What's new in the 2023 Schedule of Contributions
This section presents the latest developments to the 2023 Schedule of Contributions, as published in the Gazette officielle du Québec.
Porcelain – New material subject to a fee
Since the 2021 Schedule of Contributions, ceramic containers and packaging are subject to a fee, considering it is a disruptive material with no outlets in sorting centres. Due to the fact that porcelain reacts in a similar way to ceramic and in order to further ecomodulate its Schedule, ÉEQ chooses to integrate this material by giving it the same rate as ceramic, effective as of the 2023 Schedule.
Ecomodulation of the polypropylene (PP) rate
As part of the 2022 Schedule of Contributions, plastic #5 (polypropylene or PP) was isolated from other plastics, polymers and polyurethanes due to the rapid market expansion of this material over the last few years. However, its rate was not changed, so that additional data on quantities put on the market during the reporting period could be obtained; this data was necessary to reduce the risk of over- or underfunding related to estimates.
ÉEQ can now complete this segregation and assign a rate respective to this material. With its high recovery rate and greater resale value, polypropylene will benefit from a lower ecomodulated rate in comparison to other plastics, polymers and polyurethanes within the 2023 Schedule.
Penalty for failure to register and report
As announced during consultations over the 2022 Schedule, ÉEQ is introducing a new measure to encourage company compliance and reinforce fairness. The penalty for failing to register or report will apply to targeted companies who do not comply despite our communication efforts.
ÉEQ will reach out to associations whose members would be susceptible to this change to allow them to share this information and strengthen their compliance.
Exception to the amendment to the notion of first supplier
One of the measures in the 2022 Schedule was an exemption allowing the delayed entry into force of regulatory change. To keep in line with the procedures of other extended producer responsibility programs, the amendment to the compensation plan’s regulation changed the person responsible for reporting indirect sales – products reintroduced in Quebec by a retailer or a distributor.
Since the launch of the compensation plan, the responsibility to report indirect sales resided solely with brand owners from Quebec. The change in regulation meant that the person who reintroduces the products, i.e. the retailer or distributor, would now be responsible for the reporting. This amendment will have a considerable impact on how companies with national reach and with warehouses outside of Quebec operate, but also on all brand owners in Quebec who sell to these companies.
Since this is an important change which will require supporting companies affected in adjusting their reporting process, ÉEQ will uphold this exemption for the 2023 Schedule in order to maintain the status quo. ÉEQ prefers postponing the change to the 2024 Schedule, to set up the conditions which will ease this transition.
Future ecomodulation measures – Penalty for two materials starting in 2024
During 2022 Schedule consultations, ÉEQ had announced two upcoming ecomodulation measures, one a penalty for polyvinyl chloride (PVC) and the second a penalty for degradable plastics. These measures will take place as soon as the 2024 Schedule comes into play. Consequently, ÉEQ had classified these materials as separate from polystyrenes in order to quantify the amounts they each generated, as of the 2022 Schedule. The reporting data gathered is as such being studied to determine a rate specific to each material, once the 2024 Schedule is enacted.
These measures are necessary toward fighting a number of issues related to these materials, such as:
- Disrupted recycling ;
- Lack of end-of-life treatment stream ;
- Market constraints ;
- Health and security issues.
In the interest of predictability and to let companies adjust to these changes, ecomodulation conditions and penalties will be developed and announced by ÉEQ over the course of the following year. ÉEQ will contact contributing companies to inform them of this.
Renewal of the ecodesign incentive bonus for a 3rd year
Introduced as a pilot project during the 2021 Schedule, the ecodesign bonus was reviewed over the 2022 Schedule to ease the process for companies and subsidize eligible amounts. Financed by the permanent “Containers and packaging” fund, this bonus aims to recognize ecodesign processes. It also helps to identify levers of action, document challenges, identify potential solutions and measure environmental gains.
Contributing companies have since expressed their growing interest by attending the webinar on the subject this last summer and by submitting their 2022 report. Following this, the board of directors has agreed to renew the pilot project, considering moreover that a preliminary analysis of the applications received suggests that not all sums initially given will have been granted.
Here are the project’s key points. Do not hesitate to visit our website for further details.
- Divisible, well-defined and cumulative bonuses;
- 50% bonus for materials targeted by the process;
- Floor amount of $5,000 (capped at the total contribution if it is less than $5,000);
- Maximum amount of $25,000 per application and $60,000 per company.
Eligibility criteria remains the same:
- Be a contributing company compliant with ÉEQ;
- Have marketed one or multiple ecodesigned containers and packaging during the base calendar obligation year;
- Have submitted the application form before the deadline;
- Collaborate with ÉEQ in documenting the process, identifying the challenges and issues, and agreeing to publication.
Eligible companies whose application has been approved by ÉEQ will receive this bonus through a credit note issued in the year following the deadline to submit the 2023 Schedule report, applicable to the contribution balance for the 2024 Schedule or for a subsequent year.
How to apply?
To learn more about the eligibility criteria or to access the form to apply for the ecodesign incentive bonus, click here.
Éco Entreprises Québec provides support for contributing companies.
Registrants can communicate with Company Services for information and assistance with the reporting process.
One-on-one meetings are also possible.