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Product Content/Safety

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The announcement earlier this year by the British Columbia Ministry of the Environment granting a waste-based ethanol the lowest the carbon intensity value ever issued a transportation fuel in that province properly raises questions as to where energy-from-waste (EfW) now stands in the coming age of resource recovery / lifecycle circularity in North America.  The answer isn’t entirely clear. Haven’t the Europeans Already Figured This Out? North Americans will do well to recognize the origins…

Following the recent shock and awe felt by North American producers at the prospect of individual producer responsibility (IPR) for their coming circular economy legal obligations, attention has inevitably shifted towards the role to be played by producer responsibility organizations (PROs) as potential surrogates for producers in the discharge of their core resource recovery duties, while the legal liabilities remain non-transferrable.  Producers will want to ask themselves… You Want Us to Join a Not-for-Profit Collective?  …

When the Waste-Free Ontario strategy was first released in 2016, the dramatic scope of the legislated individual producer responsibility regime (IPR) no doubt drew the attention of the international automakers, which have been regulated under a multitude of government-run waste diversion programs across Canada for a number of years. Individual Producer Responsibility – But For What? IPR represents a fundamental shift in product lifecycle thinking, essentially de-regulating the means by which producers resource recover their…

The explosive growth of corporate sustainability programs truly affirms the prominence, if not centrality, that many of these programs have within multinational producers across a wide variety of industries.  Further, the breadth and specificity of many of these programs can rightly be said to reflect the granular analysis in which many companies engage in determining the content and resources expenditures for these initiatives.  But what’s truly notable in its absence – either buried in the…

Much has been made in recent months over the garment and footwear industries’ embrace of a more visible supply chain in the form of a “Transparency Pledge” developed among industry, corporate social responsibility bodies, and workers’ rights advocates. Central to the Transparency Pledge is a commitment to openness as to: authorized production units and processing facilities; site addresses; parent companies of site operators; products made; and worker numbers at each site. The Transparency Pledge arose,…

In considering the effect that traditional EPR regimes have had on product design changes, the recent OECD report Extended Producer Responsibility – Updated Guidance for Efficient Waste Management had to conclude: The contrast between [Design-for-Environment] policy expectations and realizations … seems stark.   In other words, the obligations upon producers to participate in Extended Producer Responsibility schemes has not led to a profound re-envisioning of how their products might be deconstructed and repurposed at the post-consumer phase. Product Re-Design Always Central…

As North America’s first circular economy framework has begun to roll out in Canada, program designers of the individual producer responsibility model (IPR) for waste electronics and electrical equipment would do well to learn from the experiences of another common law (and Commonwealth) regime – Australia. Australia’s IPR Model for WEEE The Australian model, introduced in 2011, comprises a statutory framework – the Product Stewardship Act – under which any number of IPR schemes can…

In a move that will send shockwaves across the cosmetics and fragrance industries, the European Commission’s Standing Committee on Cosmetic Products has just passed a proposal to ban three fragrance allergens, atranol, chlorotranol and HICC. The proposal would require that products containing the allergens be banned from sale four years after the enabling regulation comes into force, with a marketing ban effective two years prior to the ban. Labelling Not Sufficient Currently, Annex III of…