Please find attached full…

ERO number

019-0048

Comment ID

32534

Commenting on behalf of

County of Simcoe

Comment status

Comment approved More about comment statuses

Comment

Please find attached full comments with respect to the regulations, below are the key points:
• We are supportive of the Electrical and Electronic Equipment regulation and the Batteries regulation;
• The list of acceptable items is comprehensive however we recommend that toys be included in the EEE program;
• Municipalities should be exempt from reporting separate categories of EEE as this is difficult to do so and would require significant staff time which we would not be financially compensated for;
• We support the requirement for the producer to supply the packaging and shipping material needed to ship the items;
• Currently, municipalities are financially compensated for being a collector, we recommend the insertion of a subsection addressing the ability for the producer to use third party collectors and regulate how that third party would be financially compensated for being a collection site.
• With respect to limits of quantities per person per day (15 kg of batteries and 150 kg for EEE), the County feels that municipalities should be exempt from these sections as is the case with the current Used Tire regulation.
• The Ministry should reconsider the 15kg weight limit per person per day for batteries as one large battery may exceed 15kg.
• Ensuring producers are responsible for the end of life of their products makes them more environmentally conscious and these regulations will result in a significant improvement to the current program.