I am responding on behalf of…

I am responding on behalf of Wine Growers Ontario to the posting of regulations related to ERO number 019-2579.

WGO supports the decision to maintain the bottle deposit system.

We are seeking clarity on a number of issues related to the regulations that have been posted.

1. From our reading of the regulations Ontario wineries will not be considered producers under the renewed blue box program and therefore will not need to register, report or conduct audits every three years. Can you please confirm.
2. If our reading of the regulations outlined in (1) is not accurate will the annual TBS (and/or LCBO report) be sufficient for any reporting requirements for Ontario wineries?
3. We are very interested in understanding if any changes to the bottle deposit system is anticipated specifically how it will be paid for, by who and is there any anticipated changes to Ontario wineries costs?
4. Currently Ontario wineries pay an Environmental Levy on every bottle sold. As the government is moving to full producer responsibility it is unclear to us why this levy would continue to be required. Will this levy be eliminated?
5. From our reading of the regulation Ontario wineries will not have promotion and education responsibilities. Please confirm.
6. From our reading of the regulation the bottle deposit will attach to every bottle of wine sold in Ontario regardless of the $2M de minimus threshold set out in the regulation. Please confirm.

Thank you and we look forward to continuing to work with you as the government implements this strategy.