The Post-consumer Waste Problem and Extended Producer Responsibility Regulations:
The Case of Electronic Toys in British Columbia
by
Andrea Nemer Soto
A Thesis Presented in Partial Fulfillment
of the Requirements for the Degree
Master of Arts
Approved July 2014 by the
Graduate Supervisory Committee:
Kevin Dooley, Chair
George Basile
Philip White
ARIZONA STATE UNIVERSITY
August 2014
ABSTRACT
Currently, consumers throw away products every day, turning those materials into
waste. Electronic waste poses special problems when it is not recycled because it may
contain toxic components that can leach into landfill surroundings and reach groundwater
sources or contaminate soil, and its plastic, metal, and electronic materials do not biodegrade
and are lost rather than recycled. This study analyzes a system that attempts to solve the
electronic post-consumer-waste problem by shifting the economic burden of disposal from
local municipalities to producers, reducing its environmental impacts while promoting
economic development. The system was created in British Columbia, Canada after the
province enacted a recycling regulation based on Extended Producer Responsibility (EPR), a
policy strategy that is fast growing globally. The BC recycling regulation requires all e-toy
corporations in BC to comply with a government-approved product-stewardship program to
recover and dispose of e-toys after they have been discarded by consumers. In response to
the regulation, e-toy corporations joined a Canadian non-profit entity that recycles regulated
waste. I conducted a case study using in-depth interviews with the stakeholders to identify
the outcomes of this program and its potential for replication in other industries. I derived
lessons from which corporations can learn to implement stewardship programs based on
EPR regulations. The e-toy program demonstrated that creating exclusive programs is
neither efficient nor economically feasible. Corporations should expect low recycling rates in
the first phases of the program implementation because EPR regulations are long-term
strategies. In order to reach any conclusions about the demand of consumers for recycling
programs, we need to measure the program’s return rates during at least three years. I also
derived lessons that apply to the expansion of EPR regulations to a broader scope of
product categories. The optimal way to expand EPR policy is to do it by gradually adding
i
new product categories to the regulation on a long-term schedule. By doing so, new
categories can take advantage of existing stewardship programs and their infrastructure to
recover and recycle the post-consumer products. EPR proved to be an effective option to
make corporations start thinking about the end of life of their products.
ii
ACKNOWLEDGMENTS
Many people played fundamental roles in my life before I was able to accomplish my
Master’s degree at Arizona State University. First of all, I want to thank the School of
Sustainability and The Sustainability Consortium for giving me the opportunity to be part of
their teams; I gained priceless knowledge and experience in sustainability, plus I was able to
fund my studies. To my adviser Kevin Dooley, for your guidance, inspiration, and
encouragement. To George Basile and Phillip White, thanks for your priceless insights. Many
thanks to my supervisor Carole Mars--you became my mentor. And to the rest of my
colleagues at TSC, especially at the ASU office, all of you were the sparkle in my ice-cream
on this journey. To my friend and best writer-advisor in the world Kathryn Kyle, thanks to
you I learned to do my best in communicating my ideas. To my very dearest friends Pamela
Lam and Javier Abraldes, I valued your advice and support to help me make the best
decisions. I want to thank my family, my grandmother, my parents, my aunt Herlinda, and
the rest of the family, for your emotional support. To my precious friends Ashwina Mahanti,
Cathy Rubinos, Christine Strum, Jaimi Inskip, Karen Kao, Mady Tyson, and Tammy
Foucrier, I am grateful for being able to find true friendship with all of you. Thank you to
my always virtually present best friends Bere Duarte, Ana Holguin, Xochitl Padilla, Reyna
Quintana, and especially to Noe Cesena because you were there for me when I was in a
hotspot (inside joke). Finally, thank you to the reader of this document, by reading it you will
make all this work is worthwhile.
iii
TABLE OF CONTENTS
Page
LIST OF TABLES ..................................................................................................................................... v
LIST OF FIGURES ................................................................................................................................. vi
CHAPTER
1
INTRODUCTION ................................................................................................................... 1
Background ............................................................................................................................. 1
Study Purpose......................................................................................................................... 3
Study Objectives .................................................................................................................... 3
Research Design..................................................................................................................... 4
2
LITERATURE REVIEW .. ...................................................................................................... 5
Sustainability and Consumer Products .............................................................................. 5
The Electronic Post-consumer Waste Problem ................................................ 6
Extended Producer Responsibility and Product Stewardship ...................................... 8
Global Highlights of E-waste Extended Producer Responsibility .............. 11
Stewardship of Electronic Toys.......................................................................... 19
Mitigation, Adaptation, and Resilience ............................................................................ 20
Transformation and Resilience: Designing a Zero Waste System ............... 22
3
RESEARCH DESIGN ....... .................................................................................................... 25
Stakeholder Selection .......................................................................................................... 26
Data analysis ......................................................................................................................... 28
4
RESULTS AND DISCUSSION .......................................................................................... 30
The Stewardship Case of E-toys in British Comumbia ............................................... 30
E-toy Program Description ................................................................................. 34
iv
CHAPTER
Page
E-toy Program Activities ..................................................................................... 38
Corporate Adaptation to EPR Policy .............................................................................. 41
Extended Producer Responsibility Policy Expansion .................................................. 51
5
CONCLUSIONS .. ................................................................................................................... 54
REFERENCES ....................................................................................................................................... 57
APPENDIX
A
INTERVIEW QUESTIONS .............................................................................................. 69
B
RESEARCH MATRIX ......................................................................................................... 74
BIOGRAPHICAL SKETCH ................................................................................................................ 77
v
LIST OF TABLES
Table
Page
1.
Global State of E-waste Extended Producer Responsibility Regulation.................... 18
2.
Historical Highlights of Extended Producer Responsibility in BC ............................ 33
3.
E-toy Categories Identified in the Recycling Regulation ............................................... 34
4.
Components of a Stewardship Program ......................................................................... 51
5.
Electronic Category Implementation ............................................................................... 53
vi
LIST OF FIGURES
Figure
Page
1.
Global State of E-waste Extended Producer Responsibility Regulation ........... 18
2.
Embeded Single-case Designs (Multiple Units of Analysis) ................................ 25
3.
Stakeholders in the BC E-toy Case ........................................................................... 29
4.
Historical Highlights of Extended Producer Responsibility in BC..................... 31
5.
Components and Responsibilities of Stewardships in BC.................................... 35
6.
E-toy Stewardship System without the EPR Regulation in Place ....................... 37
7.
E-toy Stewardship System with the EPR Regulation in Place .............................. 37
8.
EPRA BC E-waste Collection Network .................................................................. 39
9.
Summary of Learned Lessons for Corporate Adaptation to EPR Policy. ........ 50
10.
Summary of Learned Lessons to Expand EPR Policy ........................................... 52
vii
CHAPTER 1
INTRODUCTION
Background
The world’s human population had never been more numerous than today, it started
growing in the 19th century, as the era of mass production was beginning. In 1800, it was
between 813 and 1,125 million people--six times less than today (US Census Bureau, 2013;
Population Reference Bureau, 2010). After over a century of mass production to meet the
demands of a growing and increasingly affluent world population (World Business Council
for Sustainable Development, 2008), discarded products (post-consumer waste) have
become a huge problem.
Discarded products create long-term problems: for example, plastics, metals, and
other synthetic materials are made from non-renewable resources and are not biodegradable;
electronic products contain toxic ingredients that can leach into and contaminate their
surroundings and infiltrate water sources (Lim and Schoenung, 2010). Electronic waste (ewaste) is not biodegradable, pollutes the landscape, contains toxic materials, and creates an
economic liability for cities. A relatively new concept is now being implemented to solve
these problems by transferring responsibility for post-consumer waste disposal from
municipalities to producers. This concept is called Extended Producer Responsibility (EPR),
a policy strategy intended to recover and dispose of post-consumer waste that becomes
hazardous or that can be recycled. The strategy consists of placing the disposal responsibility
on the producers, which encourage them to design safer, non-hazardous, and more
1
sustainable products that never become waste. The motivation behind EPR, besides
preventing hazardous waste from going into landfills, is to remove the economic burden of
disposal from local governments and place it on to the waste generator: the producers.
Canada has used the concept of EPR as the basis for a number of laws, and British
Columbia (BC) has been a pioneer in implementing EPR policy in North America. The BC
Ministry of the Environment enacted the BC Environmental Management Act Recycling
Regulation (BC Reg. 449/2004) in 2004 to provide for environmentally sustainable disposal
of post-consumer waste. It requires all brand owners, manufacturers, sellers, distributers, and
importers of a set of defined product categories to either create or join an approved
stewardship program to recover and dispose of post-consumer waste. Product categories
now under stewardship include batteries, TV’s, computers, cell phones, thermostats, small
appliances, and smoke detectors, among others.
In 2012, the category of electronic-toys was added to the regulation. This includes all
types and sizes of electric and electronic toys that use a cable, plug, or batteries to provide
power; non-electronic toys are not included in the regulation. In response, the Canadian Toy
Association in British Columbia (CTA BC) created a third-party recycling organization, the
Canadian Brandowner Residual Stewardship Corporation (CBRSC), an exclusive stewardship
program for e-toys. Just one year later, the CBRSC voted to pass its e-toy stewardship
responsibility to the Electronic Products Recycling Association of British Columbia (EPRA
BC) stewardship program; the transfer took effect on August 1, 2013. The reasons for this
2
transfer are analyzed in this study because it provides important lessons about adaptation to
EPR. Some stakeholders involved in the e-toy stewardship program are skeptical about the
program’s benefits because they consider it economically burdensome and not so
environmentally friendly.
Study Purpose
Recycling regulations based on EPR are been imposed globally and they have been
generally applied to post-consumer products that become hazardous waste or that can be
recycled. This study analyzes the implications of applying EPR to electronic toys (e-toys).
This case is singular because e-toys are products that are not commonly considered
hazardous or recyclable; they are not commonly included in EPR regulations. I aimed to
discover what could be learned from this case to generate lessons for strategic corporate
adaptation to EPR recycling regulations that can be applied to other, similar consumer
products elsewhere. Additionally, I aimed to learn how the scope of this policy can be
expanded to include more consumer products.
Study Objectives
Using BC e-toy recycling regulations as a case study, the objectives were: 1) to
identify the key aspects of corporations implementing EPR policy successfully, and 2) to
derive lessons from the case study that can improve the way corporations can implement
EPR with environmental sustainability.
3
To reach these objectives I: 1) summarized the global state of electronic-waste EPR
practice and policy, 2) reviewed additional EPR policies and regulations that have been
applied to toys, 3) summarized research about EPR policy extension and adaptation, 4)
described the context and history of the BC e-toy stewardship case, 5) interviewed strategic
stakeholders in BC e-toy stewardship to identify successes and failures of the BC regulations,
and 6) identified the BC e-toy stewardship program’s future challenges, improvement
opportunities, and the elements essential to its success.
Research Design
Using the case-study method, I conducted a comprehensive literature review and I
interviewed professionals involved in BC’s e-toy stewardship program. Interviewees
represented CBRSC (the first e-toy stewardship program), EPRA (the current e-toy
stewardship program), and a recognized global toy company. The interviews were conducted
by telephone. The questions were oriented towards the interviewee’s insights about and
experiences with the regulation and the stewardship program.
I argue that corporations that know how to adapt to EPR policy can reduce solid and
hazardous post-consumer waste, prevent resource depletion, and prevent the emission of
toxic substances into the environment, while still meeting profitability goals. Lessons from
the e-toy case can be applied to other consumer products.
4
CHAPTER 2
LITERATURE REVIEW
Sustainability and Consumer Products
We humans should not disturb the balance of the environment by depleting the
planet's resources or by discharging more substances than the planet can absorb and process
without harming existing life. Sustainability in general implies that future generations should
have the same opportunities and access to resources as our generation. Sustainable
development “…meets the needs of the present without compromising the ability of future
generations to meet their own needs” (The World Commission and Development, 1987).
However, it seems that we are not doing our part to preserve resources. As the world
population grows, it also grows wealthier, and the culture of consumerism spreads and
intensifies (World Business Council for Sustainable Development, 2008). Production of large
amounts of consumer goods creates large amounts of discarded products (post-consumer
waste) in our current society. A consumer good is any physical commodity that is produced
and subsequently purchased and used by the consumer to satisfy his or her current needs or
desires. Consumer products can be discarded either immediately or after some time,
depending on each particular way of usage. Once consumer goods are discarded they
become post-consumer waste. We keep demanding products, and corporations keep
providing them, with little concern or awareness about post-consumer waste generation and
the environmental problems that come with it, e.g., hazardous materials in the environment,
resource depletion, landscape pollution, and land space lost to landfills. The next section
expands more on these problems.
5
Discarded products (post-consumer waste) are materials that could be recovered or
reincorporated into the manufacturing cycle; however, the majority of this recyclable waste is
sent to landfills (United States Environmental Protection Agency, (USEPA, 2013). In 2012,
the US generated approximately 251 million tons of household waste (USEPA, 2013, pp.
67). This waste is harmful to the environment, squanders non-renewable resources, and
results in the loss of potential economic benefits. If the current recycling system were
improved, the US could add over $20 billion to its GDP annually, and create jobs and
additional economic activity (Jeffery et al., 2014, p.p. 77).
The Electronic Post-consumer Waste Problem
Electronic waste (e-waste) poses particular problems of toxicity and resource
depletion. Its plastic, metal, and electronic components are not biodegradable and can
contain toxic materials that may leach into the environment, concentrate in the soil, and
enter ground-water sources (Lim and Schoenung, 2010). The most toxic chemicals in ewaste are found in their printed wiring boards (Niu & Li, 2007) and batteries. Electronics
also contain valuable materials like copper, aluminum, and gold (Ongondo, Williams &
Cherrett, 2011). When these materials are not recovered for recycling, we need to extract
more of them as virgin materials to produce more products; this depletes non-renewable
resources (United States Environmental Protection Agency, 2011; Neelis et al., 2008; Roes et
al., 2007; Pietrini et al., 2007). Plastic from e-waste is not typically recycled because it
potentially contains toxic substances like flame retardants, and its contact with toxic
materials from the electronic components makes it unsafe for new products, so recycling is
6
not economically advantageous (Nakajima & Vanderburg, 2005; Mansfield, 2013). Various
industries have begun to cooperate to develop best practices for including recycled plastic
from electronics in the manufacture of new goods (Leif, 2014).
In addition to the impacts above, e-waste generates greenhouse gas (GHG)
emissions during waste transportation and incineration (Tabasová et al., 2012; Vidal,
Martinez, & Garrain, 2009; European Union, 2011), harms human health when it is
disassembled or burned improperly (Dlamini et al., 2011; Foolmaun & Ramjeeawon, 2013),
contributes to loss of land to landfill use (Hopewell et al., 2009), and litters natural habitats,
thereby contributing to biodiversity loss (Cierjacks et al., 2012; Costa et al., 2010; Barnes et
al., 2009; Teuten et al., 2009).
Governments around the world have found a way to deal with e-waste though
Extended Producer Responsibility, a policy strategy that places the responsibility of postconsumer e-waste recovery and disposal on producers and manufacturers. This strategy
provides two main advantages: 1) to switch the disposal cost from municipalities to
producers, and 2) to prevent hazardous or recyclable waste from ending up in landfills. The
following two sections explain this concept from its origins to its current application on a
global scale.
7
Extended Producer Responsibility and Product Stewardship
The roots of Extended Producer Responsibility (EPR) are found in corporate social
responsibility. Corporate social responsibility (CSR) has been discussed in the literature for
the past fifty years. Corporations have learned that they cannot make sustainable profits
without paying attention to social concerns (Carroll, 1999), so they have progressed from
being profit-seekers only to being more concerned about social issues (e.g., workers’ health
and rights, community issues, gender and racial discrimination, and child labor).
CSR issues are not the only ones of concern to corporations; they are also concerned
about environmental issues. Since the industrial revolution, corporations have provided
consumer products in exchange for money. Because this production-consumption dynamic
became massive in the last few centuries, corporations, together with governments and
consumers, have created unintended but still major environmental impacts, like ozone
depletion, excessive accumulation of CO2 in the atmosphere, and soil and water
contamination around manufacturing facilities. These are major disturbances to our
environmental system that cause externalities to people. Externalities are unperceived or
unpredicted side effects or consequences of industrial activities that affect parties other than
the industry, and whose costs are not included in the cost of production. Some corporations,
governments, and people are trying to change their behavior so that the environment is less
affected by their activities. Nowadays, either driven by regulatory obligations or by voluntary
initiatives, corporations are going beyond social responsibility to extended producer
responsibility.
8
Extended producer responsibility (EPR) is a policy strategy to relocate the
externalities caused by post-consumer waste disposal from municipalities to producers; it is
implemented through administrative, economic, and informative instruments (Lindhqvist,
2000; Tojo, 2008). EPR holds corporations financially responsible for their products across
the full product life cycle, and especially for the take-back, recycling, and final disposal of
products (Nakajima & Vanderburg, 2005). An important goal of EPR is to encourage
corporations to eco-design their products to improve their environmental sustainability
during the full life cycle, especially at disposal, i.e., to design products that are easier to reuse
or recover, more environmentally friendly to dispose of, and to take responsibility for the
impacts that cannot be eliminated by design, like post-consumer waste (Organisation for
Economic Co-operation and Development (OECD), 2006; Lifeset & Lindhqvist, 2008;
Atasu & Subramanian, 2012).
Product stewardship (PS) implies a responsibility for sustainable development that
should be shared by all the actors involved in a product’s life cycle. PS is a concept that is
frequently attached to EPR, and it has proven to align economic development to EPR by
involving different stakeholders who share the responsibility or provide expertise in the
disposal of the post-consumer product. PS can be either voluntary or required by law. It has
the same goals as EPR, and while the producer still has the greatest stewardship
responsibility, other stakeholders, such as suppliers, retailers, and consumers, also play
important roles (Product Stewardship Institute, 2001). Hewlett Packard has taken
responsibility for PS by creating its own take-back product program for collecting and
9
remanufacturing ink and toner cartridges. In coordination with other stakeholders like
Staples and FedEx, it has produced approximately 1.5 billion products that contain recycled
materials from its closed-loop program (HP, 2014). Another example of PS is the subject of
this study. The Canadian Toy Association created a PS program by joining EPRA BC, a
third-party organization that, in exchange of a fee, takes over the collection and end-of-life
process of electronic toys (e-toys) on behalf of producers who comply with the e-toy
recycling policy. EPRA BC operates with 1,666 manufacturers, retailers, and other industry
stewards within the province (EPRA BC, 2014). In BC, EPR is also seen as “industry
product stewardship,” but there is no distinction between EPR and PS under the BC Reg.
449/2004 regulation. In this document, I make no differentiation between EPR and PS and
I refer to both as EPR.
In summary, EPR increases the environmental responsibility of economic actors,
promotes technological innovation, reduces pollution, promotes product and packaging
ecodesign, reduces resource consumption, diverts waste from landfills, reduces wastehandling problems, redistributes product costs, shifts and integrates disposal costs in a
market economy, and increases jobs (Kroepelien, 2000; Product Management Alliance,
2012). EPR policies are being adopted rapidly in developed countries and more consumer
products are included under the EPR umbrella every year. In the United States, 110 state
EPR laws were enacted from 1991 to 2011 (Nash & Bosso, 2013).
10
There is no global consensus on how EPR policy should be applied; implementation
ultimately depends on the political style of each government. EPR policy can be
implemented through a single approach or a combination of different approaches, some
examples of which are: 1) fees applied to consumers for post-consumer waste disposal at
point of sale or at point of product return, 2) fees applied to producers for post-consumer
waste handling and processing, sometimes requiring producers to submit detailed
stewardship plans for government approval, 3) requirements that producers provide financial
incentives to consumers or contractors to return used products for recycling or proper
disposal, 4) specific performance targets, and 5) penalties or fees charged to noncompliant
manufacturers (Nash & Bosso, 2013; Federal Office for the Environment (FOEN), 2014;
Nakajima & Vanderburg, 2005).
Global Highlights of E-waste Extended Producer Responsibility
Many countries have implemented Extended Producer Responsibility (EPR)
regulations to prevent e-waste from ending up in landfills, especially in Western Europe and
North America, with the exception of Mexico. Some countries in Central and South
America, including Costa Rica, Colombia, Peru, Brazil, and Chile, have taken steps in this
direction as well; they have initiatives to approve EPR regulations for e-waste. This section
provides a global overview of EPR practice.
EPR policies diverge principally on whether they place responsibility for postconsumer product disposal on the consumer or the producer, although at the end of the day,
11
either way the cost is reflected in the product price. Some policies place the responsibility for
e-waste disposal on the consumer by including a disposal tax fee in the electronic product’s
purchase price (ETC, 2012; Munoz et al., 2008).
North America
In 2009, Canada created a nationwide Action Plan (CAP) to implement EPR policies.
The Canadian Council of Ministers of the Environment (CCME) helps Canadian provinces
to implement EPR in a coordinated way (Canadian Council of Ministers of the
Environment, CCME, 2009). The EPR model normally consists of a province-wide
stewardship plan for taking post-consumer products back, recycling them, and collecting
fees from producers to fund the take-back and recycling activities. As of July 2014, Alberta
(2004), British Columbia (2007), Manitoba (2011), Nova Scotia (2008), Ontario (2009),
Prince Edward Island (2009), Quebec (2008), and Saskatchewan (2007) have adopted EPR
policy for e-waste (Miller, Barr, & Hsueh, 2010; Davis LLP, 2012). The e-waste stewardship
operators in Canada are EPRA, Alberta Recycling Management Authority (ARMA), and
Ontario Electronic Stewardship (OES) (EPRA, 2014).
In the United States, starting with California in 2005, 24 states have enacted EPR
policy for electronic products (Product Management Alliance, 2012). The US model of EPR
is not nationally coordinated; each state creates its own e-waste regulations. In Mexico,
electronic waste is considered to be a category of waste requiring “special management,” but
there is no legislation that requires producers to be responsible for managing post-consumer
12
products. The Law for the Prevention and Management of Waste (Ley General para la
Prevención y Gestión Integral de los Residuos) aims to divert “special waste” (including e-waste)
from landfills, but it does not provide guidelines for e-waste reduction, reuse, take-back, or
recycling (Honorable Camara de Diputados, 2014).
Central and South America
In 2010 Costa Rica, with help from the German Federal Ministry for Economic
Cooperation and Development (BMZ), approved EPR regulation. It passed the 35933-S
electronic recycling regulation (Reglamento para la Gestión Integral de Residuos Electrónicos), which
obliges electronic corporations to operate in the country in partnership with a governmentapproved third-party steward (Medina, 2012). ASEGIRE is an example of an approved third
party steward that provides take-back infrastructure and environmental disposal services for
e-waste in Costa Rica (ASEGIRE, n.d.). In 2013, Ecuador approved the agreement Nº 190
Post-consumption of Electrical and Electronic Equipment in Disuse (Política Nacional de Postconsumo de Equipos Eléctricos y Electrónicos en Desuso), which is based on EPR and also promotes
participation from the government and citizens (FAOLEX, 2013).
Colombia approved the EPR law No. 1672 in 2013, which establishes guidelines for
a comprehensive public policy for Waste Electrical and Electronic Equipment (WEEE)
management. Some Colombian e-waste management companies available are Fundambiente,
E-WasteSolutions SAS, Ocade, Belmont Colombia, E cycling, CI Recyclables SA, Gaia
Vitare Ltda, and Lito Ltda (RELAC, 2013a).
13
In 2012, Brazil included e-waste management in its National Law on Solid Residues
Nº. 12.305. This law includes guidelines for collecting and disposing of e-waste. Some of the
approved e-waste management companies are Ativa Reciclagem, Cimiela, Lorene, Oxil,
RESTEC, Suzaquim, TGC Recycling (Energy Press, 2011; RELAC, 2013d). Peru, in
cooperation with the Swiss government, developed an electronic waste management
regulation that was made law in 2012 (Coperacion Suiza en Peru, n.d.). Regulation 001-2012MINAM (Reglamento Nacional para la Gestión y Manejo de los Residuos de Aparatos Eléctricos y
Electrónicos) gives disposal responsibilities to producers, waste handlers, consumers, and local
governments (Sistema Nacional de Informacion Ambiental, 2012). Peru has some way to go
to set up the necessary infrastructure to take back electronics (Perú Green Recycling, 2013),
but some e-waste management companies currently available are Grupo Salaverry, San
Antonio Recycling, AKSTARCOM, COMIMTEL, and Brunner E.I.R.L (RELAC, 2013b).
Through a joint technical and economic agreement, the Chilean government and the
German Organization for Technical Cooperation (GTZ) developed an EPR recycling
regulation in Chile. This regulation is pending approval and will cover lubricant oil,
packaging, batteries, medications, vehicles, pesticides, printed paper, tires, and electronics
(Ministerio del Medio Ambiente, 2013). The government will set recycling goals that must be
met by the companies that produce these products.
In Argentina, the government in Buenos Aires approved municipal legislation on
management of disused electronic devices in 2008 (Medidas Para la Gestión de Aparatos
14
Electrónicos en Desuso) Law 2807/LCBA/08. The law only included electronic waste from
government offices and did not contain EPR elements, but it was the first step to regulate
electronic post-consumer waste in Argentina. Since 2013, a national initiative on Waste
Electric and Electronic Equipment Management (Gestión de Residuos de Aparatos Eléctricos y
Electrónicos) has been under discussion in the senate. Currently there are six companies and
five cooperatives that provide e-waste disposal services. The companies are: Silkers,
Industrias Dalafer, Scrap, Rezagos, Protea, and Computrash. The cooperatives are: Va de
Vuelta Asociación Civil, Fundación Compañía Social Equidad, Centro Basura Cero, Reciclando Sueños
Cooperativa de Cartoneros, and Cooperativa la Toma del Sur (RELAC, 2013e).
Europe
In 2002, the European Commission released the Waste Electrical and Electronic
Equipment (WEEE) Directive to reduce waste and prevent pollution. WEEE is based on
EPR principles and aims to prevent disposal of toxic waste into the environment. WEEE is
the term used by the European Commission for “equipment which is dependent on electric
currents or electromagnetic fields in order to work properly and equipment for the
generation, transfer and measurement of such currents and fields” (European Commission,
2014).
The WEEE directive requires each European Union country member to implement
the directive within their national laws according to their own process of implementation.
For instance, in the Netherlands, producers pay for the disposal of their electronic products,
15
and product stewardship is managed by a third party, ICT Mileu. In Belgium, producers,
importers, and consumers of electronic equipment pay a fee to the product-stewardship
operator, Recupel, to cover the administration, collection, and processing cost of these
products. The fees are charged when the products are brought into the Belgian market and
at the time of product purchase (Nakajima & Vanderburg, 2005; Recupel, 2014).
Switzerland has had laws governing disposal of e-waste since the mid-1980s, before
the WEEE directive came into being (FOEN, 2014). Its EPR legislation, “Ordinance on the
Return, Taking Back and Disposal of Electrical and Electronic Equipment (ORDEE),”
came into force in 1998 (Khetriwal, Kraeuchi, & Widmer, 2009). In the Swiss model, which
was also implemented before WEEE, consumers pay an extra fee for disposal at the time the
product is purchased, and the e-waste operators are Switzerland Foundation for Waste
Management, Swiss Lighting Recycling Foundation, and Swico (Wang, 2013. pp. 439).
Norway was also an early adopter of EPR regulations for e-waste. In 1999, the
Scrapped Electrical and Electronic Products regulation was enacted to support the Pollution
Control Act and the Product Control Act (Lee & Røine, 2004).
Asia-Pacific
Japan has enacted EPR legislation since 1998. The laws make several parties-citizens, corporations, and governments--responsible for product disposal, but the biggest
portion of the economic responsibility lies on citizens (Ogushi & Kandlikar, 2007; Ministry
16
of the Environment Government of Japan, n.d.). The Home Appliances Recycling Law went
into effect in 2001. It requires citizens to pay fees of $16-$61 USD at the time of disposal,
the downside of which is that these fees encourage illegal dumping of post-consumer
electronics (The Economist, 200; INFORM, 2013). The disposal fees for products like
automobiles and computers are included in the product purchase price (Ogushi & Kandlikar,
2007).
In China, there is a special regulation to recover e-waste, called “China WEEE.”
Manufacturers can take advantage of government subsidies to build recycling facilities, but
the most recent version of this regulation places greater financial responsibility on
government instead of manufacturers (Tong & Yang, 2013). South Korea approved the Act
on Resource Circulation of Electric and Electronic Products and Vehicles in 2007. This
regulation is based on EPR and promotes recycling of e-waste and vehicles (Ng, 2013). India
implemented its E-waste Management and Handling Rules in 2012 (Rathoure, 2014).
Australia implemented its Product Stewardship Act in 2011, which covers batteries,
computers, and large electronics, among other items (Australian Government Department of
the Environment, 2009).
Africa
South Africa and Nigeria are leading efforts in Africa to implement e-waste
regulations based on EPR; they are also influencing Ghana, Kenya, Uganda, and Ethiopia to
create their EPR legislation for e-waste (Rathoure, 2014).
17
Table 1: Global State of E-waste Extended Producer Responsibility Regulation
Country
Switzerland
Japan
EPR E-waste Legislation
Ordinance on the Return, Taking Back, and Disposal of Electrical and Electronic
Equipment
Home Appliance Recycling Law
Norway
Scrapped Electrical and Electronic Products
Enacted 1998,
Enforced 2001
1999
European Union
Waste Electrical and Electronic Equipment Directive
2002
United States
Local Regulations (24 States)
2005
Canada
Local Regulations (8 Provinces)
2006
China
China Waste Electrical and Electronic Equipment
2009
Costa Rica
Comprehensive Management of Electronic Waste Regulation
2010
Australia
Product Stewardship Act
2011
Brazil
National Law on Solid Residues
2012
Peru
Management and Operation of Waste Electrical and Electronic Equipment Regulation
2012
India
Ecuador
E-waste Management and Handling Rules
Post-consumption of Electrical and Electronic Equipment in Disuse
2012
2013
Colombia
Waste Electrical and Electronic Equipment Management
2013
Argentina
Electric and Electronic Equipment Management
Bill sent to the
Senate in 2013
Chile
Bill for Waste Management and Extended Producer Responsibility
Bill sent to
Parliament 2013
Source: Author’s research
Figure 1: Global state of e-waste Extended Producer Responsibility regulation.
Source: Author’s research
18
Date Passed
1998
Stewardship of Electronic Toys
The future of toys seems to be electronic. Many traditional toys, like board games,
building sets, dolls, plush, and figures are now electronic or at least require batteries to
operate. Digital technology is changing at a rapid pace and electronic toys (e-toys) become
obsolete or out-of-fashion quickly. The demand for e-toys is fast increasing, and so is e-toy
waste (Fullana et al., 2008); e-toy sales in the US grew 32% from 2012 to 2013 (TIA, 2014).
In Europe, toys are included in the WEEE regulation under categories 6 and 7 (small
electronics and big electronics). Most e-toys are regulated under the category of small
electronics but they have low collection rates (Sole et al., 2012), and generally are not subject
to special stewardship programs. However, in Spain, the Generalitat de Catalunya funded
“ecojoguina,” a program for e-toy ecodesign that aims to produce environmentally friendly
toys and to be more competitive against Asian toy manufacturers; complementarily, the
project “r-ciclejoguina” aims to improve collection and recycling of post-consumer e-toys
(Agencia de Residus de Catalunya & Generalitat de Catalunya, 2008). These projects are
voluntary initiatives, and are not required by the WEEE legislation.
Some aspects of e-toys that make them different from other electronic waste (ewaste) are: 1) e-toy recycling can be challenging because toys are composed of a wide variety
of materials and are designed to be difficult to disassemble in order to make play with them
safe; 2) the materials recovered have little value in the current recycling markets;
approximately 72% of an e-toy is made of PP, PS, or ABS plastic, 12% of electric and
19
electronic components, 5% of metals, and 11% of other materials (CBRSC, personal
communication, June 4, 2013; Pérez-Belis, Bovea, & Gómez, 2013); and 3) the content of
hazardous substance in e-toys is below the limit defined in the Restriction of Hazardous
Substances (RoHS) directive, which was originated in the European Union in 2002 and
restricts the use of hazardous materials in electrical and electronic products (Pérez-Belis,
Bovea, & Gómez, 2013). The outcomes of “ecojoguina” and “r-ciclejoguina”projects suggest
that the key to improve the end of life of e-toys is eco-design (Pérez-Belis, Bovea, & Gómez,
2013). The following section discusses the importance of eco-design to achieve better
environmental results for post-consumer product disposal, and it uses the concept of
resilience to explain how eco-design and zero-waste thinking can be used as long-term
strategies to prevent post-consumer waste and to adapt to the above identified long-term
environmental impacts.
Mitigation, Adaptation, and Resilience
The term resilience is used in the natural sciences to refer to how natural systems
change and adjust in response to external perturbations without losing their ability to return
to their original state (Walker et al., 2004; Korhonen & Seager, 2008; Folke et al., 2010).
From the economic perspective, Milton and Rose Friedman (1982) describe the essence of
resiliency: “Only a crisis, real or perceived, produces real change.” Corporations can use
resiliency theory as a basis for strategy to avoid or minimize diverse environmental risks
(Beermann, 2010), including climate change, resource depletion, landscape pollution, land
loss, and toxicity in the environment.
20
The concepts of adaptability and transformability are central to resilience theory.
Adaptability is the capacity to adjust to new circumstances or changes, while transformability
involves a complete change into a new or different thing. Korhonen & Seager (2008) suggest
that a system cannot be capable of adapting to external disturbance unless it can transform
internally. Corporations need to transform internally to adapt to external change.
Traditionally, corporations have used a mix of risk assessment, mitigation, and optimization
strategies in their systems to survive to external change, but in the long term, it is uncertain
that these strategies will be adequate for surviving major environmental changes like global
warming (Korhonen & Seager, 2008).
Eco-efficiency is one of the most-used mitigation and optimization strategies in the
manufacturing sector. Eco-efficiency practices help to increase productivity by reducing
costs and by improving a product’s environmental performance throughout design, sourcing,
manufacturing, packaging, and distribution to the end of use (Montgomery, 1997; Brunett &
Hansen, 2008). Eco-efficiency practices are applied to ensure the most efficient use of
resources in the whole life cycle. Practices include lean manufacturing, waste minimization,
reuse, technology improvements that reduce material or energy use, and increasing the use of
renewable energy to reduce use of fossil fuels (Korhonen & Seager, 2008). Two examples of
eco-efficiency are reducing the product’s weight by using less material, and incorporating
recycled materials into products to avoid resource depletion.
21
Increasing collection and improving the treatment of post-consumer waste are two
immediate solutions to ensure efficient use of land (by avoiding the use of landfills) and to
decrease the use of non-renewable resources (by recycling) in the short term (Huisman,
2013). However, the post-consumer waste problem won’t be solved in the long term merely
by using corrective strategies. Corporations need to transform within to be resilient in the
long term and to be able to be profitable despite changes in the environment, e.g., changes in
the supply of raw materials due to resource depletion. By implementing long-term
transformation strategies in the present, corporations can build competitive advantages in
the future. The following section describes two examples of these transformation strategies.
Transformation and Resilience: Designing a Zero Waste System
Design for the environment and sustainability (DfES) and zero waste are strategies
that imply transformation within corporations. In some cases, these strategies can bring
immediate profits to the company, but in other cases they may seem inefficient because
changes that these strategies require may necessitate additional expenditures without rapid
return of investment. However, these strategies can increase resilience to major external
environmental changes in the long term (Korhonen & Seager, 2008).
Design for the Environment and Sustainability (Eco-design)
In the last century, many electronic products have been designed deliberately for
obsolescence (Slade, 2006), and this has contributed to the electronic post-consumer waste
problem. Design for the environment and sustainability (DfES) can improve adaptation to
22
Extended Producer Responsibility (EPR) policies aimed to prevent post-consumer waste.
DfES is used to produce more environmentally friendly and socially responsible products
during all their life-cycle stages. The choices made during the design stage impact 70-80% of
the life-cycle cost of production and product environmental impact (Montgomery, 1997).
Some aspects that should be considered in DfES are: material selection and combination,
energy use, product delivery, use phase, reuse, and end of life (Armstrong, 1997; Graedel &
Allenby, 2011). The redesign should provide the same benefits that the original product
offered, but it must do so by reducing the use of resources and energy, and by preventing
the generation of waste over the whole life cycle (Armstrong, 1997).
DfES is also known as eco-design. An eco-designed product for end of life should
be either durable, easy to recycle, or designed to biodegrade, depending on its usage;
choosing which route to take requires a good understanding of environmental tradeoffs
when making design decisions. The European Union released a directive for eco-design
targeting large electronic products like electric motors, dishwashers, fans, washing machines,
and refrigerators (European Commission, 2009). The 2012 evaluation of this policy
concluded that it produced substantial environmental benefits; however, the EU decided not
to expand the scope to more products because of lack of data to evaluate the full
consequences of this decision (European Commission, 2012).
23
Zero Waste
Zero waste aims for more than reducing the use of resources and minimizing waste
streams through recycling. Zero waste is based on the idea that “if the community cannot
reuse, repair, recycle or compost it, industry should not be making it” (Connett, 2006). In
order to achieve zero waste, industries and communities must have a set of attitudes and
lifestyles that emulate natural cycles, with all discarded materials designed to be useful for
other organisms (Zero Waste International Alliance, 2009). Biomimicry is a concept that is
useful to achieve these goals; it looks to nature in its search for designs and processes that
can solve some of our environmental problems (Schroeter, 2010). Biomimicry imitates the
ways in which living plants and animals solve their problems (Vepa, 2013). In nature, there is
no garbage because one organism’s waste is useful to others. Zero waste requires
corporations to take responsibility for products that become waste, encourages them to
design better products, and encourages communities to take responsibility for their way of
consumption and disposal (Zero Waste International Alliance, 2013).
24
CHAPTER 3
RESEARCH DESIGN
I conducted exploratory case-study research in the Province of British Columbia,
Canada. My analysis of the BC e-toy stewardship program experience provided a foundation
on which to develop suggestions for corporate strategies to adapt to Extended Producer
Responsibility (EPR) recycling regulations. The research was designed as a single case study
with multiple units of analysis. The units were the organizations involved in the BC e-toy
stewardship case. Figure 2 illustrates the selected case-study typology (Yin, 2003, pp. 40).
The rationale for selecting this typology was the unique characteristics of the case, that is,
toys are not commonly included in EPR regulations.
Figure 2: Embedded single-case designs (multiple units of analysis).
Source: COSMOS Corporation cited in Yin (2003, pp. 40)
To incorporate the insights of each organization involved in the program without
losing a holistic perspective, I used process modeling to describe how events and decisions
have been made over time throughout the policy implementation process.
25
I studied extended producer responsibility and product-stewardship principles to
understand the drivers and objectives of the recycling regulation (BC Reg. 132/2011). I
reviewed the literature on policy, regulations, and the practices of e-waste and e-toy recovery
and disposal, as well as the literature on EPR policy extension and adaptation, to find out
how EPR has been established in other countries.
I complemented this research with interviews with relevant stakeholders involved in
the BC stewardship program. The interviews were guided telephone conversations in an
unstructured format, using the framework proposed by Alvesson (2003). The framework
uses neopositivist, romantic, and localist methods. I formulated 60 interview questions
(Appendix 1), which I posed to three key stakeholders. Their responses helped me to answer
the two main research questions: “How can corporations adapt to EPR policy?” and “How
can EPR policy be expanded to a broader scope of product categories?”
Stakeholder Selection
I interviewed one person from the Canadian Brandowner Residual Stewardship
Corporation (CBRSC) and one from a prominent global toy corporation as preliminary
research for selecting relevant stakeholders to interview. I chose these interviewees because
they were closely involved with the CBRSC stewardship program, which was the first
program designed for e-toys in BC. Information from these interviews helped me to expand
my literature review, to design my interview questions, and to select the most appropriate
people for the main interviews.
26
The organizations involved in the BC case were the units of analysis, which are
shown in Figure 3 and ranked by their level of influence on the BC recycling policy. With the
exception of consumers and retailers, I selected a professional from each unit of analysis
who was deeply involved in the BC e-toy program to interview. Because e-toy take-back
retailers now operate under the Electronic Products Recycling Association of British
Columbia’s (EPRA BC) management, I used information from my EPRA BC interviewee
and from the literature to represent their unit in the case study. I excluded consumers from
the study because studying consumer behavior is a field of its own.
The interviews were conducted by telephone, recorded, and transcribed between
March and July of 2014. The questions sought information about how the e-toy stewardship
program was designed and applied, and about its current development, economic challenges,
and plans for future action. I interviewed one relevant stakeholder from each of the three
units: the toy industry, CBRSC, and EPRA BC. A fourth stakeholder I had planned to
interview from the BC Ministry of the Environment (BC MOE) was unable to participate.
The main challenge faced during this research was to get participation from additional
toy corporations and from the BC MOE. Even though during the first contact these
stakeholders demonstrated willingness to participate, the interviews never took place. Thus,
the research questions I hoped to answer with their input were answered using literature
review and the insights of the stakeholders who did participate in the interviews.
27
Data analysis
Data collection, data analysis and coding were conducted simultaneously. The interview
recordings were transcribed in an all-inclusive code, i.e., accounting for all the responses
without exception. After a thorough review of the literature, I created a list of basic
components of a stewardship program to identify the essential elements for program success
(Lindhqvist et al., 2008, pp.8; CBRSC, 2011). These components are presented in Table 4.
Additionally, using a matrix and based on personal insights gained from the interviews, I
grouped the 60 interview questions into 23 category groups (Appendix 2). Then I compared
interview responses with the basic components of a stewardship program shown in Table 4.
This enabled me to answer the two main research questions and to create theoretical
guidelines for how corporations can adapt to stewardship program regulations that are based
on the concept of EPR. The matrix used to link methods with questions is provided in
Appendix 2, which shows how each group of questions helped to answer the two main
research questions. I associated these guidelines with theories of resilience to show how toy
corporations can change and adapt to EPR regulation though internal and external
transformation, to be resilient to environmental perturbations in the long term.
28
Figure 3: Stakeholders in the BC e-toy case.
Source: Author
29
CHAPTER 4
RESULTS AND DISCUSSION
The Case of E-toy Stewardship in British Columbia
The BC Environmental Management Act Recycling Regulation enacted in 2004 (BC
Reg. 449/2004) replaced all previous regulations attempting to solve the post-consumer
waste problem. It aimed to divert e-waste from landfills to be disposed of in an
environmentally friendly way. Figure 4 shows how post-consumer waste regulations evolved
from their beginning in the 70s to today, and Table 2 presents this information in more
detail. The 2004 recycling regulation mandates that a stewardship program will manage the
recovery and disposal of certain kinds of post-consumer products. Categories of products
were added to the regulation periodically, and the province made the commitment to add
products to these categories every two years (CBRSC, personal communication, April 17,
2014). The categories include paint, pesticides, solvents, pharmaceuticals, beverage
containers, lubricating oil, tires, electronics, lighting equipment, paper, and others. E-toys
were added to the list in July 2012.
The recycling regulation obliges all e-toy brand owners and sellers (i.e., toy
manufacturers, importers, and retailers) to comply with a government-approved productstewardship plan or program (British Columbia Laws, 2012). Therefore, all entities that
produce or sell e-toys in BC must join or create a government approved stewardship
program to recover and dispose of e-toys after they are discarded by the consumer.
Stewardship-program operators are responsible for activities such as public consultation,
30
program administration, capital procurement, reporting, auditing, providing collection
infrastructure, organizing transportation logistics, processing and recycling, producing and
communicating data and information, and educating the public.
Figure 4: Historical highlights of Extended Producer Responsibility in BC.
Source: Author’s research
The British Columbia Ministry of the Environment (BC MOE) defines e-toys as
“electronic or electrical toys, including, without limitation, trains, car racing sets, cars and
trucks, including remote control and ride on toys, video games and video gaming equipment
and consoles” (British Columbia Laws, 2012, section 3.2, schedule 3). The Electronic
31
Products Recycling Association of British Columbia (EPRA BC) (2014) defines e-toys as: “a
plaything placed on the market that uses a cable, plug or batteries to provide power.” These
definitions include all types and sizes of electric and electronic toys. The e-toy stewardship
program identified four categories of e-toys, which are described in Table 3.
To comply with the regulation, the Canadian Brandowner Residual Stewardship
Corporation (CBRSC) developed an e-toy stewardship program for the Canadian Toy
Association in British Columbia (CTA BC). This plan was launched in July 2012 (CBRSC,
2012). Initially, toy stakeholders decided to create a separate stewardship program for e-toys
instead of joining an existing e-waste program, for a couple of reasons. First, none of the
existing programs for similar categories (small appliances and electronics) agreed to include
e-toys in their systems because they did not know the volumes and implications of including
these types of products in their programs (Toy Corporation, personal communication,
March 27, 2014; CBRSC, personal communication, April 17, 2014).
After a two-year pilot stewardship program, the CBRSC and the Canadian Toy
Association joined EPRA BC, a stewardship program for all regulated waste in the province.
In April 2013, the CBRSC voted to pass their e-toy stewardship responsibility to the EPRA
BC program; the BC MOE approved this transfer of responsibility in May 2013 and it took
effect on August 1, 2013. The CBRSC is now dissolved. Table 2 shows this transition in
more detail.
32
Table 2: History of Extended Producer Responsibility in British Columbia
Date
1970
1980
1990
1993
2002
Oct-2004
Feb-2006
Mar-2006
Oct-2006
Dec-2006
Aug-2007
Aug-2007
Sep-2009
Apr-2010
Jul-2010
Oct-2010
Dec-2011
Jul-2012
Apr-2013
May-2013
Aug-2013
May-2014
Event
BC implements a mandatory return program for soft drink and beer containers.
Awareness that household products contribute to environmental pollution grows in BC.
BC introduces a recycling program managed by government for tires and lead-acid batteries, funded
with taxes paid by retailers.
The BC Waste Reduction Commission recommends an approach to managing household hazardous
waste (HHW) that would shift responsibility from general taxpayers to producers of household
hazardous products.
BC MOE releases the Industry Product Stewardship Business Plan, which considers end-of-life
products the responsibility of producers and consumers rather than the general taxpayer.
BC Environmental Management Act Recycling Regulation is enacted. It replaces previous
regulations dating back to 1971, shifts to results-based, extended producer responsibility, and
replaces the Beverage Container Product Stewardship Program Regulation and Post-Consumer
Residual Stewardship Program Regulation. Producers are given 2 years to amend existing plans.
The Electronic and Electrical Product Category is added to the Recycling Regulation. It includes
computers, small appliances, power tools, cell phones, batteries, and light bulbs.
A schedule for the Tire Product Category is added (en. BC Reg. 65/2006, s. 5.).
The original e-waste stewardship plan is submitted to the BC Ministry of Environment. All existing
stewardship agencies submit amended plans to meet the new Recycling Regulation’s requirements.
The original Stewardship Plan (the “Plan”) is approved by the BC Ministry of Environment (MOE).
The Electronics Stewardship Association of BC (ESABC) launches a province-wide electronics
stewardship program. The original stewardship plan commences operation. It was established
under the British Columbia Society Act to develop, implement, and manage an approved
stewardship program designed to allow obligated electronics producers to meet their regulatory
obligations under the British Columbia Recycling Regulation.
The electronic stewardship program officially launches with Phase I products (TVs, computers,
computer peripherals, and printers).
The original stewardship plan is amended to include Residual Product Categories.
The plan is amended to include Beverage Container Product Category.
The Program expands to include Phase II products (information technology and
telecommunications equipment, small appliances, audio/visual playbacks and recording systems,
lighting equipment, toys, leisure and sports equipment, and monitoring and control instruments).
The CBRSC, in partnership with the Canadian Toys Association and consultants from Sustainability
Services, launches a pilot project for recovery of electronic toys.
Responsibility for the electrical and electronics collection and management program operated
under the approved ESABC stewardship plan is shifted to the newly formed Electronics Product
Recycling Association (EPRA).
EPRA’s scope of e-waste is expanded; now it provides services for individual consumers and
businesses obligated in Phase IV products (large appliances, electronic tools, electronic cash
dispensing appliances, and electronic medical devices). The Canadian Toy Association in partnership
with the Canadian Brandowner Residuals Stewardship Corporation launches the Stewardship Plan
for Electronic Toys.
The CBRSC votes to pass its e-toy stewardship responsibility to the Electronic Products Recycling
Association of British Columbia (EPRA BC) stewardship program.
The BC MOE approves transfer of e-toy stewardship responsibility.
EPRA BC e-toy stewardship program begins.
The BC MOE launches the packaging and printed–paper recycling program (PPP), which manages
residential PPP waste and gives the disposal responsibility to businesses instead of municipal
government and taxpayers.
Source: Author’s research
33
Table 3: E-toy Categories Identified in the BC Recycling Regulation
No.
Category
EPRA’s Fee
(CAD)
$0.05
1
Micro e-toys that weigh under 100 g
2
Non ride-on e-toys that weigh over
100 g and require batteries of less
than 12 volts
$0.40
3
Non ride-on e-toys that weigh over
100 g and require batteries of 12
volts or more
$1.20
4
Ride-on e-toys
$5.50
Example
Source: LEGO
Source: Mini In The Box
Source: Amazon
Source: Amazon
Source: Information from EPRA BC technical product listing 2014 and author’s research
E-toy Program Description
According to the BC MOE (2011), a stewardship plan requires producers to define
their program objectives, describe how they will collect and manage their designated postconsumer products, and define how they will measure their performance. Figure 5 shows the
basic components of a stewardship plan and the responsibilities of program operators.
34
Figure 5: Components and responsibilities of stewardships in BC.
Source: Adapted from the BC Ministry of the Environment webpage
E-toys Life Cycle
E-toys are made of plastics, rubber, cardboard, wood, textiles, metals, wires,
batteries, circuit boards, and other electronic components. Approximately 72% of an e-toy is
made of PP, PS, or ABS plastic, 12% of electric and electronic components, 5% of metals,
and 11% of other materials. The content of hazardous substance in e-toys is below the limit
defined in the Restriction of Hazardous Substances (RoHS) directive, which was originated
in the European Union in 2002 and restricts the use of hazardous materials in electrical and
electronic products (Pérez-Belis, Bovea, & Gómez, 2013).
The life cycle of e-toys starts with raw material extraction, during which all of the
minerals, fossil fuels, metals, woods and wood-derived materials, water, and other material
35
resources required to produce the toys are extracted from the biosphere to be processed
(inputs). All of these extracted resources are then transported, processed, and converted into
final products using energy, electricity, and more embedded resources. During each of these
stages, wastes and emissions are released into the biosphere (outputs) (Jensen et al., 1997).
These processes are simplified in Figure 6 under the blue box labelled “E-toy Corporations.”
Figure 7 uses a life-cycle approach to represent the BC e-toy stewardship system; each
stakeholder is composed of a group of organizations that share the same interests in the
system and each of them belongs to a different stage in the life cycle of the e-toy.
Figure 6 represents the system without the e-toy recycling policy in place. In this
system, all the post-consumer e-toy waste ends up in landfills and there is no additional
economic activity generated by the activities required by the regulation. Figure 7 shows all
the activity generated with the EPR regulation. The BC MOE created the recycling policy to
be followed by e-toy stakeholders. EPRA BC maintains a stewardship contract with the
stakeholders; its stewardship plan has been approved by the BC MOE. EPRA BC provides
feedback to BC MOE through its annual report. These relationships are represented by the
blue-dotted communication flows between these stakeholders. The straight black flows
represent the e-toys that are produced, exhibited, sold, and eventually taken back to EPRA
BC or thrown in the garbage by the consumer. EPRA’s disposal activities include retail takeback for collection, transportation, and waste processing (recycling, waste to energy, landfill).
Figure 7 shows a red flow line between e-toy recycling and e-toy design because this is a
failed communication flow; this feedback is considered to be essential for an Extended
36
Producer Responsibility (EPR) program but is not occurring in the current stewardship
system.
Figure 6: E-toy stewardship without the Extended Producer Responsibility regulation in place.
Source: Author’s research
Figure 7: E-toy stewardship system - relationship diagram with the Extended Producer Responsibility
regulation in place.
Note: The dotted arrows represent communication flows and the straight arrows represent material flows.
Source: Author’s research
37
E-toy Program Activities
Goals
The e-toy program’s goals for the next five years are: 1) to employ industry-leading
standards for product recycling, refurbishment, and reuse; 2) to sustain consumer awareness
and encourage voluntary participation in the program; 3) to continue to expand the
consumer collection network to increase accessibility and convenience; 4) to develop and
implement new service-delivery models for Phase IV products; and 5) to implement new
performance indicators to track operational, accessibility, awareness, and environmental
aspects of the program (EPRA BC, 2012).
Awareness
In the 2013 report, the EPRA stewardship program announced that 72% of the
population was aware of the e-recycling program in BC (EPRA BC, 2014). The program
collaborates with producers and large retailers to integrate recycling awareness into their
marketing programs. However, post-consumer e-toy recovery is challenging. Despite
substantial and successful efforts to make consumers and producers aware of the program,
very few e-toys were recycled in the first year. The theory behind this low collection is that
consumers tend to give unwanted toys to family members or donate them to charity, and
toys are often kept for a long time for sentimental reasons before being reused or disposed
of (Toy Corporation, personal communication, March 27, 2014; CBRSC, personal
communication, April 17, 2014). Unfortunately, the EPRA program does not provide
38
detailed material recovery reports for specific categories, so there is no way to measure
return progress.
Collection (Take-back)
The collection network includes 164 depots across the province, which means that 98%
of the population can access a depot within 45 minutes (rural areas) or 30 minutes (urban
areas) (EPRA BC, 2014). These depots are selected based on their proximity to populations,
their available space, and ease of access and transportation, and they handle all e-waste,
including e-toys (Figure 8). EPRA BC employs a combination of methods to recover postconsumer e-waste: 1) permanent take-back centers at retail stores, schools, and malls; 2)
temporary collection facilities for rural communities; and 3) occasional voluntary events at
retail locations, schools, and malls, as appropriate.
Full collection site
Retail stores
Figure 8: EPRA BC e-waste collection network.
Source: EPRA website http://www.recyclemyelectronics.ca/bc/what-can-i-do/drop-off-centres/
39
Transportation
EPRA BC contracts transportation services to operate the program. E-toy collection
centers feed into strategically located depots distributed throughout the province, as shown
in Figure 8. A variety of contractors, transporters, and processors are part of the collection
network. EPRA BC contracts transportation services to operate the program. Contracted
transporters must meet all regulatory requirements and maintain qualifications under a
rigorous vendor-management system administered by EPRA BC. Because the components
of e-toys do not trigger requirements for transportation of hazardous waste as defined by the
Environmental Management Act, no hazardous-transportation provisions are required for
unwanted e-toys.
Disposal
EPRA BC partners with three approved processors within the province, FCM
Recycling, Global Electric Electronic Processing, and eCycle Solutions (EPRA, personal
communication, May 7, 2014). These processors use three disposal methods: 1) recycling for
metal and plastics, 2) energy recovery for textiles and non-recyclable plastics, and 3) sending
non-recyclable waste to landfills.
In 2013, the disposal cost for all e-waste in BC was $1,055 CAD per tonne. This incudes
the costs of delivering the program, including collection, consolidation, transportation,
audits, processing, administration, communications, management and professional fees
(EPRA BC, 2014).
40
Corporate Adaptation to EPR Policy
In order to know how corporations can adapt to EPR policy for consumer products,
I identified the challenges that toy corporations experienced in the BC e-toy program. This
section provides a summary of lessons (see Figure 9) that should be considered before
starting any type of stewardship program based on EPR policy. These lessons were derived
from the stakeholder interviews and defined while taking into account the current
application of EPR on a global scale. The basic components of a stewardship program based
on EPR are shown in Table 4; they were derived from a literature review and the BC e-toy
program. The concepts of zero waste, eco-design, and key aspects of resilience are
embedded in these lessons, as useful models against resources depletion in the long-term.
Lesson #1: Communicate with stakeholders in advance
According to the interviewed stakeholder from the toy company, the news about etoys being included in the recycling regulation was unexpected: “I don’t remember how we
found out about this regulation. My peers and I were working on an ad-hoc Canadian Toy
Association Committee and somebody knew about the BC regulation and we began to
discuss it off line, and we all started to do some research on it individually” (Toy
Corporation, personal communication, March 27, 2014). Toy corporations knew about the
regulation through informal communication channels. The BC MOE did not engage or
communicate with the toy corporations affected by the regulation before the regulation came
into force. The Canadian Brandowner Residual Stewardship Corporation (CBRSC) also
confirmed lack of engagement: “I was at the meeting when the regulation came though and
41
everybody in the room practically fell off their chairs, because nobody expected this to
happen” (CBRSC, personal communication, April 17, 2014).
The Canada-wide action plan suggests that stewardship programs should operate
with a minimum of government involvement. Therefore, I infer that the lack of prior
engagement from the BC government was intentional to avoid lobbying and conflicts of
interest among the stakeholders, especially among those paying the fees. Nevertheless, the
approved regulation should establish an appropriate timeframe that allows corporations to
prepare and plan their strategies to comply. In the BC e-toy case, after a lot of struggle, toy
corporations were able to gain an extension of time to put the program into place and to
comply with the regulation (CBRSC, personal communication, April 17, 2014). This case
suggests that stakeholder engagement and cooperation among the toy corporations was a key
aspect for adapting to, and creating a strategy to comply with, the EPR regulation.
Lesson #2: Survey available or potential stewards
Once toy corporations had gained more time to put their programs in place, the next
great challenge was to find appropriate stewards. This situation was a novelty for the toy
corporations; there were no templates to use because this was the first program of its kind.
They did not know where to start. They looked into existing stewardship programs such as
those for paint, batteries, electronics, and small appliances, but e-toys were unable to join
those programs because none of those stewards would risk including such unpredictable
products in their existing systems. They could not foresee how much work and product
42
return would result. Additionally, toy corporations faced a lack of participation from the
retail sector. Retailers did not want to deal with other stewards and refused to serve as takeback depots for e-toys. For these reasons, the toy corporations had to create their own e-toy
program, which proved to be less efficient than joining an existing program (Toy
Corporation, personal communication, March 27, 2014; CBRSC, personal communication,
April 17, 2014). In order to find stewards, corporations need to be able to anticipate the
outcomes of taking back and recycling their products after use. This implies using life-cycle
thinking and eco-design in their individual systems.
Lesson #3: Engage with stakeholders to develop strategy
After recognizing that no programs available would agree to accept e-toys, toy
corporations gathered to create a strategy to comply with the regulation. The toy industry
formed a workgroup to develop a plan on how to respond to the regulation. They designated
a person to be the communication liaison between toy corporations and the BC MOE. They
maintained long-distance weekly meetings through different media options like webinars,
phone calls, and online meetings. They included waste-management processors in the group
to figure out disposal options and recycling potentials. They made all the decisions as a
group during the first six months, after which they formed the CBRSC, the formal entity
that created, put in place, and submitted the first e-toy stewardship plan to be approved by
the BC MOE.
43
Maintaining the CBRSC program was economically unsustainable. After a year of
awareness efforts, collection, and recycling, the toy corporations generated enough
information about toy take-back and recycling. Only then did EPRA finally accept e-toys
into its existing electronic program. The CBRSC dissolved and this was a relief for toy
corporations.
Lesson #4: Analyze economic model options and trade-offs
It is important to analyze the different ways to allocate program fees. In the case of
e-toys, retailers at first refused to participate in the e-toy program since toy corporations had
expected that retailers would collect the fees from consumers for e-toy disposal. I infer that
retailers considered additional fees to harm their consumer-retailer relationship. But
programs that apply fees to consumers at the time of disposal can bring negative responses
from consumers and additional consequences; an example is the Japanese model that
charged disposal fees to consumers and thereby encouraged illegal dumping of electronics
(The Economist, 2001; INFORM, 2013).
The CBRSC was entirely funded by the toy corporations; consumers did not fund
the first year of the BC e-toy program. Toy corporations paid fees based on their sales, and
continue to do so under EPRA as well, but now the fees are reflected in the e-toys prices
sold in BC.
44
Another consideration is whether to create your own program or to join an existing
program. Toy corporations decided to join EPRA and dismiss CBRSC for economies of
scale; the stand-alone program for e-toys--CBRSC--was not economically feasible to
maintain. Putting together the CBRSC program from scratch involved much work,
administrative costs, creation of new roles, and time-consuming activities. For EPRA, adding
e-toys to their existing electronics program represented zero challenges (EPRA, personal
communication, May 7 2014). This is because EPRA has grown in infrastructure and
expertise in electronics recycling and, at that point, it had the capacity to adopt any similar
product. This case demonstrated that partnership is key to the success of EPR programs.
Previous case studies in EPR have concluded that industries should not create their own
EPR programs unless they are strong enough to overcome the economic and complexity
challenges (Tomchyshyn, 2003).
Lesson #5: Define clear and measurable goals
According to the toy corporation and the CBRSC, the BC MOE did not
communicate clear goals for recovery targets and recycling to the toy corporations. Setting
goals is essential to measure the program’s success. Governments implementing EPR
programs should engage with stakeholders to define and communicate measurable goals in
the regulation. In order to achieve these goals, corporations should create the systems and
roles necessary to collect the data and information needed; this is discussed further in Lesson
6.
45
Lesson #6: Measure the program effectively
The BC recycling regulation requires stewardship program operators to generate and
communicate data, but is not clear how detailed the data must be. EPRA releases an annual
report, but the report does not provide enough information to measure collection for each
product category. There was no publically available report specifically about e-toy
stewardship for the 2013 period. The toy-corporation stakeholder interviewed was not aware
of such a report, which means that toy corporations do not measure their program’s
progress. EPRA requires corporations to submit sales reports, which are used to calculate
the appropriate program fees. However, the absence of return, recycling, and disposal
reporting indicates that a measurement system is lacking; without details about how much
and what material was taken back and how it was disposed of, there is no way to estimate the
material return rates, the environmental impact of the program, or the program’s progress
over time.
Based on the idea that stewardship programs should operate with a minimum of
government involvement, the BC MOE does not audit a program’s progress once the
stewardship plan has been approved. Not auditing is considered industry self-policing. It is
probable that because of the BC MOE does not audit the program’s implementation, neither
the obligated stakeholders nor the program stewardship operators feel obligated to create
detailed reports and measure the program.
46
Lesson #7: Generate and publish data
Generation and communication of data is one of the requirements of the regulation
for the stewardship operators. However, as discussed in Lesson 6, the level of granularity of
this data is not explicit. Generating data in a complex system like EPRA may imply great
coordination efforts within the program; however, from the resilience point of view, this
effort can support adaptation to future external perturbations to the system. Providing data
with enough granularity is important to continue research on post-consumer waste disposal
and to provide feedback for product eco-design. New research provides tools to improve
the recycling system and make it more efficient.
Lesson #8: Consider low product-return rates
The e-toy program had very low collection rates in the first year of operation despite
extensive awareness and education efforts. The CBRSC and toy companies were
disappointed with these results and attributed them to irregular timeframes during the e-toy
usage stage. E-toys are unlike other electronics and their timeframe of usage is unpredictable.
A recent consumer study showed that most toys that are no longer being used end up
stockpiled in houses, because as children change their toy preferences as they age, they stop
using and store their younger or “babyish” toys to make room for new ones that appeal to
them (Reece, 2014). Based on consumer research, the CBRSC and the toy corporations also
concluded that toy consumers typically save the toy to pass it along to a family member
(CBRSC, personal communication, April 17, 2014). The second option is to give it to
47
charity. Only broken toys are typically recycled; therefore, the CBRSC and toy corporations
argue that e-toys have no demand for recycling.
However, these are only assumptions based on a very short timeframe of collection
and therefore they cannot be taken as absolute. In order to reach better and more reliable
conclusions, the program needs to be evaluated. The return-rates data should be analyzed
during at least three consecutive years. EPR programs are behavioral transitions that extend
over the long term; immediate results should not be expected. A good measurement strategy
needs to be in place to determine success in collection rates. Moreover, low collection rates
during the initial phase of a stewardship program should be considered an opportunity for
adaptation. The initial phase provides time to learn and to improve the system gradually
while the material recovered increases.
Lesson #9: Consider low-grade recycling material
Another difference between e-toys and other electronic products is their low
hazardous and electronic content, high percentage of low-grade plastics, and mixed material
content. The BC e-toy case showed that, on top of the low return rates, the materials
returned contain very few metals and batteries that could be profitable in recycling markets;
the majority of the recovered materials are non-recyclable plastics. Additionally, toys are
difficult to disassemble and this process normally requires manual labor. E-toys, then, are
costly to dispose of. The biggest opportunity for toy corporations to reduce their postconsumer waste-disposal cost is the eco-design of their toys. This is discussed in Lesson 10.
48
Lesson #10: Eco-design products
Post-consumer waste was not perceived as a pressing problem for the interviewed
toy corporation. This may well be the case for other toy corporations. Eco-design would not
be a challenge for a corporation that is already thinking about post-consumer zero waste.
However, the BC e-toy program is failing to provide feedback from recyclers to ecodesigners. EPRA argues that BC represents less than 1% of the e-toy global market and the
impact of providing feedback to large corporations would not be significant (Toy
Corporation, personal communication, March 27, 2014; EPRA, personal communication,
May 7, 2014).
Lesson #11: Move forward with the regulation
There is debate among the program’s stakeholders about EPR regulation. They argue
that most toys are less hazardous than other electronic products because they do not contain
the chemicals of concern that electronic products do, and therefore there is no need to
include e-toys under the EPR regulation. Additionally, some stakeholders claim that EPR
strategies are not necessarily environmentally friendly because of the energy consumption
and emissions that occur during the take-back and recycling processes (Toy Corporation,
personal communication, March 27, 2014; CBRSC, personal communication, April 17,
2014). These stakeholders suggested that we should continue sending e-toys to landfills as
“resources reservoirs,” and when the time comes landfill mining will solve the problems of
lack of land space and resources depletion. Although this suggestion could be considered a
biomimicry strategy because nature has stockpiled unused resources like hydrocarbon and
49
phosphate and humans resulted benefited from it), this idea not only contradicts one of the
main principles of pollution prevention, but also ignores the problems of land use and space,
resource depletion, and the risks from extracting contaminated and spoiled materials from
landfills. Landfilling may be a short-term solution for an existing waste problem, but it
should not be considered as a long-term solution for our current post-consumer waste
problems because it entails future environmental and health problems of its own.
Opposition to EPR inhibits program’s success because corporations spend more time
thinking about how to dismiss the regulations or the program than on finding solutions to
avoid post-consumer waste.
Figure 9: Summary of Lessons Learned about Corporate Adaptation to EPR Policy.
Source: Author
50
Table 4: Components of a Stewardship Program
Basic Components of an EPR Stewardship Plan





















Apply eco-design and zero waste in new products
Apply pollution prevention hierarchy and product life-cycle management
Assure resources are used efficiently
Communicate and consult with stakeholders
Create collection system, organize transportation logistics, and facilitate consumer access
Define scope for product take-back
Differentiate new products from old products
Generate and publically communicate data and detailed reports
Get input from consumers
Give feedback to corporations for product eco-design
Manage program costs
Mark products with symbols to facilitate take-back
Measure and audit program performance
Offer incentives to producers for eco-designed products
Prevent free-riding and orphan products
Process segregation, recycling, and disposal
Procure capital and set program fees
Provide consumer communications, awareness, and education
Reuse and refurbish
Set minimum take-back and recycling goals
Set up and manage product take-back retail for recollection
Source: Author’s research
Extended Producer Responsibility Policy Expansion
Since 2004, British Columbia has been expanding EPR regulations to more and more
products. The BC Ministry of the Environment has done this by adding product categories
to the regulation gradually, through a planned schedule. In turn, these categories added were
also implemented in phases. For example, in 2004 the BC Environmental Management Act
Recycling Regulation included beverage containers, pesticides, pharmaceuticals, and
household hazardous waste like paint and tires. Two years later, the electronic category was
51
added to the regulation and the category itself was implemented in five phases (Table 5). In
2011, the category of packaging and printed paper products was added to the regulation. The
category was launched in 2014 with products like containers made of glass, metal, paperbased materials, plastic, or any combination of those materials; and newsprint, direct
mailings, flyers, magazines, directories, and any other printed materials.
In summary, in order to expand EPR policy to new categories of products, the
government implementing the policy should create a timeline in advance and implement it
over the long-term by engaging with stakeholders. By doing so, producers can learn from
previous programs and take advantage of the existing information and infrastructure to
create their new stewardship programs.
Figure 10: Summary of Learned Lessons to Expand EPR Policy to a Broader Scope of Consumer
Products.
Source: Author
52
Table 5: Electronic Category Implementation
Phase
Year
1
2007
2
2010
3
4
2011
2011
5
2012
Categories
televisions, computers, computer monitors, keyboards, mice, printers,
and other peripherals
cell phones, audio-visual equipment, consumer equipment, thermostats,
and residential compact fluorescent light bulbs
smoke detectors
small appliances
large appliances, electrical and electronic tools, medical devices,
automatic dispensers, lighting equipment, toys, leisure and sports
equipment, monitoring and control instruments, and
telecommunications equipment
Source: Government of Canada, http://ec.gc.ca/gdd-mw/default.asp?lang=En&n=D65DC132-1
53
CHAPTER 5
CONCLUSIONS
This study analyzed the BC e-toy stewardship case to help corporations adapt
strategically to Extended Producer Responsibility (EPR) regulations. I identified the
outcomes of adapting to EPR and derived lessons that can improve corporate adaptation to
EPR for consumer products. I analyzed the literature to understand the EPR concept, its
drivers, and its global applications. I studied resilience, mitigation, adaptation, and
transformation strategies as potential solutions to overcome long-term environmental risks.
These topics are described in Chapter 2. I also described the context and history of the BC
e-toy stewardship case in Chapter 4.
The topic of resiliency was discussed in Chapter 2 to understand how EPR strategies,
if applied correctly, can benefit corporations in the long term. Table 4 provides a list of
components that I consider to be essential for an EPR program’s success. The idea of
providing feedback from recycling to designers has been discussed in the literature as one of
the core components of EPR (Lindhqvist, 1992; Lifset, 1995; Lifset & Lindhqvist, 2000;
Korhonen & Seager, 2008), but it is not easy to apply. Building a resilient system against
resource depletion over the long-term requires an internal automatic feedback flow from the
recyclers to the e-toy designers, much like the one that already exists between corporate
marketing and product design functions. Toy designers should include concepts of ecodesign and zero waste into the design process; doing so will help corporations adapt to
environmental changes.
54
I complemented this research with interviews with stakeholders closely involved in
the BC e-toy program. The lessons derived from these interviews are summarized in Figure
9. The BC e-toy program demonstrated that creating exclusive programs is neither efficient
nor economically feasible. The importance of surveying existing or potential available
stewards is one of the lessons learned. Additionally, corporations should expect low
recycling rates in the first phases of program implementation because EPR regulations are
long-term strategies. In order to reach conclusions on consumer demand for recycling
programs, it is necessary to measure a program’s return rates over at least three years. Some
stakeholders perceived the BC program as impractical, lacking consumer demand, and saw
no benefit from it. This perception was based mainly on the low volume rates of returned
products in the first year. However, the fact that there were low e-toy collection rates at an
early stage does not mean that there is no demand for e-toy recycling. EPR programs are
long-term strategies and need to be measured over time to confirm success of collection.
A life-cycle assessment of e-toys sold in BC should be performed to measure the
environmental implications of the e-toys produced and sold in BC and compare them
through the years. The assessment should take into account the amount of waste that the
toys sold in a given year, assuming that the use phase was the same for all these e-toys. Such
a study would require intensive data collection in British Columbia and among the toy
corporations.
55
I also derived lessons to expand EPR regulations to a broader scope of product
categories. The highlight of expanding EPR policy is to do it by gradually adding new
product categories to the regulation on a long-term schedule. By doing this, new categories
can take advantage of existing stewardship programs and their infrastructure to recover and
recycle post-consumer products.
56
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APPENDIX A
INTERVIEW QUESTIONS
69
APPENDIX A
INTERVIEW QUESTIONS
Interview Questions to the Toy Corporation
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
What are the goals of the B.C. Recycling Regulation? Were these goals communicated to
your company?
How was the initial communication to those affected by the regulation? How did you find
out about the policy?
How did you collaborate with the stakeholders (including the B.C. Ministry of the
Environment and other affected parties)?
What were the main challenges in adapting to the policy?
Why were the retailers so resistant to compliance if they are also required to comply under
the regulation?
How is the MOE auditing or assuring compliance to the program; is there any mechanism
for that?
What actions are being taken right now?
Is your company facing a similar policy elsewhere?
What are the benefits of the program?
What are the main challenges right now?
Do you have a sustainability department at your company?
So is the sustainability them working in the design phase?
Do you think that your company has a post-consumer waste problem? Problems at the
product’s end of life?
Besides fees, what other economic burdens arose? (Minute 33:15)
What are the next steps for the program? How do you think this program will evolve in the
future?
Do you see the program expanding to other provinces?
Do you think that may have played into why other provinces haven’t joined the program?
Do you think that other toy manufacturer have end of life problems?
Do you think that this program somehow could make sense for other (cheaper) toys?
What would your company do if the policy is applied in the US?
70
APPENDIX A
INTERVIEW QUESTIONS
Interview Questions to the Electronic Products Recycling Association of British
Columbia (EPRA BC)
21. How does EPRA collaborate with the BC MOE?
22. What is your perspective on the EPR policy (the recycling regulation); do you think that it is
a good way to solve the post-consumer waste problem?
23. How does EPRA collaborate with the toy corporations? How were they engaged in the
program?
24. How many toy corporations joined EPRA?
25. How did toy corporations react to the recycling policy?
26. What are the challenges that you have faced with the toy program?
27. In terms of recovery of materials or disposal, are toys different from other electronics?
28. What are the benefits of the e-toy program so far?
29. What steps does EPRA follow to process the disposal of toys?
30. Is EPRA still using the collection infrastructure or any other resource from the CBRSC
program (the previous e-toy stewardship program)?
31. Do you see any additional electronic products that need to be incorporated in the program?
32. Does EPRA provide feedback to toy corporations to produce recyclable toys?
33. How do you visualize the future of this EPR policy? (Minute 22:50)
34. How do you visualize the future of the e-toy program?
71
APPENDIX A
INTERVIEW QUESTIONS
Interview Questions to the Canadian Brandowner Residual Stewardship Corporation
(CBRSC)
35. What are the goals of the B.C. Recycling Regulation? Were these goals communicated to
those affected by the regulation?
36. Do you think that the new people in the ministry will make changes to the policy?
37. How were those affected by the regulation engaged? How was the initial communication to
those affected by the regulation? How do they ensure that the regulation is respected?
38. How have the stakeholders been affected by the policy and how have they reacted to it?
39. Was the toy industry successful in giving its perspectives?
40. How did you collaborate with the stakeholders (including the B.C. Ministry of the
Environment and other affected parties)?
41. What were the main challenges in adapting to the policy? What were the challenges in
creating the toy program (CBRSC)?
42. Why didn’t CBRSC work?
43. Besides fees, what other economic burdens arose?
44. What actions are being taken right now?
45. What are the benefits of the program?
46. What are the next steps for the program?
47. How do you visualize the future of this policy and e-toy program?
45. Do you see other provinces considering something like this?
46. How have you identified the reuse process to be?
47. What is the benefit to the BC MOE?
72
APPENDIX A
INTERVIEW QUESTIONS
Interview Questions to the BC Ministry of the Environment
48.
49.
50.
51.
52.
53.
54.
55.
56.
57.
58.
59.
60.
What was the driver to implement the policy?
How did you collaborate with those affected by the regulation?
How did you engage those affected by the regulation?
How did the stakeholders/those affected react to this policy?
How was the communication to the stakeholders/affected involved?
Where you successful in giving your perspectives?
What are the goals of the regulation?
What are the challenges that you have faced with the toy program?
What actions are being taken right now?
What are the benefits obtained so far?
What is your perspective on the program?
How do you visualize the future of this policy?
How do you visualize the future of the toy program?
73
APPENDIX B
RESEARCH MATRIX
74
Group of questions - What do I need to know
Why do I need to know
this
What kind of data
will answer the
question
Whom do I contact for
answers
What was the driver to implement the policy? What
are the goals of the BC Recycling Regulation?
To asses basic components
of a stewardship plan: set
minimum take-back and
recycling goals
Literature review/
Interview
BC MOE, Toy
Corporations, CBRSC
How was the initial communication to those
affected by the regulation? Were the goals
communicated to the affected/toy corporations?
How did you find out about the policy?
To asses basic components
of a stewardship plan:
stakeholder consultation
Interview
All Stakeholders
How were those affected by the regulation
engaged? Was the toy industry successful in giving
its perspectives? How did you collaborate with the
stakeholders? How does EPRA collaborate with
the BC MOE? How does EPRA collaborate with
the toy corporations?
To asses basic components
of a stewardship plan:
stakeholder engagement
Literature review/
Interview
All Stakeholders
How did the stakeholders/those affected react to
this policy? How did toy corporations react to the
recycling policy?
To identify challenges and
improvement opportunities
for the program
Literature review/
Interview
All Stakeholders
What were the main challenges in adapting to the
policy? What were the challenges in creating the
toy program (CBRSC)? What are the challenges
that you have faced with the toy program? Why
didn’t CBRSC work?
To identify challenges and
improvement opportunities
for the program
Literature review/
Interview
Toy Corporations,
CBRSC, EPRA
Why were the retailers so resistant to complying if
they are required to comply under the regulation?
To identify successes and
failures of the program
Interview
All Stakeholders
How is the MOE auditing or assuring compliance
to the program; is there any mechanism for that?
How does the MOE ensure that the regulation is
respected?
To assess policy extension
and adaptation
Literature review/
Interview
All Stakeholders
What actions are being taken right now?
To asses basic components
of a stewardship plan
Literature review/
Interview
All Stakeholders
Is the toy company facing a similar policy
elsewhere?
To assess policy extension
and adaptation
Literature review/
Interview
Toy Corporations
How have you identified the use phase of e-toys?
To identify future challenges
and improvement
opportunities for the
program
Literature review/
Interview
Toy Corporations,
CBRSC, EPRA
What are the benefits of the program? What are the
benefits of the e-toy program obtained so far? How
does the BC MOE benefit from the
program/policy?
To identify successes and
failures of the program
Literature review/
Interview
All Stakeholders
In terms of recovery of materials or disposal, are
toys different from other electronics?
To identify challenges and
improvement opportunities
for the program
Literature review/
Interview
Toy Corporations,
CBRSC, EPRA
75
What are the main challenges right now (with
EPRA in charge)?
To identify challenges and
improvement opportunities
for the program
Interview
All Stakeholders
Do you have a sustainability department at your
company?
To asses basic components
of a stewardship plan: give
feedback to eco-design
better products
Literature review/
Interview
Toy Corporations
What is your perspective on the EPR policy (the
recycling regulation); do you think that it is a good
way to solve the post-consumer waste problem?
To identify successes and
failures of the program
Interview
Toy Corporations,
CBRSC, EPRA
Do you think that your company has a waste
problem after consumers use your products?
Problems at the end of product life?
To identify challenges and
improvement opportunities
for the program
Interview
Toy Corporations
Besides fees, what other economic burdens arose?
To identify challenges and
improvement opportunities
for the program
Literature review/
Interview
Toy Corporations,
CBRSC, EPRA
Which steps does EPRA follow to process the
disposal of toys? Does EPRA provide feedback to
toy corporations to produce recyclable toys?
To asses basic components
of a stewardship plan
Literature review/
Interview
EPRA
Is EPRA still using collection infrastructure or any
other resource from the CBRSC program (the
previous e-toy stewardship program)?
To assess efficiency and
adaptation
Literature review/
Interview
EPRA, CBRSC
What are the next steps for the program? How do
you think the program will evolve in the future? Do
you see any additional electronic products that
need to be incorporated into the program? How do
you visualize the future of the e-toy program? Do
you see the program expanding to other
provinces?
To identify future challenges
and improvement
opportunities for the
program
Interview
All Stakeholders
Do you think that other toy manufacturers do have
end of life problems? Do you think that this
program somehow could make sense for other
(cheaper) toys?
To identify successes and
failures of the program
Interview
Toy Corporations
What would your company do if the policy is
applied in the US?
To identify successes and
failures of the program
Interview
Toy Corporations
How do you visualize the future of this EPR
policy? Do you think that new people in the MOE
will make changes to the policy?
To identify future challenges
and improvement
opportunities for the
program
Interview
All Stakeholders
76
BIOGRAPHICAL SKETCH
Andrea Nemer-Soto was born in Cananea, Sonora, Mexico on September 10, 1983. In 2007,
she graduated from the Tecnológico de Hermosillo with a degree in Business Administration. The same
year, Andrea joined Cadena Comercial OXXO, the retail sector of FEMSA group in Mexico, as a
Business Supervisor. In 2009, she entered the Universidad de Sonora to pursue a specialization in
Sustainable Development. In a study abroad program, she developed research in Germany to study
the “Der Grüne Punkt” waste program through an internship with the Universidad de Sonora and the
Hochschule Zittau/Görlitz. In 2010, she joined Transformadora de Mexico, a leading recycling firm in
Mexico, as a recycling consultant. There, she coordinated coworkers and high-level stakeholders
from government, industry, and community to design projects to recover recyclable waste. In 2012,
Andrea entered the School of Sustainability at Arizona State University to pursue a master’s degree
in Sustainability. While pursuing her degree, she was a Graduate Assistant at The Sustainability
Consortium, where she focused on developing pathways to improved and more sustainable
consumer products.
77