Electronics Product Stewardship Canada Albert Street Suite Ottawa Ontario Fax by thebestone


									                           Electronics Product Stewardship Canada
                                  130 Albert Street, Suite 500
                                        Ottawa, Ontario
                                           K1P 5G4
                                613 238 4822, Fax 613 238 7967

24 January 2003

Dennis Darby
Chairman of the Board
Stewardship Ontario
26 Wellington Street East, Suite 601
Toronto, Ontario
M5E 1S2

Dear Mr Darby:

Electronics Product Stewardship (EPS) Canada is a not for profit corporation established with
seed financing from fifteen leading multi national corporations in the electronics and information
technology industries (please see attached list of our members). Our mandate is to implement a
national, industry led electronics product stewardship program for Canada.

EPS has been an active member of Stewardship Ontario’s Data and Reporting Advisory
Committee. We have welcomed the opportunity to express our views on the packaging issue and
the committee chair, Gordon Day, has been very receptive to our suggestions. We look forward to
continuing this consultation process on behalf of our member companies.

We have briefly reviewed the proposed blue box program plan issued by Stewardship Ontario on
January 21, 2003 and we would like to bring to your attention our concerns with the proposed
date of obligation of June 2003. We believe that additional work is required in a number of areas
of the plan to ensure a fair and equitable packaging waste program is introduced in Ontario and
we are asking that the date of obligation be delayed until the end of calendar year 2003.

We have the following concerns:

    1) Industry must be given additional time for review and comments. The proposed blue
       box program plan was issued on 21 January 2003 with a deadline for comments of 24
       January 2003. The plan is 109 pages long and this short time frame prohibits any kind of
       detailed industry review-especially for many organizations who have not been involved in
       the ongoing committee work of Stewardship Ontario.

    2) The anticipated date of obligation of June 2003 does not provide our member
       companies with sufficient time to budget for the packaging levies. This date must
       be extended to the end of 2003 to allow companies to introduce these costs into
       their pricing model and to properly plan for the levy implementation. The method for
       calculating proposed levies was made available to industry in December of 2002 and
       continues to be modified. It is only now that our members are completing packaging
       audits within their firms and beginning to understand their potential financial commitment.
       For some of our member firms this commitment will be well in excess of $100,000 per

    3) More work is required to determine the short term and long term method of
       calculating packaging levies. We are pleased that Stewardship Ontario has expressed
       support for the implementation of sectoral calculators and we are working diligently to
       develop a calculator that represents our industry. We are very concerned that the
        proposed cross sectoral calculator from Belgium may not accurately reflect Ontario’s
        market conditions. In addition we believe additional work is required to define how
        industry will work towards determining a long term levy calculator and we need to
        understand the associated administrative costs.

    4) Additional work is required to define who must take responsibility for remitting the
       levy. There continues to be confusion around who must take responsibility for remitting
       the levy and we believe this must be better defined prior to implementation. Perhaps the
       following example will help illustrate this point. A large electronics manufacturer without
       an Ontario based legal entity imports product into Canada through a distributor in
       Vancouver. The distributor in Vancouver sells the product to both retailers and
       distributors in Ontario. The distributors in Ontario sell the product to retailers in Ontario
       and to other provinces in Canada. In this example how do you calculate the levy, who
       pays the levy, and how does each party know how the other party is interpreting the levy
       obligation? More work is required to define how this type of problem will be handled to
       ensure the outcome is fair and equitable.

    5) The principle of fairness requires that de minimus be set as low as possible and
       that aggressive measures be taken to enforce non compliance. While we support the
       de minimus rule in the proposed plan, additional work is required to review how the de
       minimus rule will ensure fairness in each business sector and have minimal impact on
       industry competition. We are also very concerned with stewards having a significant
       financial burden to pay for non compliance. We believe that further work is necessary to
       ensure an effective monitoring, auditing, and communication program is in place targeting
       all obligated parties. In our industry sector the issue of internet and other non traditional
       sales could have a serious impact on the level of compliance and it is not clear how this
       will be managed.

In closing, we applaud the work that has been completed to date on the blue box plan and we are
calling upon Waste Diversion Ontario to provide Stewardship Ontario with the additional time
they, and all affected stakeholders, require to implement this program in a fair and equitable
manner. We believe that an obligation date effective the end of calendar 2003 would allow
sufficient time to address the issues we have raised in this letter.

Yours truly,

(original signed by)

David A. G. Betts
President and CEO

Copy: Tim Moore, Chair, Waste Diversion Ontario
      Honourable Chris Stockwell, Minister of the Environment, Ontario
      Electronics Product Stewardship Canada
                Member Corporations
                    January 2003

                  Apple of Canada

            Brother International Canada

             Dell Computer Corporation

                  Epson Canada

              Hewlett-Packard Canada

                  Hitachi Canada

                    IBM Canada

                 Lexmark Canada

               LG Electronics Canada

                 Panasonic Canada

                  Sanyo Canada

            Sharp Electronics of Canada

                  Sony of Canada

                Thomson Multimedia

                 Toshiba of Canada

Founding associations: Electro-Federation Canada and
  the Information Technology Association of Canada

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