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Complying with the British Columbia Ministry of Environment’s (MoE) Recycling Regulation

January 27, 2012

Q:  Who must participate in the Stewardship Program?

A: The language in the regulation states that the “Producer” must participate.  In the regulation the “Producer” is defined as anyone from the OEM manufacturer through the distribution channel to the retailer that sells the product to the consumer.

It does not include component suppliers.

Q:  Why must we report sales of equipment?

A:  There have been changes in the Canadian government recycling requirements for electric products shipped to British Columbia, Canada.   OPEI, with the Canadian Taskforce of member representatives, is working to ensure its members fulfill the Producer requirements under Part 2 of the BC Ministry of Environment’s Recycling Regulation.

The information reporting is for number of units, not $.  Initially, this will be used to complete the details of the Stewardship Plan with regard to setting the environmental handling fees and budget planning.  It will also be used to report weights for calculating recycling recovery rates over time.

Q:  What information do you need reported?

A: An Excel form is available that asks companies to fill out information on retail outlets and distribution channels shipping or selling product in British Columbia.

Only one worksheet should be submitted per company and only for electrical-driven products.

Companies will be submitting sales estimates for each category of product sold in British Columbia, or Canada as a whole. An excel form is available for submitting this data.

As the program continues, sales (shipments) into Canada will be reported monthly and used to calculate recycling recovery rates for the program.

Q: What if we only have Canadian sales, not broken out by province?

A:  We have agreement in our plan to represent British Columbia sales as a percentage of all Canadian sales; this being 13 percent for British Columbia.

Q: Why must recovery rates be determined?

A:  A requirement of the regulations is to report Recovery Rates of product subject to the Regulation.  This Recovery Rate will be calculated as the percentage of product recycled compared to the product introduced into the market place.

The estimates of recoverable OPE are relatively small compared to other stewardship programs. The OPEI-CTF estimates that approximately 30,000 electric-powered OPEs are retired every year in British Columbia, or approximately 150 to 200 tonnes.

Q:  How will the recovery rates be determined?

A: Data will be collected and reported to the Product  Care Association (PCA) by the steel recycling companies as to the amount of outdoor power equipment collected for recycling.  The amount of product introduced into the market will be reported monthly to PCA.  PCA will use this data to calculate the recycling recovery rates.

Q:  What about fuel powered products?

A: The Stewardship Plan requires a two-year study of fuel (gas) powered products to analyze the level of existing recycling rates and the potential for these products to be disposed in landfills.  This study will commence in 2013.

Results of this fuel-powered products study will be used to determine if any regulatory action is warranted for these products.

Further information on fuel-powered products will be communicated at a later time.

Q:  Will an Environmental Handling Fee (EHF) be imposed on fuel-powered products?

A: It is not the intent of the Stewardship Plan to impose an EHF on fuel-powered products.  The EHF will be collected on electric products only.

Q:  Who will collect the EHF?

A: The EHF will be collected by the retailers at the point of sale to the consumer.  The EHF will show on the sales ticket as a separate item.

The EHF applies to all battery and corded outdoor power equipment.

Q:  Why should we provide a list of Retailers, Dealers, Distributors, etc?

A: The Retailers, Dealers and Distributors have a responsibility to charge, recover and submit the EHF to the Program.  To protect our Retailers, Dealers and Distributors and to insure they operate properly within the regulatory requirements, we must communicate to them the information they require to comply with the requirements of the program.  This includes having the proper rate structure for the EHF and insuring they properly implement and submit these.

If you have any questions on this matter, please contact

Gerry Coons @ OPEI – or by phone @ 703-549-7600;

Claire Hargrove @ Hargrove & Associates or by phone @  612-436-5506 and

Mark Kurschner @ Product Care Association or by phone @ 604 592 2972  ext. 201