2.3.2 Deductions: Materials that are designated but may be deducted from your report

Packaging and Paper Product materials supplied to a residential consumer is always designated and must be reported in its totality in the Annual Report. However, in limited circumstances, packaging and paper product materials that is otherwise designated (because it is supplied to residential consumers) sometimes may be disposed of outside of the residential waste stream and therefore, may be deducted from the Annual Report with appropriate proof and where the steward completes and submits the Deduction Declaration Form.  In addition to completing the Deduction Declaration Form, stewards must describe their methodology for calculating their deduction in the methodology section of the Annual Report.

An Excel Deduction Declaration Form has been added to the WeRecycle Portal for stewards to provide information on the types of deductions taken. The form requires acceptable supporting documentation for any deductions, including stock keeping unit (SKU)-level data or relevant third-party studies and their application to the SKU level data.  The Programs may require any steward claiming a deduction to provide additional validation or submit to an audit of the deduction.

Please note that stewards are not permitted to retroactively claim deductions which they did not claim in a prior Annual Steward Report. The Steward Initiated Adjustment Policy prohibits retroactive methodological changes, and this includes changing the percentage of designated material for which the steward claims a deduction for past years.

Please contact National Steward Services with any questions about deductions: 1-888-980- 9549 or stewards@cssalliance.ca.

The deduction information that follows in sections 2.3.2.1 through 2.3.2.3 generally applies to packaging and paper materials supplied by Brand Owners or First Importers to consumers in British Columbia, Saskatchewan, Manitoba, and Ontario, with two important exceptions:

  • In British Columbia, a steward’s obligation to report and pay fees extends to designated material disposed of on municipal property. Specifically, no deduction is permitted in British Columbia for out-of-home disposal where the disposal occurs on municipal property, which includes public waste disposal bins and recycling bins in all municipal parks, streets, etc. [1]
  • MMSM and Ontario are the only CSSA-supported programs in which stewards may claim a deduction for plastic bags which are returned to retail as part of a return to retail program for plastic bags. A Deduction Declaration Form must be completed and submitted on the WeRecycle Portal by all stewards in Manitoba and/or Ontario that are reporting a reduced quantity of their total plastic bags supplied due to return to retail. Stewards that commingle their plastic bag returns with other plastic materials such as overwrap must ensure that the deducted quantity for plastic bags does not include other plastic material. As is generally the case, all stewards claiming a deduction for plastic bags may be required by the Program to provide supporting documentation to validate their deduction

With proper completion of the Deduction Declaration Form on the WeRecycle portal and appropriate supporting documentation, stewards may claim a deduction for certain otherwise designated materials as described in sections 2.3.2.1, 2.3.2.2. and 2.3.2.3.

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[1]  The Recycle BC approved plan covers the following:

Under Schedule 5 of the Recycling Regulation, the packaging and paper product program addresses residential premises and municipal property that is not industrial, commercial or institutional property. Residential premises are:

  • Single-family dwellings inhabited year-round or seasonally; and
  • Multi-family dwellings including rental, co-operative, fractional ownership, time-share, condominium and seniors residences

Municipal property that is not industrial, commercial or institutional property comprises the following which are collectively referred to as ‘streetscape’ in this Program Plan:

  • Sidewalks which are municipal property, which adjoin buildings in an urban commercial area and which are used for pedestrian traffic;
  • Plazas or town squares which are municipal property and which are available to the public; and
  • Parks which are municipal property