Product Compliance Overview - Canada
Product Compliance Overview - Canada
Please review the following policies below:
- Transportation of Dangerous Goods
- Environmental & Sustainability
- Privacy Policy
- Important Program Updates
TRANSPORTATION OF DANGEROUS GOODS
Click to Transportation of Dangerous Goods Policy
ENVIRONMENT & SUSTAINABILITY
1. Product Packaging Materials & Reporting
Government regulations require reporting which identifies the number and type of batteries; or type and amount of packaging for all products sold to consumers in the regulated market.
Packaging is defined as any materials; or combination of materials, used for the containment, protection, handling, delivery, presentation and instruction of finished Product. The definition extends to packaging components or other elements that are integrated into the packaging, examples of which can be, but are not limited to, labels, staples, pins and clips.
The regulations assign “Obligated Steward” responsibilities to the entity who brings the product into the province (considered to be the “First Importer”); or to the entity who owns the brand and has residence within the regulated province (considered the “Brand Owner”).
The regulations permit “Voluntary Steward” responsibilities to entities who are neither First Importer, nor Brand Owner within the regulated province. Voluntary Steward obligations are equal to those assigned to Obligated Stewards.
- Paper & Packaging: Stewards are required to file annual reports summarizing the total quantities of packaging materials included with or produced in conjunction with consumer sales.
- It is recommended that all Vendors review the information published on the Canadian Stewardship Services Alliance (CSSA) website; a not for profit organization who provide administrative and management services to all stewardship programs.
- For obligations in Quebec, all Vendors should visit the Éco Entreprises Quebec (EEQ) website.
- Batteries: The total number of batteries sold with product or as stand-alone power sources are summarized and reported on a quarterly basis. Please refer to the additional requirements in our Transportation of Dangerous Goods policy
- Mercury: Government of Canada requires that manufacturers and first importers report the quantity of mercury imported and sold every three years. More information is available on the Government of Canada website.
Best Buy Canada relies on our partners for the accuracy of the reports we submit. Failure to accurately represent what is sold can result in fines and prosecution. The following policies are in effect for all partners to minimize opportunities for errors or risks to Best Buy Canada and its partners.
Policies - (Product Packaging Materials & Reporting):
Dealer and Vendor agree the intent of the following policies is to correctly assign obligations and promote waste reduction. The provisions of these policies demonstrate the commitments between Vendor and Dealer to accurately represent the materials being contributed to consumer recycling streams and to properly distribute all responsibilities and risk to the appropriate parties.
1.1 Any Vendor who has residence in any province in Canada must assume Voluntary Steward obligations in any province where Steward Obligations exist. It is recommended that Vendors consult the most current Steward Obligations Lists on either the CSSA or EEQ websites.
1.2 Any Vendor who imports goods into; but is not a resident in Canada must a) deliver product to a supplier who is a Steward; or b) request that Dealer assume obligations as Steward. Vendors should register with either CSSA or EEQ using the links provided herein.
1.3 Any Vendor who is unable to assume obligations agrees that Dealer may, at its election, assume the obligations as Steward. As Steward, Dealer will submit reporting and fees on behalf of the Vendor and such fees will be reimbursed to Dealer by Vendor. Vendor also agrees that for each program for which Dealer submits a reporting fee, Dealer will debit an annual fee of $500.00 from the amounts owed by Dealer to Vendor. All fees will typically be deducted within thirty (30) days from the date of report submission to the authority.
1.4 All vendors (including Obligated/Voluntary) are required to include packaging information using the Environment smart sheet appended to the Dealer’s SKU setup form. It is recommended that vendors refer to the “Materials Tool” published on the CSSA website; or to the “Materials Guide” published on the EEQ website. Vendors acknowledge Dealer’s right to either: a) amend incomplete SKU setup forms by loading material weights as determined by Dealer; or, b) reject incomplete SKU setup forms.
A “SKU Setup Summary” of materials most common to Best Buy and how to classify them in our SKU setup is available for our partners’ convenience.
Note: Material weights in Dealer’s system of record at December 1 will be used in the next reporting period and in accordance with Section 1.3 may be eligible for reimbursement by Vendor to Dealer.
1.5 In accordance with Section 3.2 of Exhibit B, Dealer may return all inventory on-hand where a Vendor has not remedied information within 30 days of being identified by Dealer as incorrect.
1.6 Repeated errors and/or omissions of packaging or battery information may result in termination of the vendor agreement.
1.7 The Vendor agrees that the Dealer shall not be held responsible for inaccurate or incomplete Vendor information and will accept any fines, levies, penalties or other costs incurred by Dealer resulting from inaccurate or missing packaging or battery information.
2. Environment Handling and Product Recycling
As a leading electronics and appliances retailer; Best Buy is committed to maintaining the highest standards for effective and responsible end of life product dispositions. As a leader in sustainability, we recognize our obligations to the programs that provide oversight and set the standards responsible for reducing the waste going into our landfills.
Environment handling fees (EHF) collected at point of sale or incorporated in the price of products are key for both program funding and tracking how much of which types of products and materials are contributed to the consumer recycling streams.
We are extremely proud of our partnerships and encourage all vendors to use the following links to access information about the various recycling programs:
- Electronic Products Recycling Association (EPRA) – an industry-led, not-for-profit organization that operates regulated recycling programs across Canada.
- Alberta Recycling Management Authority (ARMA) - a not-for-profit association responsible for managing the province's Electronics, Paint, Tire and Used Oil Materials Recycling Programs in Alberta.
- Major Appliance Recycling Roundtable (MARR): a not-for-profit stewardship agency created to implement and operate a stewardship plan for end-of-life major household appliances in the province of British Columbia (BC) on behalf of the major appliance "producers" who are obligated under the BC Recycling Regulation.
- Canadian Electronics Supplier Association (CESA): a federally-incorporated, not-for-profit organization that is led by the very industry whose small appliances, power tools, and exercise products are stipulated in the regulations.
- Call2Recycle (C2R): a not-for-profit organization working on behalf of stakeholders to provide its battery and cellphone recycling program at no-cost to consumers across Canada.
- Outdoor Power Equipment Institute of Canada (OPEIC): a non-profit organization representing the outdoor power equipment industry in Canada.
- Product Care Light Recycling (PCA): a not-for-profit organization, and provide recycling services across nine Canadian provinces.
- Resource Productivity & Recovery Authority (RPRA): The regulator mandated by the Government of Ontario to enforce the province’s circular economy laws. RPRA oversees the province’s Blue Box, Batteries, Tires, Electronics, and Municipal Hazardous or Special Waste programs.
Policies - (Environmental Handling and Product Recycling):
Dealer and Vendor agree the intent of the following policies is to correctly assign obligations and ensure EHF fees are accurately applied and reported to the appropriate authorities. The provisions of these policies demonstrate the commitments between Vendor and Dealer to effectively promote sustainability initiatives.
2.1 EHF fees are charged by Dealer in addition to the retail price for all products sold to consumers (whether or not EHF fees are displayed). EHF fees cannot be included into Vendor’s cost of goods without the consent of Dealer.
2.2 Dealer may apply and collect EHF fees for product sold to consumers.
2.3 Refunding EHF fees for customer return transactions:
- Initiated with Dealer: Dealer will provide a full refund of EHF fees collected when products are returned by a consumer to the Dealer.
- Initiated with Vendor: Vendor will provide a full refund of EHF fees collected when products are returned by a customer to the Vendor
2.4 EHF Fees for customer exchange transactions: Neither Dealer nor Vendor are responsible for collecting or remitting EHF fees provided an EHF fee was associated with the original purchase transaction.
2.5 Where Dealer elects to collect EHF fees, Dealer shall be responsible for reporting and remittances to the local authorities. In such cases, Vendors should not be reporting or remitting fees for products sold to Dealer.
3. SKU Setup Summary – Classifying Materials used for Product Packaging
Privacy Under provincial and federal privacy laws, Best Buy is responsible for safeguarding all personal information in its custody or under its control. This includes any customer personal information that may be left on the product returned to our stores.
Most people recognize the risk posed by customer personal information (videos, music, pictures, documents, emails, etc.) left on the hard disk drive of a personal computer. What many people forget is that today’s technology has advanced to the point where even seemingly innocuous products can retain user data: SMART TVs and Blu-ray players have the ability to store links to personal Netflix and Facebook accounts, scanners and printers often have a memory feature to store documents, some GPS units can run applications like Word and Excel, iPods can also store photos and videos, and credit card numbers can be stored on gaming systems for online play.
To ensure Best Buy properly sanitizes returned product prior to resale or disposal, we require the assistance of our vendors to identify all product which may have a digital memory or data storage capacity. The information provided by our vendors on the SKU set-up form will be used to guide Best Buy’s data sanitization processes.
IMPORTANT PROGRAM UPDATES (4) BELOW - MANDATORY - PLEASE REVIEW:
1. ONTARIO EEE RECYCLING UPDATE - MANDATORY - PLEASE REVIEW
In September 2020, The Ontario Electrical and Electronic Equipment Regulation (O.Reg.522/20) was introduced to the Resource Recovery and Circular Economy Act, 2016. Like the Batteries Regulation (O.Reg. 30/20) released earlier this year, the Ontario EEE regulation features Individual Producer Responsibility and an updated definition of producer residency. Vendors are encouraged to review Best Buy’s Environmental Handling and Product Recycling policies as well as the regulation, available here: Ontario Electrical and Electronic Equipment Regulation. Any questions should be directed to prodtdgcompliance@bestbuycanada.ca.
2. ONTARIO BATTERY RECYCLING UPDATE - MANDATORY - PLEASE REVIEW
In July 2020, the Ministry of Ontario implemented changes to the Resource Recovery and Circular Economy Act, 2016 by introducing the Batteries regulation (O.Reg. 30/20) and redefining Ontario’s battery program obligations. In addition to updated collection responsibilities, one of the most significant and impactful changes to the program is a shift in producer responsibilities, along with the updated definition of producer residency. All vendors are encouraged to review Best Buy’s Environmental Handling and Product Recycling policies and the regulations available through this link: Ontario Batteries Regulations. Any questions should be directed to prodtdgcompliance@bestbuycanada.ca.
EHF Fee Letter 10.07.2020 (available for download)
4. IMPORTANT ACTION REQUIRED by Dec 24. – Ontario EHF Letter
IMPORTANT ACTION REQUIRED by Dec 24. – Ontario EHF Letter (available for download)