2.3 Step Three: Obtain your sales data and/or information on services provided

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Identify all PPP for which you are the brand owner, franchisor and/or first importer. (Please see sections 1.6 through 1.11 of this Guidebook for obligation requirements).
You must also identify services and other activities undertaken by your organization that generate PPP.
- Examples of materials that need to be accounted for but are sometimes overlooked include: hard copies of annual reports, bank statements, marketing brochures, flyers, and printed materials distributed to your employees that are likely to be managed in the residential waste stream such as records of employment, pay stubs and T4s, and any envelopes, flyers or inserts accompanying these documents.
- In order to access this information, you may rely on systems data, customer sales records, mail service data etc.
Identify the sources of data available to you and ensure you have access to the data required to complete the report (e.g., franchises, marketing, vendor management, divisions, shareholder services, etc.).
Ensure that you have identified changes to your organization (as a result of acquisitions or divestitures of brands or businesses) since your previous report and you have incorporated them into or excluded them from your report.
Extract a sales report from your accounting system for all products sold for which your organization is the obligated steward in the relevant data year. Gather other data as required that will enable you to prepare your report (e.g., shareholders that received annual reports, marketing materials provided to consumers, etc.).

2.3.1 Introduction: The Difference Between Exclusions and Deductions

Some packaging or paper products are not designated by the programs because the material is never supplied to a residential consumer or is not considered to be disposable packaging. These are known as exclusions because the PPP was never within the scope of the program. For example, PPP associated with products which are never supplied to residential consumers such as products used only in commercial applications, is “excluded” material. Stewards do not need to include material which is “excluded” (i.e. not designated) in their annual reports. The following subsections discuss the types of excluded packaging which do not need to be included in the stewards’ annual reports.

In contrast to “exclusions”, all material supplied to residential consumers, even if the PPP is subsequently returned by the consumer or removed from the consumer’s home, and regardless of where the PPP is disposed of by the residential consumer (e.g., at home or in a commercial establishment), is designated material.

In limited circumstances, stewards that complete and submit a Deduction Declaration Form may be permitted to deduct some designated packaging or paper products which are supplied to residential consumers but are managed outside of the residential waste stream. Deductions are discussed in section 2.3.2. Deductions and Exclusions are fully explained in the Deduction and Exclusion Policy available here.

2.3.1.1 Exclusion: Durable Packaging

Durable packaging refers to packaging that has a useful life of at least five years, is intended to facilitate longer term storage of the product and remains with the product throughout its useful life. Where only a portion of the packaging is considered integral to the long-term use or storage of the product, this portion may be excluded from the steward report because it is not designated PPP. The following are examples of durable packaging that should not be included in your report:

CD/ DVD cases
Power tool cases
Vinyl record covers
The boxboard used to contain, store and transport pieces of a board game or puzzle.

2.3.1.2 Exclusion: Products and services supplied to IC&I consumers for the IC&I consumers’ consumption

Where a steward supplies packaging or paper product materials to the industrial, commercial, or institutional (IC&I) sector, is never re-supplied to a residential consumer, and the material is not disposed of in the residential waste stream, this constitutes material which is not designated by the programs. It can include corrugated or boxboard shipping cases, plastic pallet wrap or any other material used for the delivery of the product to a retail outlet but is disposed of or recycled in the warehouse and never included as packaging supplied to the consumer.

Please note that PPP supplied to home offices and disposed of in the residential waste stream is not an 'exclusion' and cannot be excluded or deducted from your annual report because it will be managed in the residential waste stream not managed via a commercial establishment’s waste management system.

Stewards must be able to demonstrate that the packaging and paper product excluded from the report was:

supplied to IC&I consumers for their consumption or for the consumption of other IC&I organizations and it was never supplied to residential consumers and,
never managed in the residential waste stream.

This situation is illustrated by the following examples:

A steward may supply industrial cleaning supplies in bulk-sized containers to hospitals (part of the IC&I sector) for their use in maintaining health care facilities. The packaging associated with these bulk-sized containers is never supplied to residential consumers and is managed within a commercial establishment’s waste management system. As a result, this is material supplied to the IC&I sector (and not to residential consumers). This material is not designated under the provincial recycling programs and therefore should be excluded from the steward’s report.
A steward sells “bulk sized” packages of cooking oils to a restaurant (part of the IC&I sector) which incorporates the cooking oil into its menu items. The same steward also sells the same bulk sized packages of cooking oil through a “big box” retailer which in turn sells this product to residential consumers. The steward should not include the portion of the packaging supplied to the restaurant in its annual report because this packaging is not designated material because it is supplied to the IC&I sector. However, the steward must report on the bulk packaging supplied to residential consumers through the big box retailer, as this is designated material.

As a result, if you can prove (with auditable data) that:

specific products (and their associated packaging) are only supplied to IC&I consumers;
are never resupplied to residential consumers, and
are never disposed of in the residential waste stream

that material may be excluded from your report. You must retain all supporting documentation regarding any materials excluded from your report as you may be required to substantiate the exclusion of this material by providing auditable data upon request.

2.3.1.3 Other items to exclude from your report

Do not report items that are not generally considered to be packaging such as accessories to the product that do not serve a packaging function. These items are not designated under the provincial programs. This would include items such as:

paper serviettes
plastic cutlery, straws etc. ⁶*

Do not report packaging sold as a product (empty) to the end consumer. This would include items such as:

garbage bags
organic waste bags
food storage bags
food storage containers

Please note that retail carry-out plastic bags are considered designated items and must be reported.

Do not report items that constitute an integral part of the product. This would include:

toner cartridges
single use cameras

^[6] Recycle BC stewards please note these are considered SUP/PLP items and are not eligible to be excluded from the steward report. Please see the BC Ministry’s Explanatory note here.

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

Packaging and Paper Products supplied to a residential consumer are always designated and must be reported in their totality in the annual report without deduction. However, in limited circumstances, packaging and paper product materials that are designated (because they are supplied to residential consumers) sometimes may be disposed of outside of the residential waste stream and therefore may be deducted from the annual report as long as the deductions are substantiated and validated through the completion of a Deduction Declaration Form and supported by appropriate validation data.

The residential waste stream is a system of waste collection which services residential dwellings, including single family and multi-family dwellings, regardless of whether the service is provided by a municipal government or by private contractors. In the Recycle BC Program, the residential waste system also includes streetscape containers, because streetscape is part of the Recycle BC Program funded by BC brand owners and first importers. Please note that deductions based on where the item is managed within the residential waste system i.e., recycling, garbage or organic stream, are not permitted.

Designated packaging and paper products that are disposed of outside the residential waste stream may be deducted from the annual report, as long as the deduction is supported by adequate validation data and a completed 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.

If permissible pursuant to the Programs' Exclusion and Deduction Policy, deductions are optional at the election of the steward. In order to claim a deduction, the steward must fully complete an Excel Deduction Declaration Form which is available on the WeRecycle Portal. The form lists examples of 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. Validation data must be submitted at the same time as the Deduction Declaration Form to support the review process and confirm the eligibility of the underlying deduction.

The Programs may require any steward claiming a deduction to provide additional validation data or submit to an audit of the deduction. If the deduction substantiation involves a third-party study, waste audit data, or market research; please ensure that:

a copy of the study, data or research is included along with your submission,
information such as time frame of the study/research/data, demographics, location, survey questions, and results are clearly stated,
any other relevant information is provided and that the questions asked in the research and study demonstrate the percentage of Packaging or Paper product managed outside the waste stream vs the percentage consumed or delivered etc.

Please note that stewards are not permitted to retroactively claim deductions for a previously filed report which they did not claim at the time they submitted that 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@circularmaterials.ca.

The deduction information that follows in sections 2.3.2.1 through 2.3.2.3 generally applies to packaging and paper product materials supplied by brand owners or first importers to residential 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.⁷
MMSM and Ontario are the only Circular Materials-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. All MMSM or Stewardship Ontario stewards claiming a deduction for plastic bags may be required by these programs to provide supporting documentation to validate their deduction. With proper completion of the Deduction Declaration Form on the WeRecycle Portal and appropriate validation data, stewards may claim a deduction for certain otherwise designated materials as described below. This deduction for plastic bags is not available for stewards under the MMSW and Recycle BC programs as return to retail programs are not permitted. With proper completion of the Deduction Declaration Form on the WeRecycle Portal and appropriate validation data, stewards may claim a deduction for certain otherwise designated materials as described below. This deduction for plastic bags is not available for stewards under the MMSW and Recycle BC programs as return to retail programs are not permitted.

^[7]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.

2.3.2.1 Deduction: Materials supplied to consumers but not managed in the residential waste stream

A steward may deduct packaging from products supplied to consumers that is consumed at the steward’s on-site premises, when the packaging and/or printed materials associated with the product is disposed of outside the residential waste stream. The following are two examples of how a steward might claim this deduction:

1) At quick service food establishments, a portion of customers eat in the restaurant and dispose of their waste at the restaurant. Other customers may have the food delivered to their residence or pick up the food and remove the associated packaging and paper from the restaurant and dispose of it at their residence. The portion of PPP that is disposed of on-site at the steward’s business premises may be deducted in the steward’s annual report. In this example validation data may include waste audit data of what remains at the business premises or a third party study. Both sets of data must be applied to SKU-level information to account for the deduction taken. Stewards must ensure that they do not claim deductions for PPP which is removed from another steward’s premises. For example, if a steward is supplying ketchup packages to a quick service restaurant, the only packages that can be deducted from the total supplied quantities are those that are disposed of onsite at the restaurant. The rest must be reported.

2) As a brand owner resident in BC, SK, MB and ON, Confectionary Candy Co. is the obligated steward for its chocolate bar packaging. Confectionary Candy Co’s (the Steward) research indicates that 50% of chocolate bars are consumed away from consumers’ homes, therefore some portion of the wrappers may be managed outside of the residential waste stream. To support a deduction of a portion of wrappers from the steward’s annual report, the steward may conduct a valid study which shows:

disposal patterns of single serve confectionary products (as distinct from consumption patterns),
ensure the study is a reflection of Confection Canada Co. consumers,
ensure the study is supported by validation data

Once this type of research is conducted and the results are known, the steward may apply the results against their SKU level data. The Steward will complete and submit the Deduction Declaration Form as part of their Annual Steward Report. Please note that obligated “on the go” PPP such as chocolate bar wrappers supplied to consumers in BC cannot be deducted from the steward’s report if disposed of in streetscape receptacles because stewards are required by regulation to participate in the funding of streetscape recycling for BC residents.

2.3.2.2 Deduction: Product returns

A steward may deduct packaging or paper associated with products that are initially supplied to residential consumers, but are returned to retail, never re-supplied to a residential consumer, and disposed of outside of the residential waste stream. Stewards cannot claim this deduction if the returned product and its associated paper or packaging are subsequently re-supplied to a consumer, as it will re-enter the residential waste stream (i.e. returned products that are placed back on the shelf or sold in bulk to be re-sold by a retailer selling discounted goods). Product returns without their associated paper or packaging cannot be claimed as deductions.

Retailers may only claim this deduction for packaging and paper products for which they are the brand owner or first importer. A brand owner claiming this deduction must be able to substantiate the quantity of returns to retail. For example, a retailer could request a deduction associated with the recall of private label yogurts- some which were supplied to residential consumers and have been returned to the store for end of life management.

2.3.2.3 Deduction: Packaging removed from consumer’s home

On occasion, goods delivered to residential consumers may have packaging that is delivered with the product, but that packaging is sometimes removed from the consumer’s home by the delivery service. This packaging is designated because it is supplied to the residential consumer at the time of the delivery. However, for the portion of PPP that is removed from the consumers’ home and disposed of outside of the residential waste stream, it may be eligible for a deduction. The deduction must be claimed at the same time that the report is submitted and the steward must complete a Deduction Declaration Form and is provide supporting validation data.

For example, a big box retailer may provide home delivery for large appliances. The appliance is delivered with its packaging (e.g., corrugated box, polystyrene, plastic film etc.) and its printed paper (e.g., warranty information).

Some delivery services may offer to remove some of the packaging (but not the paper warranty information or the PPP inside of the appliance) at the option of the consumer. This packaging is designated because it was supplied to the consumer (e.g., delivered with the purchased appliance in circumstances where the consumer, not the delivery company, has the right to determine whether it stays with the appliance or is removed) and must be reported in its totality without deduction.

In these situations, the obligated brand owner or first importer may claim a deduction for that portion of packaging that is removed from the home and disposed of outside the residential waste stream. The steward must have validation data such as auditable documentation from various retailers and their delivery network that supports the deduction of this material from its report, by appliance SKU, and provide supporting information in the Deduction Declaration Form. Not all residential consumers will ask for the packaging and paper product to be removed at the time of delivery. Some SKUs may have lower rates of delivery than other items (e.g., large appliances). Further, some delivery companies that do remove paper and packaging at the time of the delivery may use the residential waste system for disposal.