Choosing Products to Focus On
CPSC supports the implementation of framework legislation over product by product legislation. However, until EPR framework legislation is enacted, CPSC will continue to support EPR for individual products on a case-by-case basis. For selection of products within an EPR policy framework, CPSC supports the California Integrated Waste Management Board's Framework for EPR System in California adopted in January 2008 which states the following in Section 6:
"While criteria used to select products/product categories would be determined within the regulatory process following enactment of statute, there are some general concepts that should be addressed in that process. The list below includes factors that would likely be addressed during this process, although it is not meant to be exhaustive or prescriptive, nor is it presented in order of importance:
- Total volume being disposed in landfills
- Level of toxicity or hazard to human or environmental health
- Total lifecycle net environmental impact
- Potential for net lifecycle impact improvement
- Level of market/infrastructure currently in place
- Effectiveness of programs currently in place, if any
- Current impacts to local governments/general ratepayers
- Usage trends (increasing, decreasing, steady)
- Difficulty to manage
- Existing problem with illegal dumping
CPSC has listed some products that are already banned from landfills or are considered hazardous because they have been the first products targeted by legislation for management. However, CPSC supports EPR approach in concept for all products and their packaging.
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