While the printing industry in British Columbia supports sustainable recycling programs in which the full life-cycle costs of a product are scrutinized, it strongly opposes the way the BC’s Ministry of Environment has established new regulations with little or no consultation with stakeholders.

The industry is extremely concerned with the stewardship plan set out by Multi-Materials BC. After months of unsuccessfully seeking information on what the plan actually means, the industry heard at a presentation by MMBC that the rates to be charged in BC are significantly higher than other provinces with similar programs (by a factor of four in the case of Ontario). This creates a risky economic proposition for BC. It has the potential to create adverse economic effects, especially considering Alberta and Washington have no such programs in place. Printing businesses and the people they employ would have to move out of the province in order to survive as those buying print seek alternative ways to reach consumers that circumvent the new regulations that come into effect in May.

We call for the Province to put a hold on implementing these regulations and on MMBC’s program until such time that proper consultation happens with key stakeholders in British Columbia. This could produce more favourable impacts over the long term without destroying an industry that delivers annual sales of $619.9 million dollars (Statistics Canada-­‐Manufacturing sales by subsector, by province 2011). The printing industry is a significant employer in the province of BC and an important stakeholder of any such stewardship program.

There was no consultation with members of the printing industry, BCPIA (the industry association) or any of the large paper merchants which supply the paper needs in the province. Information on the program was difficult to obtain and poorly communicated. It appears that the Ministry only consulted with MMBC which is governed by a Board made up of Ontario business interests: Unilever Canada, Metro Inc., Walmart, Tim Hortons Inc., Loblaw Companies Limited, Coca Cola Refreshments Canada and Procter & Gamble. Why would the BC Ministry of Environment think these Ontario-based businesses would really understand and care about businesses in British Columbia?

The MMBC program is flawed in every aspect. It does not adequately consider the administrative burden it will cause. It does not consider materials coming into the province directly through the mail system, creating gaps in the assessment of total volume going into the residential waste stream. It appears that the plan is to collect 80% of the revenue from the top 150 producers in the province. The costs will be passed back to consumers and the end effect on British Columbia is negative.

The program as it stands cannot be self-sustaining in the long term due to flawed and complex reporting guidelines, confusing rules, uncertain enforcement and audit procedures, loopholes relating to out of province mailed paper and packaging products entering the province and the excessive charges being applied to larger and already economically vulnerable producers. The program is inefficient in every aspect, from charging and collecting fees to its administration and compliance costs.

Please call your colleague the Honourable Mary Polak and tell her the MMBC program must be put on hold. It is appropriate that the government reviews the implementation of this program and broaden the discussion relating to its goals and desired outcomes. It is an important program, one that requires a well-considered solution based on feedback from all stakeholders in British Columbia not Ontario. The MMBC program is not the solution. Please tell her you are concerned for the program’s long term success and the negative economic impacts the new regulations will have on the province of BC.

For information please contact: Marilynn Knoch, Executive Director, BCPIA 604.542.0902 or mknoch@bcpia.org www.bcpia.lorg