(1) Questions About Regs: a…

ERO number

019-0048

Comment ID

32177

Commenting on behalf of

MEDJCT, Scale Up Services Branch

Comment status

Comment approved More about comment statuses

Comment

(1) Questions About Regs:
a. Are producers (small and large) equipped to sustainably manage the return of its EEE and battery waste? Have consultations explored what resources will be required by producers? What are the economic implications for producers (new jobs, expansion of facilities to manage waste, new technology, etc)? In other words, what are the economic merits and challenges to the producer?
b. How does this economically impact smaller producers who may not have the necessary infrastructure and resources for increased waste management?
c. How does this impact producers not in Canada? Would these new regs negatively affect U.S. producers bringing in EEE and batteries into Ontario?
d. Does this new reg limit producers ability to grow and scale in the short or long term?

(2) Opportunities:
a. Potential opportunities exist here for cleantech sector in the recovery of waste materials converted to new materials, improving the RER, cleaner and greener disposal methods, etc.

(3) General Feedback:
a. The idea of multiple waste recovery approaches (a combination of the permanent collection locations, collection events, collection from residences and mail-back) may be more successful. I think this gives people options since this requires behaviour change in waste management and is voluntary for the customer.
b. Unclear how the regs put the onus on the producers to incentivise behaviour change.
c. Unclear how the regs impact the producer supply chain.