From all of us at CSSA and our family of recycling organizations, we wish you a happy holiday season and thank you for your contribution and support this past year. We hope you have a great holiday and we look forward to working with you in the New Year.
CSSA Holiday Office Hours
Our offices will be closed from 1pm EST on December 24 until 8:30am EST on December 29. The office will also close for New Years from 1pm EST on December 31 to 8:30am EST on January 2, 2015.
National Voluntary Steward Policy
In our efforts to bring further harmonization to packaging and printed paper stewardship programs, CSSA has developed a single Voluntary Steward Policy and approval process for its family of packaging and printed paper programs.
What is a voluntary steward?
A voluntary steward is a non-resident brand owner who supplies packaging and/or printed paper into a regulated jurisdiction and has elected to assume responsibility for its material. A business’ residency status is a core determinant of whether or not it is obligated by a province’s stewardship regulation. In the absence of a resident brand owner, the legal obligation falls to the “first importer” – typically the retailer or distributor that has residency in the province.
Voluntary stewards relieve the resident retailer/distributor of having to report and pay stewardship fees on their brands; it is a concept that is unique to Canada and widely supported by retailers as well as brand owners that want to be recognized by their retail customers and consumers for recycling their post-consumer waste.
How does the new policy change the status quo?
Currently there are no clear and harmonized guidelines for determining which businesses are eligible to become voluntary stewards. In addition, the definition of “voluntary steward” and the process by which businesses join CSSA’s packaging and printed paper programs as voluntary stewards differs across the country.
Currently, there are no voluntary stewards in Ontario, although the Stewardship Ontario Rules do allow them. In Manitoba, stewards sign a voluntary steward agreement which requires them to list all the brands for which they are assuming responsibility and notify all their retail and distributor customers. In the event that a voluntary steward terminates the agreement, the legal obligation reverts back to the original first importers. In British Columbia and Saskatchewan, a voluntary steward signs a membership agreement which requires it to assume responsibility for all its brands supplied into the residential marketplace. However, the membership agreement does not currently require a voluntary steward to list all its brands and notify its customers that it is assuming reporting and payment responsibilities for them. The absence of retailer notification and the absence of a brand list creates complications for retailers who are trying to determine whether their supplier brand owners have fully satisfied their reporting requirements.
Key Features of the New Voluntary Steward Policy
CSSA’s objective is to provide a policy that clarifies which businesses are eligible to be a voluntary steward and contains a harmonized set of standards/requirements that must be met.
Key features of the policy (complete policy is available here) include:
- Clear definition of a voluntary steward:
- Not resident in the provincial jurisdiction for which it is applying for voluntary steward status;
- Must be a resident in Canada;
- Supplies material equal to or greater than the de minimis tonnage threshold for each program (i.e., 15 tonnes in Ontario, 1 tonne in British Columbia, Saskatchewan, and Manitoba).
- Voluntary steward agreement clearly sets out the obligations of the voluntary steward:
- Voluntary steward assumes responsibility for all brands it supplies into the provincial jurisdiction;
- Voluntary steward provides a list of its brand names for which it is assuming responsibility;
- Voluntary steward provides a list of names of all its first importer customers (retailers) in the jurisdiction for which it agrees to assume responsibility. (Voluntary stewards are not allowed to volunteer for some retailers and not others);
- Voluntary steward notifies each of its listed customers that they are not obligated to report on the brands for which the voluntary steward is now taking responsibility.
Please Note: All existing voluntary stewards (effective January 31, 2015) will be grandfathered under the new policy.
3. A voluntary steward must enter into an agreement with each stewardship program for which it intends to assume a voluntary obligation. The agreement specifies that the stewardship obligation reverts back to the first importers (retailers or distributors) listed in the agreement in the event that the voluntary steward defaults on any of their reporting or payment obligations for the material supplied in that provincial jurisdiction. This provision protects the stewardship program from having to assume the liability for the uncollected receivables of voluntary stewards, the cost of which must then be borne by other stewards in the collective.
4. Contract termination terms are designed to provide retailers with sufficient notice of voluntary steward exits: Voluntary stewards wishing to terminate their agreement will be required to provide 12 months written notice of termination. They must notify CSSA by December 31st of a calendar year (notification this year will be January 31, 2015, to accommodate introduction of new policy). This will release them from their obligation to submit any further reports. The voluntary steward will still however be obligated to pay in full for all the invoices that are based on reports already submitted (as fees will already have been set for that period). This payment obligation must be paid in full by May 31st of the year following their termination notification. This provision enables CSSA to provide retailers/first importers with sufficient notice of voluntary stewards’ termination in advance of the next reporting period at which time they will be required to assume the exiting voluntary stewards obligation.
Next Steps for Stewards
- Please review the voluntary steward policy
- To apply to be a new voluntary steward for Stewardship Ontario, MMBC, MMSW, or MMSM, please download the agreement and complete all sections. Please then scan and send to National Steward Services via email at at email@example.com or fax it to1-844–471–1836. If you have any questions, please contact National Steward Services at:1-888-980-9549 or via email firstname.lastname@example.org
- Click here for the Stewardship Ontario agreement
- Click here for the MMBC agreement
- Click here for the MMSW agreement
- Please contact National Steward Services for MMSM agreement
- Applicants will be requested to submit a completed voluntary steward agreement by no later than January 31, 2015.
- If you are an existing voluntary steward wishing to terminate your agreement, please notify National Steward Services in writing no later than January 31, 2015.
- If you are an existing voluntary steward and want to continue as a voluntary steward with one of CSSA’s programs you do not need to take any immediate action as all exisiting voluntary stewards (effective January 31, 2015) will be grandfathered under the new policy.
- Existing voluntary stewards with MMBC will be contacted by National Steward Services in 2015 and requested to complete a voluntary steward agreement, which will then be an appendix to their Membership Agreement. Please stay tuned for more details.
Click here to view a copy of the Voluntary Steward Policy.
2015 Fees – Detailed Submission Reports and Associated Fees Now Available on Portal
Detailed submission reports are now available to view on the WeRecycle Portal and will list the material fee rates and total 2015 fee obligation for each of CSSA’s programs.
Any questions should be directed to Steward Services at 1-888-980-9549 or email@example.com.
EPR Schemes in the EU
In November, CSSA hosted a one day summit ‘What can Canadian Provinces Learn from the EU About the Role of Producers and Compliance Schemes in Competitive Marketplaces for Extended Producer Responsibility?’The summit provided an opportunity for key people in the producer, recycling, EPR, and regulatory communities to discuss what can be learned from the EU experience in operating EPR programs.
Presenters from UK, Austria, Germany and Belgium shared their experience and knowledge with attendees on:
- How EPR schemes in the EU operate, and what a competitive marketplace for EPR looks like in Europe
- How and whether competition drives public policy outcomes
- What the future might hold for EPR schemes in Canada
- How best to create legislative frameworks that level the playing field for competitive schemes
- Insights into some of the longest and most successful EPR programs operating globally
The Stewardship Gazette ran a feature on the summit, which can be read here.
Copies of the presentations are available on the CSSA website.
2014: Year In Review
It has been a busy and challenging year at CSSA, and one that has seen substantial growth for the organization. The MMBC program in British Columbia has continued to grow with new communities coming on board and new depots opening up; and it looks as though new legislation in Ontario will be introduced in 2015.
CSSA has taken great strides over the last year to realize its harmonization efforts, and has achieved many milestones along the way:
- One-stop shop reporting and payment portal (WeRecycle Portal) for stewards;
- National Steward Services call centre;
- Ongoing steward training and information sessions;
- National standards and performance benchmarks;
- National material list;
- A shared administrative back office to receive, review and pay service provider claims for all programs;
- A national voice on EPR programs.
These are great accomplishments and all made possible through active engagement from our steward community across the country.
CSSA Welcomes New Board Members
For some time now, we have been looking to expand the CSSA board. We are pleased to announce that three new board members were appointed in 2014:
- Paul Hazra, VP of Corporate Services for Overwaitea Food Group
- Trevor Carlson, Director of Environmental Affairs for Federated Co-operatives Limited
- Shelly Martin, President and CEO, Nestle Canada Inc.
We also welcomed Krista Scaldwell, VP of Public Affairs and Communications from Coca-Cola, who replaces Dave Moran who served on the board for the last two years.
You can read their biographies on our website here.
Important Updates for Blue Box Stewards
Stewardship Ontario issued an update to all Blue Box stewards on December 12 containing important updates on the following issues:
- The arbitration ruling
- The 2014 steward obligation gap
- Using reserves to pay some of the obligation gap
- Revised 2014 fee schedule and the associated Arbitration Adjustment Rule
- Steward invoices and payments
- 2015 fee schedule
- Blue Box Rules for consultation
It is important that Blue Box stewards read this update as many of the issues contained in it will affect you.
Stewardship Ontario is working to issue invoices for the arbitration adjustment fee by early January. In the meantime however, you are able to calculate your remaining 2014 obligation by applying the adjustment fees to the quantities reported in 2013 based on 2012 sales data. You can easily access the 2013 reports by viewing your company’s detailed submission reports which are accessible via the WeRecycle portal. When calculating your remaining 2014 obligation, please take into consideration any tonnage adjustments that have been made throughout the year.
Click here to access the Arbitration Adjustment Rule and the revised 2014 fee rates.
To read the Blue Box update, please click here.
PIM Tables Available.
- To view the 2014 Blue Box fee calculation model with adjusted fees, click here.
- To view the 2015 Blue Box fee calculation model, click here
WDO Decision on Paint and Battery ISP Released
Waste Diversion Ontario (WDO) announced on December 10 that it has approved the Industry Stewardship Plan (ISP) from Product Care Association (Product Care) for paints and coatings, and did not approve the ISP from Call2Recycle Canada for single-use batteries. WDO has stated that the effective date of Product Care’s stewardship plan for paints and coatings will be no earlier than June 2015.
Stewardship Ontario will take some time to assess what impact these decisions will have on the MHSW program and on stewards. We will keep all MHSW stewards informed during this process.
- To read Stewardship Ontario’s full statement regarding the ISP announcement, click here.
2015 MHSW Rules Now Available for Consultation
Stewardship Ontario has received conditional approval from the WDO Board for the 2015 MHSW Rules for Stewards pending consultation with stewards. The 2015 MHSW Rules contain some changes from previous years’ Rules, including:
- Minor clarifications regarding record retention;
- Additional clarity of the Annual True-Up process, without changing the intent;
- Clarity of requirements of stewards wishing to join an industry stewardship organization;
- Removal of certain TC codes from the list of obligated pressurized containers as those specific types of cylinders are either supplied only to the IC&I sector and/or have capacities over 109 litres.This change does not impact the definition of pressurized containers nor does it impact the steward community as these cylinders should never have been included in the initial rules as they are not obligated products.
The 2015 MHSW Rules, available here, are open for comments from stewards. Comments should be sent to WeRecycle@stewardshipontario.ca with ‘2015 MHSW Rules’ in the subject line no later than January 23, 2015. We will post any comments received and our responses along with confirmation that the 2015 MHSW Rules for Stewards have received final approval.
Blue Box Rules – To review and provide comments on the 2015 Blue Box Rules, please click here.
Multi-Material British Columbia
New MMBC Website
MMBC is always seeking to make information more accessible to our many stakeholders. With this in mind, we have redesigned our website to provide a cleaner user experience to help visitors find information that’s relevant to them. Click on the link below to view the new site.
MMBC Assumes Responsibility for Recycling in New Communities Starting January 1
Recycling in the communities of the City of Langley and the City of Revelstoke, which has been managed by the respective local governments as part of the MMBC program since May, will be managed directly by MMBC starting January 1, 2015. Langley and Revelstoke represent approximately 6,400 single-family and 7,000 multi-family households of the 1.25 million curbside and multi-family households benefiting from the MMBC program.
Residents in these communities will be able to recycle new items such as plastic milk jugs, milk and other gable top cartons, hot and cold paper beverage cups, aluminum foil packaging and plant pots.
MMBC Official Supplier of Canada Winter Games
MMBC is proud to announce its commitment as an Official Supplier of the Canada Winter Games. For the 2015 Games, MMBC will provide 550 recycling receptacles to ensure that all of the venues have a comprehensive recycling program. Once the Games are complete, these receptacles will be gifted to Emterra Environmental so that MMBC can institute recycling for approximately 4,300 units in multi-family dwellings in Prince George.
“Multi-Material BC is pleased to be able to contribute to the 2015 Canada Winter Games and their legacy,” says Allen Langdon, Managing Director of Multi-Material BC. “Through this contribution we are not only assisting the 2015 Canada Games in maintaining its sustainability objectives, but we are also then able to expand opportunities for Prince George residents to recycle more materials, an essential step to help us increase the amount of packaging and printed paper that is diverted from landfills.”
Click here for the official press release from the Canada Winter Games or read the Prince George Citizen news article: MMBC on Board for Winter Games
Multi-Material Stewardship Western
Program Exemptions for Businesses Announcement
Saskatchewan Government Announces Exemption Criteria from The Household Packaging and Paper Stewardship Regulations.
The Saskatchewan government released an announcement on Thursday, December 18, regarding new exemptions and capped fees for businesses obligated by its
Household Packaging and Paper Stewardship Program Regulations(Read the announcement here and accompanying fact sheet).
This announcement presents significant economic and operational challenges to MMSW’s Waste Packaging and Paper Program, which was to launch on January 1, 2015. While the full extent and nature of these challenges will not be known until a full review and examination has taken place, MMSW can confirm that the implications of today’s announcement are serious and prevents a January 1, 2015 launch.
MMSW released a statement on December 18, which can be read here.
We will release further communications once we have completed our review and evaluation.
Multi-Material Stewardship Manitoba
MMSM issued a communication on December 15 regarding the approval of its 2015 fees. To read more about the fees and the calculations that impacted them, click here to read the MMSM communication.
Recycling & Waste Reduction: A Discussion Paper
As part of Tomorrow Now, Manitoba’s Green Plan, the Manitoba government released a discussion paper on December 12 focused on recycling and waste reduction.
Many of the proposals in the discussion document, if executed, could have an impact on stewards:
- Setting a general 75% recovery target for packaging and printed paper. (MMSM achieved a 63% recycling rate in 2013);
- A new 2020 goal for the reduction in use of retail carry out plastic bags. The target was originally set at 50% reduction in single-use carry out plastic bags. MMSM has achieved a 46.7% reduction rate and the government has stated it wants to increase the original target for achievement by 2020;
- Increase the 75% beverage container recycling target;
- Expand existing programs to include ICI packaging and printed paper;
- Reduce the presence of disposable beverage cups in the waste stream and require quick service restaurants to provide on-premise recycling facilities by 2020.
View the Recycling & Waste Reduction: A Discussion Paper. Stakeholders have until March 20, 2015, to provide feedback.
MMSM continued with its promotion and education campaigns over the past couple of months with two major initiatives:
Bag up Manitoba – Plastic Bag Challenge
The 2014 Bag up Manitoba Plastic Bag Challenge has broken another record with nearly 1.6 million plastic bags being collected and recycled during the month of October. In total, 167 schools and two daycares collected a staggering 1,596,333 plastic bags. All schools participating received a garden box and 14 lucky schools received a bench made out of 5,000 recycled plastic bags and composite wood fibers. A program of Take Pride Winnipeg! Inc., MMSM has partnered on this important initiative for the past five years. Since 2008, it has kept close to six million plastic bags out of landfills.
Brandon’s Waste Reduction School Challenge
For the third year in a row, MMSM was the title sponsor of Brandon’s Waste Reduction School Challenge. The challenge ran from October 13-29 and encouraged all students to track their waste through garbage and recycling. Students collected their waste for three weeks, took part in reduction activities and also toured the local landfill. This year’s challenge had 15 participating classrooms. The winning classrooms received pop bottle bird feeders and passes to Brandon’s Community Sportsplex. All students received water bottles, reusable lunch kits, t-shirts and an entry into the grand prize draw of a bike.
The Year Ahead
We expect that several jurisdictions will activate EPR policy and legislation within the next 12-18 months as provinces attempt to meet the deadline imposed in 2009 by the Canadian Council of Ministers of the Environment who committed to having EPR for packaging in place within six years. Our industry will need to be vigilant about ensuring we advocate strategically and cohesively with a view to achieving long-term gains.
In 2015, we look forward to continuing our work with industry associations to identify opportunities to meet various service needs when it comes to complying with stewardship obligations. A national steward registry to make it easier for retailers to identify compliant suppliers is an example of an initiative that is currently under development. Stay tuned for more updates on the work we will be undertaking to further harmonize stewardship programs for packaging and printed paper.
As always, the leadership of our steward community is critical to the success of CSSA’s family of stewardship programs’ ability to ensure we deliver against our environmental obligations responsibly, efficiently and effectively. We are grateful for your continued support and interest in our collective success.
As we look to the future we must work together to realize the meaningful results of our many efforts. We have achieved much in 2014, but there is still a great deal more important work ahead.