I would like to begin by stating that I believe the spirit of this legislation is something that the vast majority of Canadians will agree is "common-sense" legislation. However, with that said I do have some thoughts and opinions on how the current legislation is being proposed.
Currently the proposed legislation requires that the producers must:
- "...establish FREE collection networks for consumers"
- "...provide promotion and educational materials..."
I strongly believe that it is in our best interest as Canadians to have our governments continue to be accountable for and maintain consumer waste collection. The government is currently responsible for the organized pickup of yard waste, garbage, blue bin materials and compost. They should also be responsible for implementing organizing or establishing contracts of a centrally managed solution provider for the organized pickup and management of the EEE classified materials as defined by this proposal. This guarantees that Canadians will have complete transparency of how this new legislation is being implemented and how the materials are being recycled or reused. Also, on this subject is my issue with the keyword FREE. As we ALL know nothing is ever FREE. The paragraph shortly after the above referenced bullet points in the proposal goes on to say that "...costs are shifted off of the taxpayer...". Perhaps there would be no additional burden, in the form of a tax, however businesses will (as they always have) allow the additional cost of implementing such programs to flow down-hill on to the shoulders of consumers and essentially the tax payer. I have noticed when purchasing larger electronic devices and some appliances that companies charge, and inform the customer at time of checkout, that there is a "environmental fee" in addition to the HST added to the final cost of the purchase. Could this fee be charged to the producer in the form of a VAT or similar to that of a stewardship fee? Then when it comes time to perform an audit, those companies would then be rewarded that money back, or could claim a tax exemption based on a measurable target? This could help to prevent producers from immediately increasing the cost of their goods to pay to participate in the program. This proposal mentions auditing for the purpose of making sure the producer has not un-justifiably increased the cost of their goods, due to the cost of the program. What if this prevented them from increasing their cost at all? In theory once they achieved their targets the tax incentive (I previously mentioned) would provide them with no justification to increase the cost of their goods. This way seems the most cost effective. Literally at the end of the day, no one REALLY had to pay anything and we all get a better more sustainable consumer market place.
On the bullet-point regarding promotional and educational material. Again, this in my opinion is the responsibility of our government. Again, whether the government does it or oversees the management of it via 3rd party contracts is fine. However, all the information for all streams and all goods should be accessible via a centralized location and consumers should not be forced to scour an assortment of resources and have to contact producers for information on how to recycle their products. We will get far more buy-in to the program the easier we can make it. Let's face it, when it comes to distributing RAW important information the government does this best. Without the distraction of product advertising and consumer manipulation added into the mix of trying to provide people with information.
One of the categories of EEE is defined as: "Large Equipment, including appliances...". I would be entirely dissatisfied with this legislation if the same rules and proportionate costs did not apply to large automotive manufacturers, or if there was not already a piece of legislation in place that covered that. Vehicles and especially electric cars are chalk full of recyclable electronic components and the producers of those products also need to be held accountable as described by this proposal.
I noticed in the additional input section that the effect that this legislation may have on smaller business operations, which is good and needs to be strongly considered. I mentioned the automotive industry to make sure we are achieving the most impact we can on the LARGE scale before we start over legislating the "little guys" to the point where we are a detriment to Canadian industry.
An extended warranty that would provide the same coverage as the OEM Warranty, would be great but is it economically feasible? What would the additional cost to the consumer look like?
Thank you for considering and taking the time to read my comments. I look forward to reading a reviewing future revisions of this legislation.
Submitted May 13, 2019 1:31 PM