York University’s Studies of Extended Producer Responsibility Reveal Evidence of Failures

Date: 8 Feb 2021 | posted in: waste - recycling, Waste to Wealth | 0 Facebooktwitterredditmail

Advocates for corporate control over the US recycling sector through Extended Producer Responsibility (EPR) point to British Columbia as their model for the United States. Yet analysis of this system raises fundamental questions of fairness, transparency and cost effectiveness. Professor Cal Lakhan, Faculty of Environmental Studies, York University, Toronto, contributed additional research on the British Columbia EPR system. Dan Knapp, Urban Ore, Berkeley, CA summarizes and comments on Lakhan’s findings.

For previous ILSR discussion of EPR in British Columbia, go here.

These excerpts were compiled by Dr. Daniel Knapp of Urban Ore, Inc. from seven reports authored by Dr. Calvin Lakhan, Co-Investigator, “The Waste Wiki,” Faculty of Environmental Studies, York University, Toronto, Canada

Introductory note from Dr. Daniel Knapp:  These York University studies of Extended Producer Responsibility in Canada range from 6 to 16 pages, each organized around a theme or a question.  The focus is relatively narrow – printed paper and plastics used in packaging – rather than the total discard supply.  Total pages in the source studies: 66.  This collection of excerpts consists principally of my headlines followed by conclusions quoted from the reports.  A few headlines with quotation marks are from the studies themselves.  The conclusions refute EPR advocacy groups’ claims of system superiority over traditional recycling, which some EPR advocates call “the previous industry.” 

The seven studies are:

  1. Review of Recycle BC Program Performance”;
  2. Why Ontario’s plan to tackle plastic waste will not save tax payers money: A review of Ontario’s transition to full extended producer responsibility”;
  3. Economic Analysis of Including ‘Packaging Like Products’ in the Blue Bin;
  4. Modeling impact on consumer packaged goods pricing resulting from an increase in the steward obligation”;
  5. Estimating Increases in the Steward Obligation Resulting from Expansion into the IC&I” [long-term care facilities, schools, and multifamily apartment buildings];
  6. What is the goal of the Blue Box? Why recycling isn’t always what’s best for the environment or our wallet”; and
  7. Extended Producer Responsibility Primer: Answers to Common Questions and Claims.


The study refutes most of EPR activists’ claims.
“…[I]f we were to take a comprehensive examination of publicly available data for Recycle BC in British Columbia, few, if any, of… [the stated EPR objectives] are met.”  Nevertheless,“Recycle BC is touted as a best practice model for steward-led producer responsibility to be replicated… in other jurisdictions across the United States.”|
Extended Producer Responsibility Primer,” p. 4.


EPR doesn’t save taxpayers’ or consumers’ money.
“Using British Columbia as a proxy, there is no data to suggest the transition to 100% EPR has resulted in a tax savings for households.”
Modeling impact on consumer packaged goods pricing resulting from an increase in the steward’s obligation,” p. 5.


“Will a 100% EPR model save Ontarions money?|
Short answer:  No.
Long answer:  No, because producers are just going to build that cost into the price of their package.”
Why Ontario’s plan to tackle plastic waste will not save tax payers money,” p. 5.


EPR is not a way to control recycling’s costs nor to recycle more.
“There is no evidence to indicate that steward-operated extended producer responsibility schemes will result in cost containment or increases in recycling performance.”
Executive Summary, “Review of Recycle BC Program Performance,” p. 2.


“…[T]he fees for printed paper and packaging are built into the cost of the good.  The idea that producers will just absorb that cost without it trickling down to the consumer is wishful thinking.…  Full EPR in Ontario will be reflected in the cost of goods that households buy.”
Why Ontario’s plan to tackle plastic waste will not save tax payers money,” p. 5.


In British Columbia, “Program costs have increased by approximately 26% while program performance (measured as % tonnes diverted) has increased 1%“….[D]espite a 7% increase in service coverage… total collected recycled tonnes remain unchanged, while tonnes… being sent to landfill disposal is increasing.”
Review of Recycle BC Program Performance,” p. 4.


“The rate of cost increases is greater in British Columbia (Steward led) than it is in Ontario (municipal led) when compared over the same time period.”
Review of Recycle BC Program Performance,” p. 4.


In British Columbia, program performance has gotten worse, not better, since inception.  “2015 was actually the best performing year of the program.”  “…[N]et costs per tonne managed are increasing at a faster rate than any other province in Canada.”
Review of Recycle BC Program Performance,” p. 5.


EPR’s economic effects fall hardest on poor people.
“…[P]roducers are going to build that cost into the price of their package.”  The study predicts “…catastrophic consequences to low-income and marginalized families in Ontario.”  Dr. Lakhan points out that middle and high-income people can afford to buy fresh foods not packaged in plastics.
Review of Recycle BC Program Performance,” p.2.


EPR that promotes inequality isn’t sustainable.
“Is a system truly sustainable if it has negative economic and social consequences for underrepresented groups?”
Modeling impact on consumer packaged goods pricing resulting from an increase in the steward obligation,” p. 8.


EPR doesn’t facilitate or advance design for the environment.
“Producers are making no attempts to use more ‘recyclable’ materials….  Now more than ever, packaging is being made up of composite, difficult to recycle materials, and this is unlikely to change….”
Why Ontario’s plan to tackle plastic waste will not save tax payers money,” p. 4.


EPR doesn’t invest in recycling infrastructure.
“…[V]ery few investments have actually been made.”  And “…shifting financial responsibility onto producers will not magically fix what is broken….  It is naive to assume the financial incentive will result in fundamental shifts in producer behavior.”
Why Ontario’s plan to tackle plastic waste will not save tax payers money,” p. 6.


“EPR doesn’t develop healthy and robust markets for problematic packaging materials.”
“While… diverting materials from our landfills and oceans has captured the attention of the public… it has also given rise to a type of greenwashing that creates the illusion of ‘design for the environment.’  It merely delays that product from going to the landfill.”
Why Ontario’s plan to tackle plastic waste will not save tax payers money,” p. 4.


EPR doesn’t reduce greenhouse gases.
“…[I]f packaging-like materials are ultimately sent to [landfill] disposal due to a lack of infrastructure or end market demand, then the province’s decision will have… added GHGs to the environment, not prevented them.”
Economic Analysis of Including Packaging Like Products’ in the Blue Bin,” p. 6.


EPR as practiced in Ontario and British Columbia suffers from lack of transparency.
Dr. Lakhan often complains of being “forced” to guess at numbers or use only “publicly available information” because of lack of transparency about EPR’s actual effects.  Here are some of his complaints: “We have no data.” “We don’t have the administrative structure.” “We don’t know if we have the infrastructural capacity.”
Estimating Increases in the Steward Obligation Resulting from Expansion into the IC&I


“…[N]umerous attempts were made to reach out to [Recycle BC] … to seek clarity … but the university received no response.”
Extended Producer Responsibility Primer,” p. 5.


EPR’s financial structure is byzantine and difficult to understand.
“Truthfully, there are only a handful of people in the province that are even able to do a serviceable job of explaining what these… unique quirks and intricacies to these financial arrangements… mean.”
Extended Producer Responsibility Primer,” p. 3.


“What little data does exist paints a very damning picture for steward led producer responsibility for packaging waste.”
Extended Producer Responsibility Primer,” p. 5.


Although EPR in Ontario is outperforming EPR in British Columbia, it is still doing “terribly.”
In Ontario, “… the costs of the Blue Box program have almost tripled… while recycling rates have increased by less than 5%, and… are trending downward.… [T]he program has been doing terribly.”
Extended Producer Responsibility Primer,” p. 3.


EPR requires producers to manage processes they don’t understand and introduces an inefficient layer of bureacracy.
“By their own admission, most packaging companies have no clue how to operate an efficient waste managment system.  They will… have to engage in individual contracts with waste system operators who are managing the programs now,… with added administrative costs of having to coordinate multiple companies with multiple contractors.”
Extended Producer Responsibility Primer,” p, 7.


Warning: Look before you leap.
“…[O]ther jurisdictions need to think very carefully before developing a similar model.”
Review of Recycle BC Program Performance,” p. 16.


Post Script: Despite evidence to the contrary, EPR in Ontario is inevitable because manufacturers must be made to take responsibility for their products.
“I am going to assume that 100% EPR is inevitable in Ontario, and despite my criticism, it should be.  Producer responsibility is a critical step in making manufacturers responsible for the goods they produce and put out into the market.”
Why Ontario’s plan to tackle plastic waste will not save tax payers money,” p. 6.


The kicker: 100% EPR requires waste to energy, compostable plastics, or both.
“Avoiding prescriptive legislation and giving producers the latitude to pursue end of life solutions beyond recycling (compostable plastics, waste to energy/fuel) is what is going to drive sustainable Blue Box in Ontario.”
Why Ontario’s plan to tackle plastic waste will not save tax payers money,” p. 7


A final note from Daniel Knapp, Ph.D., President Urban Ore, Inc., Berkeley, California, USA 

This study is not about the whole discard supply in Canada, only a portion of it, much less than half.  A full reckoning would include far more than the cans, bottles, paper, and plastics covered by this study.  This special focus is okay, but it needs to be put in context to be understandable for people not schooled in discard management.

The total supply of discarded resources can be profiled by Urban Ore’s 12 Master Market Categories©, shown in the process-flow diagram below, The Universe of Total Recycling.  This set of categories has been independently verified to profile everything that now goes into landfill.  The materials discussed in the York studies are only four of the 12 Master Market Categories.  The included four are Metals (cans, trays, foil, etc., which are subsets of this much larger Market Category); Glass (bottles are a subset of Glass, too); Paper; and Polymers (plastics are also a subset, albeit a big and troublesome one).



Large numbers of tonnes reside in the eight Market Categories not included in the York studies.  The four biggest by weight are Plant Debris; Wood; Ceramics: and Putrescibles, including food and manures.  Smaller tonnages are available in Textiles, including clothing; Soils; and Chemicals.  The one category not covered in nearly any other set of categories, which can contain objects from all the others, and which is most valuable per tonne is Reusable Goods.  All eight of these categories that aren’t discussed in the York studies are being actively and profitably mined by Materials Recovery Enterprises all over the world.

Much more can be done to ensure that they are all captured and used.  This assertion isn’t theory; it is the essence of entrepreneurial thinking applied to the discard supply and the multiple service voids that exist within the current system brought to us by imperfect mixed-material collection systems.

As just one example, take the case of glass cullet, the term the current recycling industry uses for crushed glass.  Dr. Lakhan rightly says that making cullet out of bottles and selling it to glass manufacturers doesn’t make much money, and is probably a loser even with avoided tipping fees factored in.  That’s because mined sand is still cheap and that’s what glass bottle makers use in preference to cullet.  So they don’t pay well for cullet, and cullet is much too heavy to export.

But entrepreneurs, seeing this glass, have found that tumbling it into pebbles or grinding it into sand produces products that can be sold in small quantities for local landscape use, and for much higher prices.  Others make plates, saucers, and cups that sell for even higher prices.

Small quantities add up to large tonnes if enough are sold into commerce.  The key here is marketing, offering “this nice-looking sand” or little bag of pebbles or dinner plate that’s green or brown or blue or crystal clear “is recycled and not mined from your local riverbed or beach.”  Having a very clean product is a must as well.  One could have all sorts of sand colors in bags, each with its own price based on supply and demand.  This manufacturing is best done in small lots in many places.

To recover all the categories, what’s needed is a discard management facility that is purpose-built and that encourages upgrading the resources and selling products.

The name for these facilities is Zero Waste Resource Recovery Parks.


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Neil Seldman

Neil Seldman, Ph.D, directs the Waste to Wealth Initiative. He specializes in helping cities and businesses recover increasing amounts of materials from the waste stream and add value to the local economy through new processing and manufacturing facilities. He is a co-founder of the Institute for Local Self-Reliance.