Quebec’s Regulation respecting the recovery and reclamation of products by enterprises is quite broad and wide-ranging. We have found that it tends to impact products in ways that other regulations may not so it bears close study.
While it has the typical product stewardship aspects of joining a collective, then funding and reporting on recycled products, assessing the scope is a unique exercise. A wide variety of consumer electronics is included in Division 1 that come in to scope in two phases, but “products designed and intended to be used exclusively in an industrial, commercial or institutional environment” are explicitly excluded.
Recovery and reclamation programs for products in the first phase must be implemented by July 14, 2012 and includes the following:
- desktop computers;
- laptop computers, electronic pads and e-book readers;
- computer screens and television sets;
- printers, scanners, fax machines and photocopiers;
- cellular and satellite telephones;
- wireless and conventional telephones, pagers and answering machines;
- keyboards, mouses, cables, connectors, chargers and remote controls designed to be used with a product covered by this Division.
A year later, by July 14, 2013, the following categories must have recovery and reclamation programs in place:
- video game consoles and their peripherals, projectors designed to be used with electronic equipment, readers, recorders, burners or sound, image and wave storage devices, amplifiers, equalizers, digital receivers and speakers designed to be used with an audio video system; the types of products referred to in this subcategory include those marketed as part of a set such as home theatre systems;
- portable digital players, radio receivers, docking stations for portable digital players and other portable devices, walkie-talkies, digital cameras, digital photo frames, camcorders and global positioning systems;
- routers, servers, hard drives, memory cards, USB keys, speakers, webcams, earphones, wireless devices and other accessories and spare parts not covered by an other subcategory provided for in this section and designed to be used with a product covered by this category.
Division 2 covers batteries, and again excludes “batteries exclusively designed and intended for industrial purposes.” Electronics manufacturers tend not to design batteries so in many cases you may need to request information from the battery manufacturer describing the intended use of specific batteries. Note that the battery requirements are independent of whether the products they are used in are covered in Division 1 or elsewhere in the regulation. So if your product uses a battery and is not in the Division 1 scope, you should review this regulation.
Mercury lamps, paint and paint containers, and “oils, coolants, antifreeze, their filters and containers and other similar products” round out the scope of this regulation.
Note that the Electronic Products Recycling Association is a recently established national not-for-profit, industry-funded organization. It has been established by electronics manufacturers and retailers chartered with national responsibility for improving the efficiency of the e-waste reclamation and recycling process. While each province’s regulations are different, membership in EPRA gives manufacturers “one-stop shopping” to fulfill their obligations for most, if not all, of the regulations listed above.
Michael Kirschner is President of Design Chain Associates (DCA). DCA provides services that help Electronics OEMs and other product manufacturers increase engineering, procurement, and production efficiency, product and operational environmental performance, and corporate profitability by ensuring that the right decisions about supply base and the environment are made during the earliest stages of the product lifecycle, and are built-in to corporate strategies and tactics.
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