The Québec regulation respecting the recovery and reclamation of products by enterprises obligates all regulated enterprises (see above) of mercury-containing lamps to either operate or be a member of an approved program to recover and reclaim end-of-life mercury-containing lamps in Québec. The program must be funded by these enterprises to provide a collection and recycling option for all generators of mercury-containing lamps in Québec, pursuant to the collection system requirements outlined in the regulation.
Product Care Association (PCA) is a non-profit association and has registered in Québec under the name Association des Producteurs Responsables (APR). PCA has now finalized an agency agreement with RECYC-QUÉBEC, the oversight agency in Québec for product stewardship programs, as an organization that can implement a “recovery and reclamation system” for mercury-containing lamps on behalf of its members, pursuant to the regulation. Any enterprise that is obligated under the regulation is invited to join the PCA program in order to satisfy the requirements of the regulation.
Members of the program agree to report, on a monthly basis, their sales of program applicable products to PCA and remit applicable recycling fees on those sales after October 1, 2012, except in cases where another member agrees to report/remit fees on their behalf (see below). Formal membership in PCA is still required even if another member will be reporting sales/remitting fees on behalf of that obligated enterprise. A remitter agreement is required for PCA program membership.
Each company that is obligated under the regulation was required to notify Ministère du Développement Durable, de l’Environnement, de la Faune et des Parcs (Recyc-Québec) by April 14, 2012 of their intention to start their own program or to join an accredited industry-managed program such as the PCA program. It is not too late to act. Obligated companies must inform RECYC-QUÉBEC of their intention as soon as possible and complete Product Care’s membership process, unless they are operating their own program accredited by RECYC-QUÉBEC. See below for more information on how to join the PCA program to fulfill this regulatory requirement.
