Refurbishment activities are…

Refurbishment activities are significantly less demanding compared to recycling. They require a lower amount of energy and effectively extend the lifetime of the original product. The Ellen McArthur foundation places Refurbishment activities above recycling and just below reusing a product. According to a 2018 report from the United Nations, Repair and Reuse can reduce the environmental footprint of products by 79% to 99% on material energy and emissions and 57% to 87% of process energy and emission, as well as 90% of production waste.

We believe that it is in the interest of this regulation to promote a less resource intensive behaviour that reduces the environmental impact of electronics. Counting the refurbished materials twice provides a significant incentive for companies in sponsoring and supporting repairing and refurbishing their used electronic products and helps an entire economy of firms specialized in this business.

There could be direct and major consequences of reducing this bonus. An impact is likely on those businesses who undergo major investments to adhere to the best international standards, such as R2, to provide consumers with a used and repaired choice. This bonus provides an important outlet for these businesses and their opportunity to expand and hire more resources. Another consequence will be the reduction of the refurbished ITT/AV materials, at the expense of both the choice of consumers and the relevant environmental impact.

We kindly recommend further analysis prior to changing this item in the current regulation and we are glad to offer any necessary support in evaluating further the impact this will have on Ontario’s environment economy.

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Kindly note we have a proposal on EEE materials that could be included, you will find the list below:

LARGE HOUSEHOLD APPLIANCES
Large cooling appliances
Refrigerators
Freezers
Other large appliances used for refrigeration, conservation and storage of food
Washing machines
Clothes dryers
Dish washing machines
Cookers
Electric stoves
Electric hot plates
Microwaves
Other large appliances used for cooking and other processing of food
Electric heating appliances
Electric radiators
Other large appliances for heating rooms, beds, seating furniture
Electric fans
Air conditioner appliances
Other fanning, exhaust ventilation and conditioning equipment

SMALL HOUSEHOLD APPLIANCES
Vacuum cleaners
Carpet sweepers
Other appliances for cleaning
Appliances used for sewing, knitting, weaving and other processing for textiles
Irons and other appliances for ironing, mangling and other care of clothing
Toasters
Fryers
Grinders, coffee machines and equipment for opening or sealing containers or packages
Electric knives
Appliances for hair cutting, hair drying, tooth brushing, shaving, massage and other body care appliances
Clocks, watches and equipment for the purpose of measuring, indicating or registering time
Scales

ELECTRICAL AND ELECTRONIC TOOLS (WITH THE EXCEPTION OF LARGE-SCALE STATIONARY INDUSTRIAL TOOLS)
Drills
Saws
Sewing machines
Equipment for turning, milling, sanding, grinding, sawing, cutting, shearing, drilling, making holes, punching, folding, bending or similar processing of wood, metal and other materials
Tools for riveting, nailing or screwing or removing rivets, nails, screws or similar uses
Tools for welding, soldering or similar use
Equipment for spraying, spreading, dispersing or other treatment of liquid or gaseous substances by other means
Tools for mowing or other gardening activities

TOYS, LEISURE AND SPORTS EQUIPMENT
Electric trains or car racing sets
Hand-held video game consoles
Video games
Computers for biking, diving, running, rowing, etc.
Sports equipment with electric or electronic components
Coin slot machines

MONITORING AND CONTROL INSTRUMENTS
Smoke detector
Heating regulators
Thermostats
Measuring, weighing or adjusting appliances for household or as laboratory equipment

AUTOMATIC DISPENSERS
Automatic dispensers for hot drinks
Automatic dispensers for hot or cold bottles or cans
Automatic dispensers for solid products
Automatic dispensers for money
All appliances which deliver automatically all kinds of products