What Stewards should know for the 2018 Reporting Year.
October has been a very busy month for consultations, conferences, and annual meetings for the Packaging and Printed Paper (PPP) Stewardship world. Nearly every week of the past month has carried new information for Stewards that will change the face of future PPP reporting. For Éco Entreprises Québec (EEQ) as well as programs under the Canadian Stewardship Services Alliances (CSSA) purview, the overarching message is that there are substantial changes that will affect Stewards in every PPP program across Canada, beginning in the 2018 Reporting Year.
EEQ held their consultation meetings in Quebec and Ontario for the 2018 Schedule of Contributions where a number of program updates and announcements were made regarding next steps and future projects that will affect both Steward Reporting processes and financial contributions. Most significantly is the broadening materials subject to a fee, namely the inclusion of packaging short-life containers and packaging sold as products, such as aluminum foil, sandwich and freezer bags, disposable food containers, and party supplies. This is a marked change from previous years, where sandwich bags and plastic film were previously considered product and not covered under the program. This change could be significant for a number of companies and not affect others at all.
While not coming into effect for the 2018 Schedule of Contributions, EEQ has initiated discussions around inclusion materials generated by B2B. This would be a marked change from current program practice and would seemingly affect most Stewards. EEQ has announced that they would have a progressive introduction of designated B2B materials subject to a fee, beginning first with corrugated cardboard shipping boxes.
While these changes will impact Stewards in different ways, EEQ has been consistent and should be commended for their efforts to inform Stewards well in advance of implementing changes. This thoughtful and consultative process ensures Stewards have time to understand, provide feedback, and plan for future reporting responsibilities and financial obligations, at least a year in advance. EEQ continues to demonstrate a respect to the Steward community with regards to changes that impact them.
Canadian Stewardship Services Alliance (CSSA) hosted their Annual Steward Meeting on October 31, where an update was provided for each provincial PPP program under their purview. Updates did include the announcement of 2018 estimated program budgets as well as announcing the 2018 Fees that, once approved, will be used to determine the Steward financial obligation for 2018 based on kilograms reported in May of 2017.
Of particular significance was the announcement that despite the heavily anticipated changes to fees in Ontario using the new four-step fee methodology, it was not implemented in Ontario because the timing was impacted by the Minister’s letter regarding the Amended Blue Box Program Plan (A-BBPP). While there was anticipation and concern that 2018 Fees would look closer to that of British Columbia, or Manitoba, it would appear Stewards have at least another year of modest fee changes in Ontario.
There were two other notable CSSA meetings held on October 17 and October 25 to discuss changes to Program Rules, Membership Agreements and Policies, as well as the development of an A-BBPP.
During the CSSA webinar for Program Rules and Membership Agreement Updates, the following new policies were announced that might have major impact on a number of obligated companies:
- The new Parallel Importation Policy – impacts first importers – even if the brand owner is on the steward list.
- The new Reporting and Deduction Policy – deductions are now limited to restaurant/quick service.
- The new Harmonized Administrative Fees, Interest, and Penalties Policy – brand new fees, interests, and penalties.
The A-BBPP will also result in significant change for Stewards in Ontario in the coming years starting no earlier than 2019. As you may know, Ontario has passed new legislation, which will effectively change the level of producer responsibility from a shared 50% of net costs to 100% producer responsibility, once fully implemented. At this time, Stewardship Ontario remains heavily focused on the consultation portion of the process, but have indicated that the preliminary draft would be released December 22, 2017 and a review of the draft A-BBPP would be presented at a webinar on January 8, 2018 with feedback required by January 15, 2018.
We encourage Stewards to ensure they are informed of all of the proposed changes coming and to actively participate in the consultation process. CSSA invites Stewards to provide comments and/or questions to email@example.com no later than Friday November 10.
While stewardship in Canada continues to develop, Stewards should remember that they have the ability to influence such industry changes by asking questions or raising concerns – don’t pass up the opportunity to give your company a voice!