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On Thursday November 19th, 2015 we attended the EEQ in-person consultation in Toronto to discuss proposed changes to the Schedule of Contributions effecting packaging and printed paper reporting obligations in Quebec.  Below, you will find the key highlights and insights stewards should be aware of.

EEQ Annual Meeting Overview

  • Increased fee rates for 2015 and 2016 reporting years
  • Proposed changes to Schedule of Contributions (Rules)
  • Reporting and payment timelines
  • New refiling deadlines announced
  • Potential changes in 2017

Fee Changes for 2015 and 2016

  •  For 2015, the average fee rate increased 8.8%
  •   Material fee rate changes have large fluctuations (-32% to 80%) depending on the material type*
  •   For 2016, the average fee rate increased 7% and material specific changes do not exceed 8.5%*
  • * For more details see Schedule of Contributions, p.12

Proposed Changes to Rules

  • Online businesses may be obligated to submit an annual report if the Contribution Payment Exemption, based on a single retail point of sale, is withdrawn
  • Free-riders will be penalized with a 20% increase on their invoices for not submitting their stewardship report to EEQ

Reporting and Payment Timelines

  • EEQ did not provide any specific reporting deadlines, but they will open the reporting system on a fixed date (TBD) and will close the system when the Schedule of Contributions is enacted
  • EEQ provided a proposed payment schedule:

timelines

New Refiling Deadlines

  • You have 45 days to submit supporting documentation requested by ÉEQ and late submissions will receive admin penalties
  • Reporting methodology and excluded material revisions must be submitted one year from the reporting deadline
  • Double reporting must be submitted two years from the deadline

Potential Changes in 2017

   New materials to be included in the 2017 Schedule of Contributions may include:
– B2B transactions
– Short lifespan containers, packaging and printed matter sold as product

If you want to discuss your company’s stewardship obligations further or you need reporting advice,  please don’t hesitate to contact Kelsey Schram at kschram@reclaystewardedge.com.

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