Raven Recycling Society’s response to extended producer responsibility regulation
Raven Recycling Society has kept the Yukon’s door to recycling open for over three decades by investing in infrastructure, demonstrating value and community buy-in and shouldering the majority of the risks associated with collecting and selling commodities.
The society has persevered through market crashes, shifts in political opinion and, at times, inadequate government support. We have advocated continuously for a more organized and government-led approach to waste diversion, while successfully diverting tens of thousands of tons of material from Yukon landfills. Raven has created jobs for the Yukon, both within the society and throughout a network of businesses, which have benefited significantly from the subsidies that Raven has negotiated with governments. We have been many Yukoners’ first employer and we continue to lead education on the issue of waste diversion and waste colonialism throughout Yukon.
We’re pleased to see the Government of the Yukon demonstrating responsibility for managing waste.
We offer our sincere congratulations for developing extended producer responsibility (EPR), a regulation that obligates producers (companies that manufacture and/or market designated materials) to manage waste diversion, according to a waste management hierarchy. It is time for a shift to corporate responsibility for waste diversion and we are hopeful that this move means recycling will become more effective in the Yukon.
We commend the hard-working team at the department of Environment, and Natalia Baranova in particular, for stepping outside the bounds of consultation, to act as information gatherer and educator for the entire advisory committee.
The development of a new regulation within the timeframe promised is a significant achievement for both Baranova and the department.
EPR is a step in the right direction, working towards a more harmonized and effective approach.
However, the Yukon’s EPR legislation is not without its shortcomings.
The good:
• Reuse is prioritized in the regulation.
• Multi-family residences will be included in collection services.
• Producers will have to pay for curbside collection, if we have it before implementation.
• Producers will have to manage a comprehensive list of packaging, including glass, foam and soft plastics, as well as hazardous waste products.
The bad:
• No targets defined in the regulation.
• No standards for end markets or end of life management of material collected.
• Too much power in the hands of the producers.
• No clarity on which stakeholders the producers will have to consult or how.
• No meaningful metrics for stewardship plan evaluation and approval.
• No arms-length body to oversee registration, evaluate stewardship plans or annual reports, help with enforcement or hold government accountable to their regulation.
The Yukon government has, for all intents and purposes, replicated British Columbia’s regulation, which has been repeatedly and harshly criticized for railroading small businesses, manipulating municipalities into carrying the bulk of the cost of collection, failing to hold producers accountable to meeting their own targets or improving their plans and failing to result in the environmental benefits intended. Producers are primarily big corporations that are good at externalizing their costs, which limits the incentive to design better products.
There is still much work to do before the environmental benefits of this regulation will be realized. We are hopeful that improvements will be made over time and our government will reclaim at least some of the authority they have put in the producers’ hands. Our government should be setting high targets in the regulation, designating an arms-length oversight body and paving a clear path to enforcement.
In the absence of these measures, it is critical that the community holds our government accountable to the central strength in this regulation — the waste management hierarchy which priortizes reuse.
This year, through our Zero Waste program, we invested in a recycled glass kiln and we are working with Lumel Studio to build a recycled glass industry. We are starting small with the intent to scale up in a sustainable way. We are working with the City of Whitehorse to build programs for diversion of materials not covered by this regulation, such as mattresses, and creating our own business selling used textiles and household items. Others are taking initiative to reuse old fabrics, propane tanks, commercial cardboard and discarded hard plastics.
We’re inspired to see a movement of reuse taking hold. Let’s be the first jurisdiction in Canada to ensure our government holds producers accountable for reuse, before recycling.
Stay in touch with Raven’s activities to encourage reduce, reuse, repair and recycle by visiting www.ravenrecentre.org and following us on Instagram.
Raven Recycling Society