If you're a magazine publisher trying to wrap your head around the Multi-Material British Columbia (MMBC) registration
requirements, an info blast yesterday from Magazines Canada
aims to help.
In an effort to dispel any misinterpretations that may deter publishers from registering, Magazines Canada reiterates that BC-based publishers are required by law to submit a Letter of Intent (LOI) by March 31, 2013, and that failure to do so can result in late fees or non-compliance penalties of up to $200,000. The LOI is non-binding.
This applies to all paper producers whose products are disposed of in the BC residential Blue Box program, regardless of distribution model, and also includes non-BC residents whose products are shipped into the province and disposed of in the same manner. As Magazines Canada notes, this is where details can get muddled.
If a publisher from outside BC whose products are shipped in declines or neglects to register with MMBC, the responsibility may fall to a local distributor or wholesaler. The catch is that "the wholesaler/distributor is likely to charge back the MMBC fee to the publisher with an administrative fee attached," meaning a more expensive route than just registering directly with the MMBC.
Likewise, the responsibility could also fall to a retailer in the absence of a BC-based wholesaler or distributor. In this case, retailers can refuse to receive shipments of a product if a publisher can't prove its MMBC registration, or retailers may handle the MMBC fee themselves but then charge it back to the publisher, plus an admin markup.
According to Magazines Canada: "Although MMBC and the BC Ministry of Environment may not have direct control over non-resident publishers, they do have control over BC-based wholesalers, distributors and retailers who can prevent you from doing business with them or increase your cost of doing business with them. MMBC does not have authority over how these companies might respond to non-registrants so you may not hear this message from them."
The program doesn't take effect until May, and MMBC won't have a cost estimate until all LOIs are collected. Magazines Canada anticipates that BC's fee for magazine paper will be in the same ballpark as Ontario's, which is 6.47¢ per kg, as opposed to Quebec's more exorbitant 19.966¢ per kg.
Hit Magazines Canada
for further clarification.