On June 29, 2011, the Quebec government published the Regulation
respecting the recovery and reclamation of products by enterprises,
which came into effect on July 14th, 2011. The purpose
of the regulation is to reduce the quantity of residual materials
by making the producers and marketers of certain consumer products
responsible for their recovery and the costs related thereto.
Certain provisions of the Regulation (which will affect
industries such as the automotive, electronic appliances and retail
sectors) came into effect on July
Under the Regulation, the costs related to the recovery and
reclamation of a certain electronic products (such as digital
receivers, memory cards, USB keys, GPS systems, speakers, video
game consoles and their peripherals, portable digital players,
radio receivers, digital cameras, digital photo frames, camcorders,
routers, hard drives, webcams, wireless devices, etc.) must be
internalized in the price asked for the product (or a final product
which contains said products). Businesses covered by the
Regulation are required to implement their own recovery and
reclamation program or join a recovery and reclamation program with
an accredited organization and advise the Minister of Sustainable
Development, Environment, Wildlife and Parks of their chosen course
For ease of reference, here is a link to the Regulation.
These new rules may have a significant impact on how
manufacturers and retailers advertise and offer their products for
sale in Quebec. We therefore invite you to contact your legal
counsel to discuss how the Regulation and the Quebec recovery and
reclamation fee may affect your business.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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