Comparative Analysis of Extended Producer Responsibility Policy in the United States and Canada

This article analyzes the policy choices and programmatic elements of extended producer responsibility (EPR) as implemented in the United States and Canada. The article traces the historical development of EPR in each country and defines common features of EPR in each nation. The U.S. states and the Canadian provinces have assumed the primary role, rather than the federal governments, for enacting producer responsibility requirements in their respective countries. However, the paths taken demonstrate several fundamental differences, including the prevalence of individual versus collective responsibility and the financing mechanisms implemented for EPR. Given the deepening experience with EPR and the breadth of its application to a widening array of products in the United States, the Canadian model for EPR is starting to receive more examination from policy makers in the United States, indicating that the policy and programmatic differences between the two nations may eventually be narrowing. The comparative policy analysis is illustrated through the lens of EPR regulatory efforts for waste electronics, with particular profiles of the programs in the State of Minnesota and Province of Ontario. Both approaches broadly reflect many of the policy considerations and governance and programmatic themes that dominate EPR programs in each country. Finally, the article offers recommendations for collaborative work between the United States and Canada to explore consistency between programs and other complementary strategies to support producer responsibility activities.