Effective date July 1, 2021…

Effective date July 1, 2021 seems aggressive given costs and structure of the program(s) are yet to be in place. Is the 18 month allowance for producers to get their collection network and ministry approvals account for that? Making the start of the program truly January 1st 2023?

Does the 18 month allowance mean that charges/remittance for the program by producers is also deferred for that period?

Product Care only provider today in Ontario. Will that mean all producers need to register with Product Care by May 31, 2021?

Producers required to summit 3 year sales history – both sales $ and weight? Please confirm. If weight is required, are producers reporting weight of finished product (full) or just weight of packaging to be recycled? There needs to be consistency.

Ministry also sights new program would result in lower costs for producers:
Under a producer responsibility framework, producers can achieve operational cost savings in several ways, including through:
· negotiating pricing and contracts with service providers at lower prices
· contracting larger volumes of materials to larger businesses that can operate more efficiently due to economies of scale
· re-designing their products
investing in new innovative waste management technologies and practices
Negotiating lower price with service provider- has the Ministry explored that with Product Care, in order to make that statement?

Investments by producers in waste management technologies – not the business of manufacturers today. Are there government grants being purposed to incentivize businesses in that direction? Is this something industry associations have explored or commented on?

Product Care today operates through:
Recycling locations in Ontario are comprised of municipal special and hazardous waste collection depots, municipal events where paint and HHW materials are collected, and non-municipal sites who collect leftover paint only, such as retailers. In 2016, Product Care continued to work with the program’s retail recycling locations to strengthen this key element of the recycling system for Ontario residents.
Is the understanding that these municipal locations will no longer operate?
On June 30, 2021, all materials managed by the MHSW Program are expected to be transitioned to a new producer responsibility regulation, with the addition of select mercury-containing devices. The main purpose of the new proposed Hazardous and Special Products (HSP) regulation is to make producers environmentally accountable and financially responsible for collecting and managing HSP at end-of-life.
and...
In order to reduce burden, we are proposing that collection site operators (e.g. municipalities and retailers) do not need to register and report to the Authority, although they would still be required to keep records related to HSP at their site.

Seems like Municipalities will continue to operate collection sites but not have cost burden or reporting responsibilities - please clarify?

The new proposed Hazardous and Special Products regulation would also encourage greater consumer accessibility to HSP collection sites or services, which may help prevent additional hazardous materials from going to landfill and reduce the amount of resources from these products that are lost to disposal, which contributes to the province’s broader commitment to address litter and reduce waste in Ontario. How will the new program provide greater accessibility to collection sites? Has the Ministry identified an issue with accessibility today? Or are consumers sending materials to landfill because curbside trash pick up is the easiest and most convenient way of disposing materials? Will that change? Will Ministry fine consumers that don’t deal with hazardous waste in a responsible manner?

Producers of Category A Products and Category B Products
22. (1) On or before July 1, 2021, the following producers shall implement a promotion and education program during each applicable performance period in accordance with subsection (2):
1. Producers of Category A Products who are required under section 9 to establish and
operate a collection system for Category A Products and under section 17 to establish
and operate a system for managing Category A Products.
2. Producers of Category B Products who are required under section 9 to establish and operate a collection system for Category B Products.
How will producers be in a position to do this by July 1, 2021 if they have 18months to put a collection plan in place? What would producers be communicating on July 1st?