February 01, 2010

Draft regulation respecting the recovery and reclamation of products by enterprises

The CQCD's comments to the Ministère du Développement durable, de l'Environnement et des Parcs

 

The CQCD agrees with the approach taken by the government, which aims to establish a common regulatory framework applicable to all products that will be subject to new recovery programs in Québec (also known as programs for extended producer responsibility).

As retailers are considered to be producers under this regulation, they will be directly affected by it.

However, the CQCD considers that the proposed regulation, as presented, sets down far too many rules, thus subjecting the targeted enterprises to a vey heavy burden of obligations and, furthermore, that it does not take sufficient account of the economic reality of the CQCD's members.
 
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