Regarding the Consultation…

Regarding the Consultation Draft of the "ONTARIO REGULATION to be made under the RESOURCE RECOVERY AND CIRCULAR ECONOMY ACT, 2016 ELECTRICAL AND ELECTRONIC EQUIPMENT"

Specifically, Part II, Article 4(1) says "For the purposes of the definition of “producer” in section 1, with respect to new EEE marketed to consumers in Ontario, the producer is..."

And, similarly, in the Consultation Draft of the "ONTARIO REGULATION to be made under the
RESOURCE RECOVERY AND CIRCULAR ECONOMY ACT, 2016 BATTERIES"

Part II, Article 4(1)(a) says "with respect to new products marketed to consumers in Ontario with which new batteries are provided..." and
Part II, Article 4(1)(b) says "with respect to new batteries marketed to consumers in Ontario separately from products..."

The term "consumer" is neither defined within these draft regulations, nor is another source for the definition of "consumer" referenced. The scope of producers is, therefore, unclear: "consumer" typically references a private individual rather than a corporation or legal entity. If this is the case, then producers of EEE for commercial and industrial ("B2B") use would not be covered in this regulation. However, in order to ensure clarity, I strongly recommend defining "consumer" or incorporating a definition for it by reference to another regulatory instrument.

Thank you.
Mike