Comment
Section 30 (1) poses a challenge for the refillable pressurized containers. This section requires that no later than three months after the day that the type of HSP is collected by the producer, the HSP is processed by an HSP processor who is registered under section 42.
The first requirement of three months is not realistic if the refillable pressurized containers recovered are in a state where the content could not be identified. In that situation, the content needs to be considered as the worst case for safety reason (i.e. Toxics, class 2.3). Currently, no processors in Canada are accepting to process these types of products. The containers need to be exported to the USA following the requirements of the Federal regulation ‘’Cross-border Movement of Hazardous Waste and Hazardous Recyclable Material Regulations, SOR/2021-25’’ which process can take more than 3 months alone.
The second requirement for HSP registered processors represents also a challenge, as there are currently no registered processors in that category.
Submitted October 18, 2024 9:40 AM
Comment on
Amendments to four producer responsibility regulations for tires, batteries, electrical and electronic equipment, and hazardous and special products
ERO number
019-8866
Comment ID
101098
Commenting on behalf of
Comment status