British Columbia Outdoor Power Equipment Institute Stewardship Plan for Electric Outdoor Power Equipment Consultation Draft

Transcription

1 British Columbia Outdoor Power Equipment Institute Stewardship Plan for Electric Outdoor Power Equipment Consultation Draft September, 2016 For more information: Gerry Coons, Vice-President, Standards and Industry Affairs Outdoor Power Equipment Institute of Canada (OPEIC) 130 Adelaide Street West, Suite 701 Toronto, ON, M5H 2K4 (703) (778)

2 Executive Summary The BC Recycling Regulation 1 ( Regulation ) requires that producers of electric outdoor power equipment ( EOPE ) have an approved stewardship plan in order to sell, offer for sale, distribute, or use in a commercial enterprise the product in British Columbia. The Outdoor Power Equipment Institute of Canada ( OPEIC ), in collaboration with the Outdoor Power Equipment Institute Canadian Task Force ( OPEI-CTF ), developed, implemented and currently operates the approved stewardship programs for EOPE in BC ( Program ). This amended stewardship plan ( Stewardship Plan ) replaces the original stewardship plan approved on April 20, EOPE products are captured under section 2(1)(d) ( Electronic and Electrical Product Category ) under Schedule 3 of the Regulation. EOPE is a broad category of products classified into four categories: handheld EOPE, walk-behind EOPE, free-standing EOPE and lawn tractors, including electric lawn mowers, electric snow blowers and electric-powered gardening equipment. The Program takes a market-driven approach based on the premise that EOPE products have intrinsic value. The Program contracts with the existing scrap metal recycling industry to create a network that provides year-round recycling options for consumers wishing to return their broken or unwanted EOPE at no charge. Specifically, the Program partners with the Canadian Association of Recycling Industries ( CARI ) association for metal recyclers; contracting directly with CARI s members who comprise the majority of existing metal collection and transportation facilities in the Province. In order to determine the amount of product collected by the Program, OPEIC will continue to conduct sampling studies of CARI members on an annual basis and will report out on sampling percentages annually. OPEIC is proposing to complete a minimum of four sampling events and sample a minimum of eight sites each year. In addition, the Program will continue participating in waste composition studies in partnership with regional governments, where feasible, to determine the type and quantity of EOPE disposed of in landfills throughout the Province. The Program will maintain or exceed an accessibility standard of 95 percent of the provincial population 2, which accommodates potential changes in the number of collection sites over time. Additionally, an accessibility study will be completed in 2017 and every three years thereafter. The Program will target 55 percent consumer awareness level by 2021 and will conduct a consumer awareness survey in 2017 and every two years thereafter to measure the performance of its communication strategy. The program will continue to be funded by environmental handling fees ( EHF ), remitted to OPEIC by its participants based on the volume of sales of EOPE in British Columbia. 1 British Columbia Ministry of Environment, BC Recycling Regulation, BC Reg. 449/2004, as amended B.C. Reg. 88/2014, May 23, Accessed at 2 SABC accessibility standard: Access is defined as a 30 minute or less drive to a collection site in urban areas (urban communities with a population of 4,000 or more) and a 45 minute or less drive to a collection site in rural areas (rural communities with a population of 4,000 or more). OPEIC 2017 Stewardship Plan Page 1 of 14

3 Contents Executive Summary... 1 Contents Introduction Products Covered under the Stewardship Plan Collection System and Consumer Accessibility... 5 Collection System... 5 Product Sales... 6 Collection Rate Consumer Awareness Management of Program Costs Management of Environmental Impacts Dispute Resolution Performance Measurement Summary and Reporting Commitments OPEIC 2017 Stewardship Plan Page 2 of 14

4 1. Introduction This Outdoor Power Equipment Institute Stewardship Plan for Electric Outdoor Power Equipment ( Stewardship Plan ) is submitted by the Outdoor Power Equipment Institute of Canada ( OPEIC ) on behalf of the major brand owners of electric outdoor power equipment ( EOPE ) products sold in British Columbia to the British Columbia Ministry of Environment, pursuant to the BC Recycling Regulation ( Regulation ). 3 The Regulation sets out the requirements for extended producer responsibility, including the requirement for product stewardship plans, in British Columbia and defines a Producer as: (i) a person who manufactures the product and sells, offers for sale, distributes or uses in a commercial enterprise the product in British Columbia under the manufacturer s own brand, (ii) a person who is not the manufacturer of the product but is the owner or licensee of a trademark under which a product is sold, distributed or used in a commercial enterprise in British Columbia, whether or not the trademark is registered, (iii) a person who imports the product into British Columbia for sale, distribution or use in a commercial enterprise. OPEIC worked collaboratively with members of the Outdoor Power Equipment Institute Canadian Task Force ( OPEI-CTF ) to develop this Stewardship Plan. The original stewardship plan was approved by the BC Ministry of Environment on April 20, 2012 and the Outdoor Power Equipment Stewardship Program ( Program ) commenced operation on July 1, This version of the Stewardship Plan replaces the original stewardship plan of 2012 ( 2012 Plan ). OPEIC manages the Program on behalf of its registered participants, who are defined as Producers of OPE products under the Regulation. The Producers have appointed OPEIC as their stewardship agency. OPEIC is a Canadian federal non-profit organization established with the purpose to govern the EOPE stewardship program. OPEIC works and consults with the OPEI-CTF, comprised of representatives from the industry sector. As of August 2016, OPEIC had 48 participants representing the majority of the EOPE market in British Columbia. Participants included manufacturers, distributors and dealers. Participation in the Program is open to all Producers of EOPE, subject to the terms of the Program s Participant Agreement. Product Care Association ( PCA ) continues to be engaged as Program Manager by OPEIC. A list of Program participants can be found on the OPEIC website: 2. Products Covered under the Stewardship Plan 3 British Columbia Ministry of Environment, BC Recycling Regulation, BC Reg. 449/2004, as amended B.C. Reg. 88/2014, May 23, Accessed at OPEIC 2017 Stewardship Plan Page 3 of 14

5 Section 4 of the Regulation provides: A producer must submit a product stewardship plan, at the time specified in the applicable Schedule, if any, and in a manner and format satisfactory to a director, for the products within the product category of the product the producer sells, offers for sale, distributes or uses in a commercial enterprise in British Columbia. EOPE is a broad category of products that includes electric lawn mowers, electric snow blowers and electric-powered gardening equipment. They can be battery powered (primarily lithium ion and perhaps some lead-acid) or electric powered (primarily 110V plugged into a regular electrical socket). EOPE products are captured under section 2(1)(d) ( Electronic and Electrical Product Category ) under Schedule 3 of the Regulation: (d) electronic or electrical tools, other than large-scale stationary industrial tools, including, without limitation, (v) snow blowers and mowers and other gardening tools, Program products are classified into four categories: hand-held EOPE, walk-behind EOPE, free-standing EOPE and lawn tractors, including the corded and/or battery powered products summarized in Table 1 ( Program Products ). Table 1: OPEIC Program Products Hand-Held EOPE Walk-Behind EOPE Free-Standing EOPE Lawn Tractor Brush cutter/lopper Lawn mower Mulcher Lawn tractor Chain saw Snow thrower/snow Pressure washer blower Garden shear Tiller/cultivator Wood chipper/shredder Garden sprayer/insect Dethatcher Wood splitter fogger Ice drill Walk-behind sprayer Lawn blower/vacuum Edger/trimmer Lawn Lawn aerator scarifier/dethatcher Pole saw/pole pruning saw Walk-behind blower/vacuum Post hole digger Stick edger Tiller Trimmers (grass, hedge, etc.) Split boom OPEIC 2017 Stewardship Plan Page 4 of 14

6 OPEIC reserves the right to amend this list of products in the future as appropriate. 3. Collection System and Consumer Accessibility Section 5(1) of the Regulation provides: (a) the plan will achieve, or is capable of achieving within a reasonable time, (i) a 75% recovery rate or another recovery rate established by the director, (B) for each product category covered by the plan, other than the beverage container product category, if required by the director. (ii) any performance requirements or targets established by the director. (iii) any performance requirements or targets in the plan. (c) the plan adequately provides for: (i) the producer collecting and paying the costs of collecting and managing products within the product category covered by the plan, whether the products are currently or previously sold, offered for sale or distributed in British Columbia.. (iii) reasonable and free consumer access to collection facilities. (v) assessing the performance of the producer's product stewardship program. Collection System OPEIC contracts with existing collection sites to create a network that provides year-round recycling options for consumers wishing to return their broken or unwanted EOPE at no charge. OPEIC has taken a market-driven approach in establishing the network by partnering with the Canadian Association of Recycling Industries ( CARI ) association for metal recyclers. This approach recognizes the intrinsic, positive value of EOPE products at end-of-life and has proven to be an effective approach to stewarding EOPE despite fluctuations in commodity markets. In addition, indicators suggest the market for scrap metal will strengthen in the coming years. Currently, metals make up the largest part of the recycling market. Canadian recyclers process between 16 and 18 million tonnes of scrap metal each year and it is predicted that the metal recycling market will grow from $ billion in 2015 to $ billion by 2020 at a compound annual growth rate of 7.95 percent, resulting from increased demand for metal in construction, electronics and packaging sectors. These high projected growth rates suggest a positive future for the market-driven approach to stewarding EOPE. Alternatively, establishing a traditional product stewardship program for EOPE would not be cost effective, especially given the low volumes of product sales, and would unnecessarily disrupt the existing, robust scrap metal recycling industry. OPEIC contracts directly with CARI s members who comprise the majority of existing metal collection and transportation facilities in the Province. CARI members are ideal return collection sites for EOPE because OPEIC 2017 Stewardship Plan Page 5 of 14

7 they have an established system in BC, have long collected and processed these types of materials, apply environmentally-appropriate processes for managing these materials and are regulated by the Ministry of Environment. In addition, OPEIC contracts with other collection sites, including other metal recycling facilities, local government facilities, recycling depots and return-to-retail locations. To describe the recycling stream of these EOPE products, a CARI spokesman explains that individuals and commercial entities typically deliver EOPE to a contracted collection site either loose or in a bin. The collected EOPE is combined with other metal accumulated on-site, which is then sold to larger metal recyclers, usually CARI members, who process the majority of metal-bearing products collected in BC for recycling. As of August 31, 2016, the Program had 123 contracted collection sites located throughout the Province. Accessibility Targets The Program will maintain or exceed an accessibility standard of 95 percent of the provincial population, meaning 95 percent have access to a collection site as defined by the standard set by the Stewardship Agencies of BC. 4 The 95 percent target accommodates potential changes in the number of collection sites. An accessibility study will be completed in 2017 and every three years thereafter. Product Sales British Columbia Market EOPE are sold across Canada, with British Columbia representing approximately 13 percent of national sales; consistent since the start of the Program. Program Products are typically sold by dealers, hardware stores, department stores and other retailers, many of which are national in scope. EOPE includes seasonal products, with the majority of sales occurring in the spring and fall. The winter months (December through February) have the lowest sales presumably because this is a period of low utilization of EOPE by consumers. Collection Rate EOPE collected is processed through the Canadian Association of Recycling Industries ( CARI ) network of private metal recycling facilities. These facilities manage various types of scrap metal obtained from a range of products. Consequently, it is not possible to segregate EOPE from the mixed-stream of recycled metal products and provide discrete collection volumes. To estimate the quantity of EOPE managed through the scrap metal system, OPEIC conducts sampling studies at select CARI collection sites. Since 2012, OPEIC has conducted multiple sampling study events each year to gain an understanding of the volume of EOPE managed through the scrap metal system in 4 SABC accessibility standard: Access is defined as a 30 minute or less drive to a collection site in urban areas (urban communities with a population of 4,000 or more) and a 45 minute or less drive to a collection site in rural areas (rural communities with a population of 4,000 or more). OPEIC 2017 Stewardship Plan Page 6 of 14

8 BC. It is OPEIC s understanding that the vast majority of scrap metal recycled in BC moves through seven CARI member companies. These seven companies include nineteen locations. While all sampling locations are within the Lower Mainland and Vancouver Island, these locations receive materials from smaller scrap metal collectors located in other regional districts. Collection Rate Sampling Targets OPEIC will continue to conduct sampling studies on an annual basis and will report out on sampling percentages annually. OPEIC is proposing the following sampling targets: Complete a minimum of four sampling events each year. Sample a minimum of eight sites each year. Waste Composition Studies Regional governments conduct waste composition studies to determine the type and quantity of materials disposed of in landfills throughout the Province. OPEIC will continue to participate in waste composition studies in partnership with other stewardship organizations and regional governments, where feasible. 4. Consumer Awareness Section 5(1) of the Regulation provides: (c) the plan adequately provides for: (iv) making consumers aware of: (A) the producer's product stewardship program, (B) the location of collection facilities, and (C) how to manage products in a safe manner. (v) assessing the performance of the producer's product stewardship program. OPEIC will draw on industry best practices and previous Program experience to deliver a strategy that makes use of compelling, impactful marketing and communications tactics. Tactics may include: Advertising Digital Advertising o Search Engine Marketing (SEM) through relevant keywords o Impression Retargeting delivering relevant content based on user s search habits o Display advertising (big box, banner, expandable, etc.) on relevant third-party sites Print Advertising o Including relevant mass market and industry publications, municipal calendars Broadcast Advertising o Mainstream and community radio spots for broad reaching messages, where it is the best medium Direct Mail OPEIC 2017 Stewardship Plan Page 7 of 14

9 o o Distribution of branded OPEIC informational materials to selected and targeted groups or segments Multi-lingual direct mail to ensure major non-english-speaking communities are appropriately engaged. Information Resources Point of Sale (PoS) and Point of Return (PoR) Materials o Materials such as rack cards for existing retailers and collection sites will made readily available for re-order, free of charge Program Website o OPEIC will continue to operate a dedicated website to make information easily available for all audiences through the use of: Geographically searchable Collection Site finder Collection site hours and operations Accepted product lists FAQs related to the Program Important Program resource documents, such as Annual Reports Toll-free Number o OPEIC will continue to operate a toll-free customer service to answer consumer queries Partnerships OPEIC will leverage positive working relationships with key existing and new industry partners in order to advance program awareness and use. Partnerships may include: City departments and regional districts across British Columbia School districts, school principals and regional superintendents Stewardship industry groups such as the Recycling Council of British Columbia (who operate the RCBC Hotline and Recyclepedia search tools), and the Stewardship Association of British Columbia (who operate the BC Recycles information resource, bcrecycles.ca) Community Events OPEIC may pursue a presence at relevant third-party events to raise awareness and, where appropriate, provide one-time product collection services. Consumer Awareness Targets To measure the performance of the communication strategy, OPEIC proposes to conduct a consumer awareness survey in 2017 and every two years after. In 2015, OPEIC conducted a consumer awareness survey and found that 49 percent of British Columbians were aware of a program to recycle outdoor power equipment. The Program will target 55 percent consumer awareness by OPEIC 2017 Stewardship Plan Page 8 of 14

10 5. Management of Program Costs Section 5(1) of the Regulation provides: (c) the plan adequately provides for: (i) the producer collecting and paying the costs of collecting and managing products within the product category covered by the plan, whether the products are currently or previously sold, offered for sale or distributed in British Columbia. (v) the management of costs incurred by the program. (v) assessing the performance of the producer's product stewardship program. OPEIC is funded by participant fees, known as environmental handling fees (EHFs), remitted to OPEIC by its participants, based on the volume of sales of EOPE in British Columbia. EHFs are not a government tax and no part of the fee is remitted to the government. EHF rates are set by the OPEI-CTF. In some cases, retailers recover the amount of the fees from consumers as a separate, visible EHF applied at point of sale or by incorporating it into the cost of the product. Revenues from EHFs are used to fund Program administration and communications. Reserve Fund As part of its risk management system, OPEIC intends to maintain a reserve fund. The reserve fund will stabilize funding in the case of year-to-year cost variances resulting from fluctuations in sales, program enhancements and to cover unforeseen expenses of the Program. 6. Management of Environmental Impacts OPEIC 2017 Stewardship Plan Page 9 of 14

11 Section 5(1) of the Regulation provides: (c) the plan adequately provides for: (v) the management of environmental impacts of the program. (v) assessing the performance of the producer's product stewardship program. (vii) eliminating or reducing the environmental impacts of a product throughout the product's life cycle. (viii) the management of the product in adherence to the order of preference in the pollution prevention hierarchy. The pollution prevention hierarchy is as follows in descending order of preference, such that pollution prevention is not undertaken at one level unless or until all feasible opportunities for pollution prevention at a higher level have been taken: (a) reduce the environmental impact of producing the product by eliminating toxic components and increasing energy and resource efficiency; (b) redesign the product to improve reusability or recyclability; (c) eliminate or reduce the generation of unused portions of a product that is consumable; (d) reuse the product; (e) recycle the product; (f) recover material or energy from the product; (g) otherwise dispose of the waste from the product in compliance with the Act. OPEIC will strive to manage materials according to the highest use as per the Province s pollution prevention hierarchy. Product Design Product design influences the durability and reliability of products, which has a direct impact on the life of a product and end-of-life management options. Producers optimize product design to reduce the materials used, which in turn reduces product weight, material content and product volume. Specifically, producers conduct analyses on the use of plastics and other materials in the design and manufacture of EOPE; maximizing the use of materials that can be recycled and reused. Product design eliminates, wherever possible, the use of hazardous substances, replacing them with nonhazardous materials that can be reprocessed and reused. Producers actively work to reduce the environmental impact associated with product packaging waste. Trends include the reduction in packaging weight and volume, more efficient use of packaging materials, the use of recycled content and recyclable materials. Producers actively encourage dealers to consolidate orders, rather than place multiple, small orders to lower packaging and transportation requirements. OPEIC 2017 Stewardship Plan Page 10 of 14

12 Manufacturing Processes Producers have ongoing initiatives to reduce waste associated with the manufacturing of products. These include the collection, recycling and reuse of remnant ferrous and non-ferrous metals that result from the manufacture of components. Other waste materials that can be recovered and recycled during the manufacturing process for productive uses, including plastic, corrugated and paper materials, are collected for processing and alternate uses. Supply chain initiatives include the use of returnable-reusable packaging for components from suppliers. Suppliers are encouraged to locate support operations in close proximity to manufacturing operations, thereby reducing transportation-related energy use in the delivery of components. Producers seek to reduce water use in water-dependent manufacturing processes through improved process efficiencies. Initiatives include the treatment and reuse of process water to reduce total needs. Reuse and Repair The reuse market for EOPE is very well developed. Valuable EOPE products that are not at the end of the functional life are not expected to be dropped off at return collection sites or events because they have residual value. The market facilitates the repair and reuse of EOPE products through a variety of channels, including: re-selling websites, such as Craigslist and garage sales, charitable organizations, such as the Salvation Army or local product dealerships, and trade-ins on new product purchases. It is expected that re-use product will be in good working order and function properly. Dealer organizations can repair and refurbish used product as appropriate to ensure they are in proper working order. The Plan recognizes that there is a robust and effective reuse system already in place and hence the Program will focus on the collection and recycling of the end-of-life EOPE and, such reuse exists outside the parameters of the Program. Recycle, Recover and Dispose Metals are the primary commodities recovered from EOPE. Metals are divided into two primary classifications: ferrous metals (constituting about 90% of the metal waste stream) that can be sorted through electromagnetic separation, and non-ferrous metals (representing approximately 10% of total metals). Ferrous metals include mainly steel and cast iron; non-ferrous metals include aluminum, lead, copper, nickel and zinc. The metals in EOPE are primarily steel, aluminum and copper and it is possible to recover and sell over 90% of the metals for their commodity value. EOPE collected at a contracted collection site is combined with other metal accumulated on-site, which is then sold to a larger metal recycler, usually a member of CARI, who processes the majority of metalbearing products collected in BC for recycling. Once sold to a larger metal recycler, the EOPE products are sorted by commodity and loaded into bins or baled on-site. All EOPE material is sent to a shredder due to the high cost of dismantling by hand or with other tools. Most whole EOPE is categorized as tin, a low grade ferrous metal commodity which is usually shredded here in BC, but can also be barged or trucked to a nearby facility in Alberta or Washington State. After shredding, the resulting material is sorted into ferrous metal, non-ferrous metal and waste material (plastics, fabrics, etc.). According to information provided by CARI representatives, the shredders successfully pull out approximately 99% of the metal; this material is then shipped to smelters and formed OPEIC 2017 Stewardship Plan Page 11 of 14

13 into ingots. Ingots are then sold to manufacturers to make consumer and/or industrial goods such as cellphones and vehicles. Plastic shredder residue left over from the shredding operation contains plastic mixed with other non-metallic materials. This left over shredder material has traditionally been landfilled, as it is deemed contaminated and not recyclable. 7. Dispute Resolution Section 5(1) of the Regulation provides: (c) the plan adequately provides for (vi) a dispute resolution procedure for disputes that arise between a producer and person providing services related to the collection and management of the product during implementation of the plan or operation of the product stewardship program. OPEIC contracts with all suppliers and service providers to OPEIC by the use of commercial agreements. Any disputes arising from collection or processing contracts are resolved using normal commercial legal mechanisms as referenced in the Program s service provider contracts. OPEIC 2017 Stewardship Plan Page 12 of 14

14 8. Performance Measurement Summary and Reporting Commitments Section 5(1) of the Regulation provides: (a) the plan will achieve, or is capable of achieving within a reasonable time: (ii) any performance requirements or targets established by the director. (iii) any performance requirements or targets in the plan. (c) the plan adequately provides for (v) assessing the performance of the producer's product stewardship program. Table 2 below provides a summary of OPEIC s performance measures and targets. Table 2: Performance Measures and Targets Performance Measures Targets Collections Number of sampling events Number of sites samples OPEIC will conduct a minimum of four sampling events each year. OPEIC will sample a minimum of eight sampling sites each year. Accessibility Percent of population with access to a collection site Consumer Awareness Percent of population aware of the program The Program will maintain or exceed accessibility standard of 95 percent. OPEIC will conduct an accessibility study in 2017 and every three years thereafter. OPEIC will conduct a consumer awareness survey in 2017 and every two years thereafter. OPEIC will target a consumer awareness level of 55% in OPEIC 2017 Stewardship Plan Page 13 of 14