Return for Disassembly and Recycling

Return for Disassembly and Recycling is a product take-back approach where manufacturers accept end-of-life goods for systematic disassembly and material recovery. While not explicitly defined in the Supply Manual, this practice increasingly appears in federal contracts as agencies work to meet Treasury Board's Policy on Green Procurement requirements. The concept matters because it shifts waste management responsibility upstream to suppliers while helping departments demonstrate environmental stewardship.

How It Works

Here's the thing: there's no dedicated framework in Canadian procurement rules specifically mandating manufacturer take-back programs. Instead, the practice emerges from broader green procurement policies that require environmental considerations throughout a product's lifecycle. When PSPC or other departments draft specifications, they can include clauses requiring vendors to accept returned equipment for proper recycling or refurbishment—aligning with Treasury Board directives on sustainable purchasing, even though the mechanics get handled contract by contract.

The logistics often involve coordination with CBSA regulations. Memorandum D8-2-27 allows duty relief for goods returned to suppliers under tariff items 9813.00.00 or 9814.00.00—originally intended for repairs or cancelled sales, but applicable when products come back for recycling purposes. In practice, departments like DND or SSC negotiate return shipping terms and timelines directly into their IT hardware or equipment contracts, particularly for high-value items like servers or telecommunications gear.

Green Procurement guidance from PSPC emphasizes end-of-life management but leaves implementation details to contracting authorities. You'll typically see this in Electronics Recycling requirements or specifications for office furniture and appliances. The vendor commits to accepting returns, disassembling components, and properly processing materials—metals, plastics, hazardous substances—according to provincial and federal environmental regulations. Documentation requirements vary, but expect to provide proof of environmentally sound disposal methods.

Key Considerations

• Cost allocation gets tricky. Determine upfront whether return shipping, handling fees, or recycling charges fall to your department or the supplier. Some vendors build these costs into unit pricing; others charge separately at return time.

• Provincial regulations matter as much as federal policy. E-waste rules in Ontario differ from British Columbia's requirements, affecting how manufacturers structure their take-back programs across regions.

• Documentation and reporting expectations aren't standardized. One department might require detailed material recovery reports; another accepts a simple confirmation of receipt. Clarify your audit trail needs early in contract development.

• Timing constraints can create storage headaches. If a vendor only accepts returns quarterly or requires advance notice, you might warehouse obsolete equipment longer than anticipated. This impacts space planning and asset management.

Related Terms

On Site Waste Management, Electronics Recycling, Green Procurement

Sources

• Treasury Board Policy on Green Procurement

• PSPC Green Procurement Guidance

• CBSA Memorandum D8-2-27 on Returned Goods

Build these requirements into your specifications early rather than trying to negotiate take-back terms after contract award. The environmental benefits are real, but only if you've structured the administrative and financial arrangements to make returns actually happen.