By July 14th 2012, Quebec regulations will now require lamp producers to be part of, or have their own, Government approved EPR recycling program for lamps and batteries. Not participating in such a program is in contravention of the law in Quebec.
A Lamp Producer is defined as “the first importer to the province” – it could be a retailer, distributor or a manufacturer. We recommended manufacturers discuss with their retailers and distributors to define how and who will collect and pay the Eco fees – which will be charged on all Mercury containing lamps in QC, by the program manager, upon receipt of sales info provided in confidence to the program.
EFC has led the development of this program with the cooperation of the EEMAC Lighting section and Product Care Association. The Program Manager and owner is Product Care – We have worked with them to develop similar programs in BC and Manitoba. The BC and Manitoba programs were for Retail Lamps only, but these programs are also changing as of July 2012 to include fixtures and all Hg Containing lamps.
The attached files provided by the Program manager give you all the details required to enroll in the program (see end of document for files):
1) Notice to QC lamps potential participants to advise them of status of our entente and actions needed before April 14.
2) A form by which each company can:
* Formally indicate their intention to join PCA QC program for the purposes of compliance with the QC regulation
* For those members already in the BC and MB program, to extend their existing membership in PCA to include QC lamps
* List the information required by the regulation
3) Info letter from RQ.
The Product care web site is www.productcare.org/. Product Care is a non-profit organization selected by members to develop and Manage EPR programs. In Quebec, Product Care will be called Association – Recyclage de Produits Spécialisés.
EFC recommendations:
* Read the documents
* Discuss with your supply chain how you will deal with the Eco fees which cannot be visible at the cash register in QC. They need to be internalized.
* Signing into the program has no cost, and it meets your legal requirements until you determine in your supply chain how sales and fees will be reported and dealt with. The program will collect, recycle and report to the QC government what is being done on an annual basis.
* Get your signed forms in ASAP
(3) Information English / Francais
If you have any questions or concerns, contact Wayne Edwards, wedwards@electrofed.com, 647.258.7483, or Vanessa Groult, PCA Program Coordinator, Toll-Free: 1-888-772-9772(ext. 200), vanessa@productcare.org.
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