Comment
Removing the provision that allows producers to reduce their obligated supply tonnage based on the amount of recycled content, extended warranties, and repair incentives offered does simplify reporting, but could discourage some producers from incorporating these things in their business in the long-term. These reductions/credits are currently optional, and producers that consider this as burdensome do not claim those reductions nevertheless.
Therefore, removing these incentives does not necessarily reduce burden, but rather eliminates the mechanism currently built into the supply reporting processes that encourages producers to enhance PCR content, extended warranties and repairs to allow better circularity.
Submitted October 10, 2024 5:43 PM
Comment on
Amendments to four producer responsibility regulations for tires, batteries, electrical and electronic equipment, and hazardous and special products
ERO number
019-8866
Comment ID
100725
Commenting on behalf of
Comment status