How were the Electronics Recycling Standard (ERS) and the Recycler Qualification Program (RQP) developed?
The ERS was first developed in 2004 by Electronics Product Stewardship Canada (EPSC). The intent of the ERS was to ensure that end-of-life electronics (EOLE) collected through the industry-led provincial stewardship programs was handled in a safe, secure and environmentally sound manner.
Subsequent to the release of the original ERS it was revised on 3 different occasions, with the most recent version of the Standard incorporated into the broader RQP. The purpose of each revision of the ERS was to ensure that it met the current needs of the stewardship programs as well as the developing electronics recycling industry.
After stakeholder consultations and review and approval by EPSC and each of the provincial programs, the RQP was released in October 2010.
Why are the ERS and RQP required?
The ERS and the RQP were created by the electronics industry out of necessity; as Extended Producer Responsibility (EPR) regulations were being passed in the provinces, these regulations only required the collection and recycling of electronics at end-of-life by the brand owners, but they did not necessarily include provisions to ensure for the safe and environmentally sound recycling of these materials.
As a result, the ERS, and later the RQP, were created to provide the base minimum requirements for electronics recyclers where the environmental, health and safety regulatory requirements were non-existent, inadequate, or not being sufficiently enforced to ensure the satisfactory controls for and proper management of this material.
How was the Recycler Qualification Office (RQO) created?
The RQO was established in cooperation with EPSC and the industry-led provincial EOLE programs to manage all recycler audits and approvals on behalf of the programs. The RQO operates under the Electronic Products Recycling Association (EPRA), a national, non-profit entity, created by Canada’s electronics industry in order to improve the efficiency and effectiveness of Canada’s industry-led and regulated electronics stewardship programs.
What does it mean to be ‘approved’ to the ERS?
After a recycler has been audited by the RQO a final ‘statement of approval’ is prepared in accordance with the requirements of the RQP. This statement is provided to recycler and the provincial programs to indicate based on the audit process whether or not the recycler is been deemed to be operating in conformance with the requirements of the ERS.
The statement of approval is formed based on the information provided and assessed during the audit. It is the recycler’s responsibility to ensure that adequate, objective evidence has been provided to demonstrate conformance with the requirements of the ERS. Inability to provide this evidence will result in approval being withheld.
The statement of approval is limited to the confirmation for use under the provincial programs, for the specific material(s), processing method(s) and location covered under the scope of the audit. Approval does not constitute a certificate of conformance to the ERS, and third-parties may not rely on this recognition as such certification.
How can I attain RQP certification?
A ‘certification’ process does not exist under the RQP. Primary recyclers interested in processing material on behalf of the provincial programs are required to be audited by the RQO and confirmed to be operating in conformance with the requirements of the ERS.
Primary recyclers may apply to the RQO to initiate the audit process, and following the successful completion of the audit, the recycler will be provided a statement of approval to the ERS for a specific scope of operations.
How are approved recyclers recognized?
Approved primary recyclers are posted online at: www.rqp.ca
How long does the RQP audit process take?
The timing of the audit process is dependent primarily upon the preparedness and responsiveness of the recycler. The audit to approval process has taken as little as 2 days to complete, where the recycler was suitably prepared to undertake the process.
However, where recyclers are not adequately prepared operationally; they do not possess adequate evidence of conformance to the requirements of the ERS; or they have not adequately prepared their downstream recyclers, the process will take significantly longer, as the results are of the audit are completely dependent upon the recycler’s ability to demonstrate conformance to the ERS.
The RQP audit process has been designed to be detailed and rigorous in order to ensure that recyclers meet the requirements of the RQP and are handling the end-of-life electronics and resultant material streams in a safe and environmentally responsible manner. However, the onus is on the recyclers to demonstrate conformance to the requirements. Those that have adequate controls and systems in place are able to demonstrate conformance with little effort, those that have not developed the necessary control measures will require additional work before being approved under the RQP, which can significantly extend the timing of the audit process.
How can I initiate the audit process?
Primary recyclers can initiate the audit process by completing the RQP Application Form and submitting it to the RQO with all necessary supporting information. The recycler is responsible for ensuring that adequate supporting documentation is provided, as incomplete applications will not be assessed.
Applications for the approval of downstream recyclers must be submitted through an approved primary recycler seeking to add the downstream to their downstream flow. The primary recycler must demonstrate that they have audited and evaluated the downstream recycler, and submit a completed application form along with all supporting information demonstrating conformance to the requirements of the ERS.
The RQO will confirm receipt of all applications which in no way suggests that the application is complete or subject to audit. The RQO is not responsible for any applications or packages that are not received or are lost in transit.
Once received by the RQO, application packages become the property of the RQO for use in conducting the RQP audit. Packages are maintained in accordance with record control policies and will not be returned.
Are there defined audit protocols that the RQO conducts the RQP audits against?
Yes, the Audit Protocols are defined in Part E of the RQP.
Is there a dispute resolution process?
Yes, as per the Assessment Protocols, the Recycler may request a secondary review, conducted by a panel of representatives from the provincial programs, if it disagrees with any final assessment of the RQO.
Who is responsible for ensuring the downstream recyclers operate in conformance with the ERS?
The primary recycler is responsible for all materials until they reach their point of final disposition. The ERS requires the primary to have a process in place to evaluate downstream recyclers to assess their ability to handle material in a safe and environmentally sound manner, in accordance with the ERS and regulatory requirements.
RQO audits are conducted on behalf of the provincial programs only and they are not considered a substitute for primary recycler evaluations and approvals.
How can I promote my approval under the RQP?
Only recyclers that have been audited and approved by the RQO may indicate that they have been approved under the RQP, within the specific scope of the approval indicated by the RQO.
How long does my RQP approval last for?
The scope of approval as defined by the RQO is valid for a maximum period of 2 years for primary recyclers and 3 years for downstream recyclers. In addition, any changes in the approved process, including types of materials handled, processes undertaken, or downstream recyclers used, requires re-approval.
Can my approval under the RQP be revoked?
Yes. RQP approval is granted based on particular evidence sampled during the audit process and during a particular point in time. If it is determined at any time based on verifiable evidence that the recycler is not operating in conformance with the requirements of the ERS, a nonconformance may be issued and a corrective action response plan required. Failure to adequately respond to a nonconformance will result in the revocation of approval.
In addition, should it be determined that a recycler has provided false information or misrepresented any part of the application, supporting information or processes and operations undertaken, the Recycler’s approval will immediately be forfeited.
What is the purpose of the ‘ongoing recycler surveillance’ program?
The ongoing surveillance program is designed to verify that approved recyclers continue to operate in conformance with the ERS and within the scope of their approval, throughout the term of their approval.