I applaud the move to keep…

I applaud the move to keep harmful products out of the landfill, reduce waste in all possible ways and encourage consumers to choose long lasting, quality products. However, as written, the proposed regulations for batteries appear contrary to this mandate. The management requirement for small single use batteries begins at 30% and increases to 50% by 2023. The management requirement for small rechargeable batteries begins at 70% and increases to 80%. Therefore, producers who put long lasting, rechargeable batteries into the market incur significantly more battery management cost per unit than producers selling single use disposables. Operating cost increases will lead to a larger price gap between rechargeable and disposable batteries, thereby encouraging some customers to chose single use batteries and increasing waste. Also, an 80% diversion rate is unattainable for removable consumer household batteries. This would be an admirable goal for batteries that are normally changed professionally – automotive, etc. However, Ontario’s well established, curbside collection program has only reached a 61.3% recycling rate despite being easy and convenient. Expecting a program that requires more active consumer commitment to reach significantly higher rates in such a short time is unreasonable.

The regulation also needs to take the expected life cycle of products, both battery and EEE, into account in order to encourage consumers to make environmentally responsible choices. We entered the battery market a few years ago selling high quality lithium-ion rechargeable batteries. Based on charge cycle testing, we expect our battery life to easily surpass 10 years for our consumer product. However, since life cycle is not taken into account, we will end up subsidizing producers who sell less expensive, shorter life product. This will, again, increase the retail price gap pushing consumers to the lower price option which is the opposite of what Ontario is trying to achieve.

And from a personal (consumer) point of view, I believe making individual producers responsible for collection and management will just cause confusion. I can understand making producers, and ultimately the consumer, financially responsible for the cost of programs. However, we need to make recycling easier for consumers by standardizing programs throughout the province…ideally throughout Canada. Multiple competing programs just make it harder to figure out how to dispose of product responsibly. Eventually, you give up and toss it in the trash – again, the opposite of what we want to achieve.

Thank you for the opportunity to provide feedback.