Revisiting EPR For IC&I Sector BY RACHEL KAGAN
be impacted. Meanwhile, other provinces are continuing to explore the possibility of applying EPR to the IC&I sector, with the latest being British Columbia. The BC government committed to developing an ap- proach for IC&I packaging by 2025, as outlined in its EPR five-year action plan, and they are currently consulting on how to manage packaging and paper waste from the non-residential sector. The government’s Consultation Discussion Paper outlines many potential options, includ- ing expanding EPR to the IC&I sector and introducing EPR for a specific sector, among other possibilities. While PPEC supports efforts to increase recycling and waste diversion, and consultations are an important way to have informed discussions, we remain concerned that we are putting the cart before the horse. The cart being IC&I and the horse being EPR. We should not assume that the same approach for res- idential recycling will work for the IC&I sector for a variety of reasons. The IC&I sector is very different than the residential sector. One side features waste and recyclables collected from homes and apartments. And on the other side, ma- terials are generated from a variety of distinct locations: manufacturing facilities, retail and grocery stores, malls, restaurants, offices, hotels, stadiums, airports, schools, hospitals…the list goes on. CONTINUED ON PAGE 20
Last year the Paper and Paperboard Packaging Environ- mental Council (PPEC) asked if we were putting the cart before the horse when it came to considering a regulat-
ed Extended Producer Responsibility (EPR) approach for recycling packag- ing in the non-residential sector, com- monly known as the Industrial, Com- mercial and Institutional or IC&I sector. Revisiting that question now and the answer seems to be…maybe. Stakeholders, including PPEC, are closely watching Quebec – the only
Rachel Kagan
Canadian province to legislate EPR for IC&I – as it pre- pares to expand EPR into the IC&I sector as part of the province’s move to modernize its recycling system. Que- bec is phasing in the expansion, which begins in 2025 with schools, outdoor public areas, and similar IC&I establish- ments (defined as “comparable, in nature and quantity, to those meant for the residential sector”), while other parts of the sector will be expanded between 2027 and 2030. But there are still many unanswered questions about how EPR for IC&I will work in Quebec, what the fees will be, and how existing contracts with private recyclers will
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