As proposed, the regulation…

As proposed, the regulation appears to specify provisions for several HVAC products that are "fixed" installations and should not be treated in the same manner as typical consumer products. I would recommend the Ontario government to have a dialog with the relevant industry associations representing such products, namely The Heating, Air-Conditioning, and Refrigeration Institute of Canada, Air-Conditioning, Heating, and Refrigeration Institute, and the Canadian Institute of Plumbing & Heating.

The supply chain for “applied” products offered by our industry involves professional installation and decommissioning by qualified technicians. Both Europe and California have EPR regulations that exempt products or systems that are “fixed” installations connected directly to the building structure and installed by qualified technicians. Qualified technicians for such installations are already governed by a wide range of layered provincial regulations which bind them to strict guidelines for the handling, storage, and transport of equipment, refrigerants, oils, gases and asbestos.

Our industry also has a lengthy track record with environmentally responsible EPR programs including the Refrigerant Management Canada (RMC) program and the Thermostat Recovery Program. These programs ensure that these components are safely collected and properly disposed of at end of life.

I respectfully request you to consider these aspects and discuss the specific issues with the industry associations mentioned above before finalizing any regulations for "fixed" installation products.