The proposed regulations allow individual producers or producer collectives to charge a visible resource recovery charge (RRC) on designated products at the point of sale (POS). This could lead to consumer confusion and anger when they see a visible RRC on one brand owner's product and no RRC or a different RRC on an identical product supplied by a different brand owner (reminiscent of the eco-fee disaster experienced by the Liberal government).
To avoid this potential problem I recommend that both regulations require producers to embed the RRC in the retail cost of the product. Producers may oppose this requirement on the basis that:
(1) major retailers like to advertise consistent pricing across different provincial jurisdictions,
(2) a visible RRS at POS prevents the RCC from being marked up at each stage of the sales distribution chain and
(3) a visible RRS sends a clear message to consumers that there is a cost for managing the purchased product at end of life.
However, the public policy benefits of embedded RRCs outweigh these concerns. Embedded RRCs would:
(1) encourage producers to absorb a portion of RRCs into their cost structure in response to competitive factors, rather than simply passing the full RRC onto consumers (resulting in some actual producer responsibility rather than simply consumer responsibility)
(2) provide a financial incentive for producers to make their products more cost-effective to recycle
(3) avoid "sticker shock" when consumers reach the check out counter and see different RRCs on similar products.
(4) allow retailers to advertise online and in-store that a fee to cover the cost of end of life management is included in the product price.
With respect to the EEE regulation, the following household items should be added to the list of designated Small Equipment: crock pots, electric pressure cookers, water coolers, food dehydrators and paper shredders.
Under Large Equipment, Treadmills should be expanded to include "all electrically powered exercise equipment". Also, any exercise equipment that generates electrical power (e.g. SportsArt ECO-POWR machines) should be excluded from the regulation.
Submitted May 18, 2019 4:21 PM