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…
Jonathan Cocker will be organizing a session on Consumer Product Safety Commission developments at the upcoming 2017 North America Regional Product Safety Training Workshop in Toronto, Canada on June 28, 2017. For more information visit: ICPHSO
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…
In response to concerns over the documented diffusion of microplastics into waterbodies worldwide, regulators proudly point to the international efforts to eliminate microbeads from cosmetics and personal health care products. But microbeads are a discrete set of plastic additives to a discrete set of products, making regulatory efforts relatively straightforward. More importantly, aquatic research seems to confirm that microbeads form only a small portion of the overall microplastics waterborne content – so what regulatory steps are…
When it comes to being “Green”, many of the leading apparel and footwear brands have more in common than you might think. A number of leading brands have implemented a form of responsible forest product purchasing policies. Most recently, apparel brand conglomerate VF Corporation adopted its Forest Derived Materials Policy which sets purchasing guidelines and commits the company and its suppliers to using sustainable forest materials and products. As part of its policy adoption, the apparel…
If you thought that pest control products can’t be found at your local clothier, you haven’t been reading Canada’s Pest Control Products Act. A pest control product under that Act includes any: “product… that is manufactured, represented, distributed or used as a means for directly or indirectly controlling, destroying, attracting or repelling a pest” Still not following? Micro-organisms that are “injurious, noxious or [have] troublesome effects” are pests under the Act and your gym shirt…
It wasn’t supposed to be this way. The Global Harmonized System was supposed to be just that – a seamless harmonized set of classification and communication standards as applied to hazardous chemical products worldwide. Safety Data Sheets (nee MSDS) and labels would, in meeting the standards of one country – necessarily meet them all. At least between United States and Canada, no? Variances Between HCS 2012 and HPR With the introduction of GHS, both Canada’s…
On November 29, 2016, EPA identified the first ten chemicals that it will send through the risk review process under the amended Toxic Substances Control Act (TSCA). EPA was obligated to publish this list by December 19, 2016. Publication of the list in the Federal Register in the next several days will trigger the three-year statutory deadline for EPA to determine whether the chemicals present an unreasonable risk to humans and the environment. If EPA…
Environment Canada has published its proposed risk management measures for embattled Triclosan, confirming that Pollution Prevention Plans, mandated under the Canadian Environmental Protection Act, will soon be required for its continued use in Canadian consumer products, including: non-prescription drugs, natural health, personal care and cleaning products such as antibacterial soaps, skin cleansers, toothpastes, make-up, deodorants, skin creams, fragrances; and general purpose cleaners, and detergents. Triclosan Use Already Restricted Efforts to regulate Triclosan in Canada are not…