Date: May 1, 2026 Resource…

Improving the management of end-of-life tires (ELTs) is a critical priority from environmental,
social, and business perspectives. As the only province operating under an Individual Producer
Responsibility (IPR) regime, Ontario has sought to lead Canada in ensuring timely collection and
processing of ELTs. However, experience has shown that the current IPR framework has created
significant challenges—many resulting from unintended consequences—that have effectively
frustrated the good intentions of IPR.

Michelin supports Ontario’s ambition and commitment to responsibly manage ELTs. That said, we
respectfully urge the province to undertake a careful, comprehensive review of the existing
regulation to identify root causes and recalibrate the system, while avoiding further unintended
impacts.

In recognition that timely action is required, Michelin offers the following comments on the
proposed amendments. Our submission is intended to provide constructive, practical input toward
a regulatory framework that more effectively strengthens ELT management in Ontario. Michelin
submits that, as currently structured, the IPR system presents challenges across three
dimensions: environmental, social, and business. Michelin addresses each below.

Environmental Considerations

Consistent and reliable ELT collection across Ontario is essential. Broad geographic coverage is a
reasonable objective in a province of this size. However, the proposal to allow any registered site
to request pickup from any Producer Responsibility Organization (PRO), on short notice, risks
generating negative environmental outcomes—particularly increased emissions.

Requiring PROs to respond rapidly to ad hoc pickup requests—potentially when sites accumulate
as few as 50 tires—would likely result in more trucks moving smaller loads across long distances.
This loss of logistical efficiency would increase fuel use and emissions, undermining
environmental goals.

In practice, efficient ELT management depends on route planning, consolidation of loads, and
predictable volumes. Short-notice, low-volume pickup requirements materially undermine these
efficiencies and reduce the ability of PROs to design environmentally optimized collection
networks.

A risk-based and proportional approach where collection frequency aligns with material volumes,
site risk, and regional realities, would better support environmental outcomes while maintaining
operational feasibility.

There is also an opportunity—and a responsibility—to support Ontario-based end-use markets for
ELTs. Directing material to in-province processors can yield environmental benefits when aligned
with existing capacity and demand. Ontario already benefits from a developing recycled asphalt
pavement (RAP) ecosystem and early-stage alternative outlets. However, without appropriate
planning and market analysis, regulatory changes could disrupt these value chains and produce
counterproductive results.

The overarching objective should be to support efficient collection operations, and foster material
recovery and local end markets. Treating tire materials as valuable resources—rather than
waste—will reduce carbon intensity and strengthen Ontario’s circular economy.

Ultimately, the success of Ontario’s ELT framework should be measured by environmental
performance, economic sustainability, and public trust, rather than by prescriptive operational
requirements that may unintentionally impair system performance.

Social Impacts

Recent public commentary has highlighted concerns that Ontario tire purchasers—who already
pay an environmental fee at point of sale—may ultimately bear the cost of system inefficiencies
through higher fees. In addition, increased truck traffic resulting from less optimized collection
routes may contribute to road congestion and associated safety risks. These outcomes run
counter to public expectations underpinning the Resource Recovery and Circular Economy Act,
2016 (RRCEA).

Business Impacts

Collectively, the environmental and social concerns are compounded by significant business
impacts. The current IPR regime—and the proposed amendments—risk imposing rigid controls
over suppliers, logistics, production timelines, and material flows, often disconnected from market
realities.

Economically viable downstream processing and utilization of ELTs are essential to a self
sustaining system. Ontario already has the foundation of an ELT processing ecosystem;
regulatory uncertainty or misalignment risks undermining these investments. Rather than
destabilizing existing value chains, a thoughtful review of the system could allow the province to
adopt best practices from other jurisdictions, clarify PRO accountability, and stimulate innovation
and job creation in ELT-derived markets.

Recommendations

In light of these considerations, Michelin respectfully urges the government to:

Pause the current penalty framework to prevent further strain on the system while
adjustments are considered;

Reconvene key stakeholders to pinpoint current operational challenges limiting progress
and identify a viable path forward; and

Identify lessons learned and proactively incentivize growth markets for ELTs, supporting
material recovery, innovation, and long-term system sustainability.

Michelin remains committed to working collaboratively with the province to ensure Ontario’s ELT
management framework delivers on its environmental objectives while remaining socially
responsible and economically viable.

Respectfully submitted by: Michelin North America (Canada) Inc.