Draft MPCA Product Stewardship Policy

In November 2008, the Minnesota Pollution Control Agency (MPCA) released the DRAFT report "Product Stewardship Study and Recommendations Report". This report was requested by the Minnesota State Legislature and will be presented to the Legislature in January 2009. The report provides an overview of product stewardship including an overview of product stewardship in Minnesota, and a summary of product stewardship policy development in North America. The report provides the draft recommendations for public review and comment, including an analysis that guided the MPCA’s decision-making.

The MPCA report addresses recommendations for six key areas specified by the legislature:

1. A set of criteria to be used to evaluate products proposed for product stewardship solutions. In designating covered products or covered product categories, MPCA is recommending the following criteria be considered: 1) Environmental and public health impacts, 2) Resource conservation potential, and 3) Public and business opportunities.

2. A process for designating products for product stewardship solutions and the role the Legislature would play in the designation process. Utilizing the product selection criteria above, the MPCA will submit a recommended list of products or product categories to the Legislature for consideration under the product stewardship program. The MPCA will submit the list biennially.

3. Possible components of industry developed product stewardship plans. A manufacturer/brand owner/importer or a stewardship organization would be required to submit a stewardship plan which includes a number of specific components.

4. Options to facilitate the creation of industry-managed stewardship management organizations. The MPCA draft recommendation authorizes industry collaboration to fulfill the objectives of the stewardship program and provides immunity from State antitrust regulations.

5. Methods to identify and monitor progress toward stewardship performance goals for specific products. The identification of performance goals will be considered as a component of the stewardship plan development process. Individual manufacturers or stewardship organizations will submit a report of annual recovery rate, the methodology used to determine the performance goals and capture rates, and other product goals

6. Strategies to implement the use of standards, certifications, and eco-labels to promote environmentally preferable products. The MPCA is proposing to work with the University of Minnesota to sponsor a forum to be held in December to address how to support standards, certifications, and eco-labels.

Caltha LLP provides technical support to manufacturers and importers to meet product stewardship requirements.


For further information, contact Caltha LLP at:
Email: info@calthacompany.com
Phone: (763) 208-6430
Website: www.calthacompany.com

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