Producers in Canada that participate in Packaging and Printed Paper (PPP) Extended Producer Responsibility (EPR) are reviewing their budgets, as this once marginal compliance fee grows into a stand-alone cost centre.
Producers of Packaging and Printed Paper are faced with rising costs from multiple angles:
1. New provinces and territories are implementing PPP EPR programs of their own.
2. Existing provinces with PPP EPR programs are transitioning from shared responsibility models to 100% Producer funded.
Of the six active PPP EPR programs, only Québec has introduced an ecodesign incentive program, which helps to encourage packaging redesign in exchange for an ecodesign credit on next year’s contribution. Ecodesign credits are part of a broader approach to encourage companies to adopt more environmentally friendly practices, particularly in product design and packaging. These credits can be an effective tool in motivating producers to rethink and redesign their packaging materials and processes to be more sustainable.
Québec’s Producer Responsibility Organization (PRO), Éco Enterprise Québec (ÉEQ), first introduced the ecodesign incentive bonus for containers and packaging (C&P) in 2021. Released earlier this month, this year’s bonus guide details the eligibility criteria for Source Reduction, Procurement, Recyclability, and Communication. There is an additional incentive if your company is open to conducting a case study.
How it Works
The ecodesign incentive bonus program is based on ten specific ecodesign actions divided into four themes, with each theme offering a bonus equal to 20% of the contribution payable for the applicable C&P. As an example, if Company A uses 35% recycled content for its kraft paper bags – they are now eligible for a 20% discount in their Kraft Paper Shopping Bags C&P material category, up to a maximum of $25,000. If the company’s total obligated fees are less than $5,000 – ÉEQ will grant a minimum bonus of $5,000. Companies can receive an extra 10% bonus for conducting a case study on the ecodesign principle that was implemented. See some examples here. Producers can submit more than one application for a bonus, to a maximum of up to $60,000!
Applications are due by September 17th, 2024. All details on the program and application form can be found on the bonus webpage.
Let’s take a look at what ecodesign strategies your packaging team can take advantage of.
**This overview is not comprehensive, and the Bonus Guide should be consulted for complete understanding.
Reduction
In the context of sustainable packaging design, "source reduction" refers to strategies and practices aimed at minimizing the amount of material used in packaging without compromising its functionality or integrity. This approach focuses on reducing the environmental impact by using fewer resources and generating less waste throughout the lifecycle of the packaging. The two Source Reduction techniques that ÉEQ is encouraging are:
1. Reduction in weight and/or volume
Finding the correct packaging/product combination is important to preserve the product, but when was the last time you reviewed your specifications? How much extra headspace do you have? Could you use less material?
Headspace is the clearance between the inside ceiling of a container and the top of the contents or internal structures within the container.
This bonus applies when the company reduces the weight and/or volume of the designated C&P.
To be eligible: the total weight and/or volume of the designated C&P must have been reduced by at least 3% compared to the previous year without transferring the C&P’s weight to a secondary or tertiary packaging or having a negative impact on recyclability.
2. Design for reuse
An often-overlooked circular strategy, reusing packaging prolongs its service life and eliminates the need for producing new packaging, thereby reducing associated environmental impacts. So, if a kilogram of packaging generates 3 kg CO2e to manufacture – using it 40+ times would reduce its environmental impact to 3.0/40 = 0.075 kg CO2e per use.
This ecodesign incentive encourages Producers to develop a reuse/refill system that can be implemented in multiple retail outlets throughout Québec, increasing accessibility. Producers should look to design C&P which can be used in these systems, which would be disposed of in the Québec curbside recycling program. A specification within ÉEQ’s guidance document is that it cannot be a private deposit-return system, meaning that it cannot use store/retailer/brand – specific containers which can only be used/returned at that store/retailer/brand.
To take advantage of this incentive, the designated C&P must be either:
Used as a refill (e.g., concentrated or large format)
Reused at filling stations (e.g., bulk)
Procurement
Procurement is integral to sustainable packaging design because it ensures the selection of eco-friendly materials, fosters supplier collaboration, and drives innovation and compliance. By integrating sustainability into procurement practices, businesses can create packaging solutions that are not only environmentally responsible but also economically viable and aligned with consumer expectations.
3. Integration of recycled content
As the world continues to use plastics at an unprecedented rate, we need to find ways to incorporate recycled content rather than continuing to use virgin plastics, thereby conserving natural resources, and lowering the environmental impact of production.
'Recycled content' refers to materials recovered from the waste stream, either during manufacturing or after consumer use, and reused in producing new products. This includes post-consumer items like used plastic bottles and pre-consumer materials like manufacturing scraps. Using recycled content reduces waste, conserves natural resources, and supports sustainability.
Both post-industrial (PIR) and post-consumer (PCR) recycled content are eligible for this incentive, while the amount of recycled content required within the C&P depends on the material used:
Material | Minimum recycled content threshold |
Paper/cardboard | 30% |
Plastic | 15% |
Glass | 30% |
Aluminium | 70% |
Steel | 30% |
4. Local Content
We’ve all been encouraged to ‘buy-local’ at one time or another in our lives. Buying local is important because it supports the local economy by keeping money within the community, helping local businesses thrive. It also reduces the environmental impact of transportation, leading to lower carbon emissions and fresher, more sustainable products. Additionally, it fosters a sense of community and connection between consumers and producers.
This incentive can be taken advantage of in two ways:
Using raw materials processed in Québec for C&P (at least 75% by mass of targeted C&P)
Or by using C&P that has been manufactured in Québec
Recyclability
Recyclable packaging supports a circular economy by keeping materials in use longer, meeting growing consumer demand for environmentally friendly products. As packaging becomes more recyclable, the burden on Material Recovery Facilities (MRFs) will lessen, streamlining the recycling process and making it more efficient.
5. Elimination of a component to shift towards mono-material
Mono-materials, products made from a single type of material, are superior for recycling because they simplify sorting, reduce contamination, and produce higher-quality recycled materials. This efficiency leads to increased recycling rates and lower environmental impacts due to reduced processing energy and waste.
According to the National Waste & Recycling Association, approximately 25% of recyclables are contaminated by incorrect items, largely due to consumer confusion. Lacking the proper recycling instructions (see Communication), if consumers only have to worry about one material to recycle, they might have better luck. Similarly, recycling infrastructure has limited capabilities to separate different materials.
The bonus is applied when any components of the specified C&P that are made from materials other than the primary material are removed.
6. Elimination or substitution of a problematic material
All materials are not created equal and one way this disparity is seen is in its recyclability. A number of factors determine how recyclable something is – this list includes, but is not limited to:
Polymer Type
Ease of Separation – Mono-material plastics are easier to recycle.
Collection and Sorting – What recycling infrastructure is available? How educated are the consumers on how to sort and recycle?
Market Demand – What are the end-use applications for recycled content? Higher market value can make recycling more economically viable
A material is considered ‘problematic’ when there is a malus associated with it, or when it is recognized as “problematic” by the industry (i.e. see the Canada Plastic Pact’s Guidance document on unnecessary & problematic plastics).
A ' malus is an eco-modulation concept used in environmental policy and product stewardship programs where financial penalties are applied to products that are less environmentally friendly or harder to recycle.
ÉEQ has its own list of malus materials, polyvinyl chloride (PVC) and polylactic acid (PLA), whereas other industry guidelines profile others, introduced in the next section.
To be eligible for this incentive, the company must eliminate or substitute a problematic material which impedes its ability to be recycled. The substitution must not negatively impact the essential functions of the packaging or transfer mass towards secondary or tertiary packaging.
7. Improved Recyclability Potential
Recycling plastics isn't just about the polymer type; it involves several key factors. The ease of recycling is influenced by the presence of additives like plasticizers and fillers, the use of dyes, the removability of labels and adhesives, and whether the use of direct printing is moderated. All these elements play a crucial role in determining how efficiently a plastic product can be recycled.
This ecodesign incentive also requires the use of internationally recognized guidelines, like the APR Design Guide by the Association of Plastics Recyclers and the Golden Design Rules developed by The Consumer Goods Forum. Notably, the Canada Plastics Pact, part of the Ellen MacArthur Foundation’s Plastic Pact network, has adopted these Golden Design Rules to ensure its members follow best practices in sustainable packaging.
Communication
Effective communication helps consumers understand recycling by providing clear guidelines on what can be recycled and how to do it properly. This reduces contamination, ensures efficient processing, and boosts participation in recycling programs, promoting sustainability.
8. Self-declared environmental claims
In 2021, the European Commission conducted a study on environmental claims and found that a significant portion of these claims are misleading. Specifically, the study revealed that 53% of green claims made were exaggerated, false, or deceptive. Additionally, 40% of the claims lacked accessible supporting evidence, and half of all green labels did not provide strong verification.
These findings underscore the prevalence of greenwashing, where companies make unsubstantiated or vague claims about the environmental benefits of their products to appear more eco-friendly than they are. This practice not only misleads consumers but also undermines genuine efforts to promote sustainability by other companies.
Despite industry concerns, ÉEQ's incentive aims to encourage the use of self-declared environmental claims. In this framework, ÉEQ will require documentation, ensuring that claims and data can be validated upon request. These self-declared claims must adhere to the communication guide published by ÉEQ and comply with ISO14021 principles, promoting transparency and credibility in environmental reporting.
9. Environmental labels (recognized certification)
Recognized environmental claims provide a structured framework for transparency, credibility, and accountability in communicating environmental benefits. They play a vital role in driving positive environmental outcomes and promoting sustainable practices across industries.
To be eligible for this incentive, ÉEQ requires the environmental label to be a recognized certification and verified by an independent third-party. The environmental label must be included on the designated C&P or shared through another means (e.g. webpage, advertisement, etc.).
10. Sorting instructions
As mentioned earlier, poor consumer knowledge on how to recycle significantly impacts the quality of recycling processes by increasing contamination, thereby decreasing sorting efficiency and affecting the quality of the recycled material.
Knowledge is power, and consumers are asking for it. According to a survey by The Recycling Partnership in 2020, 75% of Americans surveyed said they would recycle more if they had more information about what materials can be recycled and how to prepare them properly.
To be eligible for this incentive the sorting instructions must pertain to all components of the designated C&P and must reflect the reality of Québec’s curbside recycling system.
It’s important to note that resin identification codes and the Mobius loop with no further explanation are not eligible sorting instructions.
Case Study
The final bonus ÉEQ offers is the ability to conduct a case study on any one (or several) of the ten ecodesign incentives that your company implemented. There are differing methodologies to conducting a case study, depending on whether or not it is a new product, or an optimization of existing packaging.
For optimized packaging, ÉEQ introduces a tool called OptimAction which calculates the net environmental benefits gained by improving the C&P based on various indicators (e.g. greenhouse gas (GHG) reductions, quantity of material used, increases in recycled content). This tool is free to use for the producer conducting a case study.
The Transition to Sustainable Packaging Design
As Packaging and Printed Paper (PPP) Extended Producer Responsibility programs expand and transition to being fully producer-funded, companies in Canada are facing rising compliance costs. The introduction of Québec’s ecodesign incentive program by Éco Enterprise Québec offers a promising solution by rewarding sustainable packaging practices. These incentives encourage companies to reduce material use, integrate recycled content, and improve recyclability, ultimately promoting eco-friendly packaging designs. Effective participation in these programs can help producers manage costs while supporting broader environmental goals and enhancing their sustainability credentials.
For more detailed information on sustainable packaging strategies and ecodesign incentives, visit Éco Enterprise Québec or get in touch with us.
Comments