has the potential to increase the diversion rates significantly. Appropriate data collection in advance of any EPR legislation, will be critical to determine the success of the program against individual product category diversion rates.
  2. There should be no mandated targets set forth in the regulations, nor required within the stewardship plans. There are many challenges with setting targets as it relates to small appliances. First and most importantly, there are hundreds of products that are by their nature small and lightweight and the cost of counting units recycled is cost prohibitive. However, the data collected from the obligated stewards is measured in units sold into the marketplace. Therefore the two measurements will never be the same, as one is units, the other is weight. Therefore a recovery rate or recovery target is unrealistic for this product category. Second, following a global trend in the marketplace, small appliances manufacturers continue to design products that are better for the environment – oftentimes leading to light weighting of products. Therefore, any target would need to account for a decrease in product weight and composition changes over time, to provide a true measure of any increased diversion.
  3. If small appliances are designated under an EPR framework in Saskatchewan, CESA would suggest that the government look at the BC program with great interest. This program has been operational since 2011, and has been very successful in increasing diversion of program products from landfill. Small appliances, microwave ovens and power tools are a logical combination of products to place within one category. However, it is worth noting that the program was implemented in two phases, not a recommended approach in the future, unless those phases are spread apart by several years. Furthermore, some categories of the expanded program, “designated very small” as an example, present a significant challenge on consumer awareness around recycling and in many cases, the cost to educate far exceeds the environmental benefits.It is CESA’s recommendation to exclude designated very small items, as well as bulky items such as fitness equipment and floor-standing tools from the program. The former are difficult to collect while the latter have long life-cycles, an excellent re-use factor and when finally are at end-of-life, garner significant value through scrap metal dealers. Therefore an existing marketplace solution is in place for large bulky items.
  4. EPR is an accepted model of waste management and recycling across most jurisdictions in Canada, and is supported by the Canadian Council of Ministers of the Environment as the go-to policy option for waste management in Canada. As the government considers what, if any, new materials might be designed under stewardship programs, CESA strongly encourages the collection of data to support the introduction of any new EPR programs. Specifically, by conducting waste audits at rural and urban landfills, and evaluating reuse opportunities that currently exist, the government will have a better idea of what products require an EPR program sooner and be able to adequately prioritize based on sound environmental outcomes from such a program.
  5. Increasing awareness and participation in recycling programs in northern, remote and First Nations communities is an area where CESA has excelled in recent years. The key factor in that success is regular and frequent communications, advertising on a local scale, including FNRadio, participating in “round-up” events, partnering with other stewardship agencies to coordinate pick-ups, and developing a training program so that remote communities can operate, and hence benefit financially and environmentally, from operating their own collection depot. CESA would be pleased to bring a similar program to Saskatchewan and help engage remote and under-serviced communities while increasing both awareness and diversion rates.
  6. As above, the same or very similar approach for First Nations communities has worked in BC. Often times it takes longer to build the relationship and trust between cultures, but CESA’s experience in BC in many First Nations communities has been overwhelmingly positive.
  7. The current stewardship and recycling programs for electronics is working for well in Saskatchewan. In 2015, EPRA collected 2,770 tonnes of electronics for recycling. However, CESA advises that one size does not fit all when it comes to stewardship programs and products. CESA encourages the government to take the time to understand the nuances of each program and the product life-cycles before considering expansion of existing programs to include additional products.

    Specifically CESA’s members are strong advocates for allowing industry to select its own collective or third party agency to manage its obligations. CESA’s members take their responsibilities under EPR very seriously and as obligated stewards, producers and retailers feel that if they are responsible for end of life management, then they should be permitted to join a collective arrangement of their choice to achieve that goal. In other words, Saskatchewan should design any new EPR regulations to allow producers the maximum freedom of contract to engage a third party to manage their obligations, not dictate which agency will manage which programs or products.

    CESA’s members believe that having a voice in the development and design of a program that manages their products at end of life is critical to the success of the program. Many of CESA’s members are small, one product line companies whose voice and concerns would be lost in a larger collective. Our member companies formed CESA precisely because they identified that collecting, and recycling small appliances, and building public awareness, required a dedicated and intentional strategy. When small appliances are included with other waste streams, the result is predictable. The largest members of the group dominate the attention, the agenda, and the decision making, and small appliances get ignored, meaning more of them end up in landfills. Furthermore, it is our belief that reducing waste is a challenge at any time, but especially so if waste streams are categorized too broadly, suggesting that, for instance, the strategy for recycling big screen TVs should be the same as the strategy for recycling electric tooth brushes.

As a long-standing member of CESA, we are confident that the small appliance category is sufficiently unique that it would be best represented by a stand-alone program that is individual and intentional in its strategy and execution.“

Rob Felix
Vice President, General Merchandise, Insurance Services, Warranty & Postal Outlets
London Drugs Ltd.

“Dyson has been a member of CESA since its inception in 2011 in BC. We are impressed with the organization’s ability to drive collection volumes higher every year, increasing awareness through partnerships in urban, rural and remote communities, all the while successfully representing smaller manufacturers whose voice would otherwise have been lost if amalgamated into larger WEEE programs.

Dyson wholly supports CESA’s efforts to introduce their successful model into Ontario, and looks forward to partnerships with Ontario’s government in developing sustainable solutions for long-term growth in tandem with environmental management.“

Andrew Robinson
President
Dyson Canada

Summary

CESA is a strong supporter of harmonized, cost-effective strategies that help our members discharge their obligations under provincial EPR programs. Our members are seeking individual representation by the collective of their choice, and not to have their products designated into an existing program, thereby eliminating their free choice of how best to manage their obligations. We are confident that our success in BC can be modelled in Saskatchewan and where necessary, adapted to the regulatory and organizational landscape within Saskatchewan. The below graphic, with data from 2016, illustrates our success in recycling of small appliances and power tools and demonstrably increasing consumer awareness and understanding. Thank you for the opportunity to present CESA’s members thoughts on the Saskatchewan Solid Waste management Strategy.