Friday, January 9, 2009

Product Stewardship Requirements - Draft Oregon DEQ Rule

In December 2008, Oregon Department of Environmental Quality (ODEQ) released a working draft of its Product Stewardship Framework. Under the working draft, no specific products were identified. In the future, products subject to requirements would be designated by the Legislature based on a set of criteria.

The draft does designate some Producer Requirements. Producer and/or importers of designated products would be required to must establish, finance, and operate statewide product stewardship programs for the designated products. The programs must:

  • Provide collection, transportation, reuse, recycling, and disposal of designated products and their components;
  • Provide adequate insurance and financial assurance;
  • Provide an education and outreach component to consumers, retailers, and other interested parties.

Producers could operate the program individually, collectively with other producers, or enter into an agreement with a stewardship organization to operate the program on their behalf. Product stewardship programs must be provided free of charge anyone with an unwanted product. Under the working draft, producers must provide statewide collection that is convenient, available, and free and there must be at least one collection site in every county and in every city with a population of at least 10,000.

Each product will have performance goals. ODEQ will establish by rule how performance goals will be measured. For the first 4 operating years of the program, the producers would establish the goal amounts and report on progress toward achieving the goals; however, these initial goals are not enforceable. In operating year 5, ODEQ would set specific, enforceable regulatory standards for the performance goals.

Caltha LLP provides expert consulting support to companies needing to meet internal or regulatory product stewardship requirements.

For further information contact Caltha LLP at
Caltha LLP Website

No comments: