HCPA Seeks Support for Household Product Stewardship Alliance

Several states are coordinating efforts to develop and implement industry-funded programs for products considered household hazardous waste (HHW). Producers of household products that are flammable, corrosive, reactive and/or toxic may have obligations because their products have the potential to land at collection sites if the consumer does not fully use them.

Vermont is implementing a law requiring producers to establish an Extended Producer Responsibility (EPR) program for HHW. Legislation is being considered in California and the Household and Commercial Products Association (HCPA) expects other states, including Connecticut, Illinois and Washington, to consider similar legislation.

HCPA has engaged on HHW policy for decades. Most recently, the Association successfully opposed EPR legislation in Vermont. Now, HCPA has formed the Household Product Stewardship Alliance (HPSA) to service myriad products that don’t fall within the purview of longstanding, product-specific laws, which are limited to materials such as batteries, pharmaceuticals, electronics and textiles.

HPSA is the industry’s stewardship organization (SO)/producer responsibility organization (PRO). But HPSA needs industry support to succeed. Without an operational SO/PRO, there is no viable compliance solution, according to HCPA. Compliance failure could result in costly sales disruptions, financial impacts and reputational damage for producers. HCPA warns that without a producer-led SO/PRO, a waste management firm or other private firm may step in and inflate HHW EPR fees.

HPSA requires initial financial support of $1.5 million from producers to fulfill its role as an SO/PRO in Vermont and streamline compliance with industry-funded HHW management programs anticipated in other states.

According to HCPA, early funding partners will assist in determining fair and transparent fees and can determine other variable fees based on the initial investments provided by founding members while considering product footprints in relevant states.

The HPSA board of directors, composed of early funding partners, will have the opportunity to make key governance decisions, including:

• Process and timeline by which seed funding will be recouped;

• Principles for setting fees associated with legally obligated costs for HHW collection and management, public education and outreach, and related requirements;

• Principles for providing additional clarity on covered products and processes for adding and removing products from the list of what is in scope.

To learn more or discuss funding opportunities, contact Mike Gruber, EVP-government relations & public policy, HCPA, [email protected] or Molly Blessing, VP-sustainability & product stewardship, HCPA, [email protected]