What's new in the 2022 Schedule of Contributions
This section provides the new features of the 2022 Schedule of Contributions (SoC), as published in the Gazette officielle du Québec.
Renewal of the ecodesign incentive bonus
ÉEQ launched the ecodesign incentive bonus pilot project in 2021 to support companies engaged in the ecodesign of containers and packaging, and to encourage others to follow suit.
Modernizing the curbside recycling system means that companies can play a pivotal role in the system and its management in partnership with the municipalities. They will therefore become responsible for the containers, packaging and printed matter they put on the market from design to end-of-life management through recycling. The purpose of including this ecomodulation measure is to move to a fee structure that is better aligned with the impact of materials throughout the value chain.
Pilot project objectives:
- Recognize ecodesign initiatives for containers and packaging marketed during the 2021 calendar year
- Document ecodesign strategies, challenges and potential solutions
- Identify environmental gains, as well as positive social and economic benefits
- Communicate companies’ initiatives that earn a bonus
A simplified and improved approach
The first year of the pilot project allowed ÉEQ to learn and make a number of improvements. The application process has been simplified and the amount of bonus available has been increased.
- The percentage of bonus available is increased to 50% of the payable contribution of the targeted containers or packaging
- Each bonus application will be eligible for a maximum of $25,000
- A company may submit multiple applications for a maximum bonus of $60,000
- An application deemed eligible will receive a bonus floor of $5,000, or capped at the company’s total contribution, if less than $5,000
Eligible companies, whose application is approved by ÉEQ, will receive the bonus through a credit note issued in the year following the deadline for submitting their company report for the 2022 SoC. The credit will be applicable to their contribution balance for the 2023 SoC or for a subsequent year.
How to apply
To learn more about the eligibility criteria or to find the form to apply for the ecodesign incentive bonus, please click here.
Wood and cork – New materials subject to a fee
Wood and cork are types of packaging or packaging components designated by law, but historically not subject to a fee by ÉEQ. In addition, cork containers and packaging that end up in sorting centres do not currently have any outlet. Consequently, to expand the SoC’s ecomodulation impact, ÉEQ has decided to include wood and cork in its 2022 SoC by assigning them their own fee.
Segregation of materials
Polypropylene (PP) containers and packaging must now be reported separately from other plastics, polymers and polyurethane. This will allow them to be assigned their own rate in a future SoC.
Containers and packaging made of polyvinyl chloride (PVC) or polylactic acid (PLA) and other degradable plastics must also be reported separately. It should be noted that the marketing of those containers and packaging will be subject to a penalty as of the 2024 SoC.
Significant overhaulof the application rules
The 2022 SoC was developed in a particular context influenced by several factors, including the publication of a draft regulation modifying certain parameters governing the publication of the SoC. In addition, the global pandemic continues to impact economic activities and business models resulting in new consumer realities.
The SoC rules have therefore undergone a significant overhaul to consider not only the regulatory changes, but also to ensure that they evolve in accordance with the principle of fairness, taking into account the various orientations and the application issues encountered. These changes also meet the demands of companies and their associations.
As a result, the rules of the 2022 SoC have been amended to include the following changes:
- Significant development: Operators of transactional websites, with or without a place of business in Quebec, whose products are acquired through e-commerce by Quebec consumers are now subject to the compensation plan
- Introduction of the concept of “practical owner of the group” and clarification of the scope of their legal responsibilities
- Voluntary contributors are no longer eligible for the flat fee based on income in Quebec
- Additions and clarifications of definitions
- Further to the update of the Environment Quality Act, the 2022 SoC now includes newspapers. It should be noted, however, that companies marketing them are still represented by RecycleMédias and must report them in a separate portal
In order to align with the EPR, it should be noted that the regulation on the compensation plan published on May 18, included an amendment to the notion of first supplier, which has an impact on the designation of the person subject to the regulation.
However, since this amendment could not be presented during the consultations, since it significantly affects the reporting methodology of the companies concerned and since it will only be required as of 2023, ÉEQ has applied an exemption in the SoC rules in order to maintain the status quo for the 2022 obligation year.
If your company is a retailer that operates nationally or is a manufacturer that distributes to these retailers, ÉEQ will be contacting you in anticipation of the 2023 SoC to help you through this change that will take effect next year.
Éco Entreprises Québec provides support for contributing companies.
Registrants can contact Company Services for information and assistance with the reporting process.
One-on-one meetings are also possible.