Last updated on June 5, 2023
The Canadian Franchise Association supports government efforts to address climate change, waste reduction, and environmental sustainability through responsible Extended Producer Responsibility (EPR) policies and circular economy legislation. Franchised small businesses across Canada recognize the importance of protecting the environment and are committed to reducing waste and improving environmental performance.
Franchised small businesses operate in local communities across Canada and are an important part of the Canadian small business economy. Many franchise small business owners are already implementing environmentally responsible practices and supporting waste reduction initiatives within their operations.
Extended Producer Responsibility legislation must recognize the realities facing small businesses in Canada. When new environmental regulations are introduced without sufficient consultation or without considering operational impacts, they can create unintended consequences for small business owners.
In several jurisdictions, Extended Producer Responsibility and resource recovery legislation treats franchised small businesses differently from other independent small businesses, often grouping franchisees with the franchisor when determining regulatory thresholds and producer responsibilities. This approach does not reflect the reality that most franchise locations are independently owned and operated small businesses.
When franchised small businesses are treated as part of a larger franchisor under Extended Producer Responsibility regulations, they may face higher compliance costs and additional reporting requirements than other small businesses. This can create an uneven playing field and make it more difficult for franchise small business owners to compete with non-franchised businesses.
Effective EPR policy and circular economy regulation require meaningful consultation with small business stakeholders, clear regulatory guidance, and reasonable implementation timelines. Governments should work with the franchise community to ensure Extended Producer Responsibility policies achieve environmental objectives while remaining practical for small businesses to implement.
Our Ask
The Canadian Franchise Association encourages governments to ensure that franchised small businesses are treated fairly under Extended Producer Responsibility legislation and circular economy regulations.
Governments should:
- Ensure franchised small businesses are not unfairly targeted or treated differently from other Canadian small businesses under Extended Producer Responsibility regulations
- Establish franchise-specific small business thresholds where appropriate within EPR frameworks
- Ensure that the materials and regulatory obligations of franchisors and franchisees are treated separately within producer responsibility systems
Fair and balanced Extended Producer Responsibility policies will help protect the environment while ensuring that franchise small business owners in Canada can continue operating, creating jobs, and serving their communities.