Hi John Fox, Thank you for…

Hi John Fox,

Thank you for the opportunity to comment on the Ontario Government’s proposed amendments to the producer responsibility regulations for tires, batteries and electrical and electronic equipment.

Regulations made under the Resource Recovery and Circular Economy Act, 2016:

• the Tires Regulation (O. Reg. 225/18)
• the Batteries Regulation (O. Reg. 30/20)
• the Electrical and Electronic Equipment (EEE) Regulation (O. Reg. 522/20)

Canadian Tire Corporation Family of Companies is supportive of the amendments which reduce burden and harmonize requirements with other Ontario Regulations.

However, we require further details relating to the proposed adjustments listed below, as they may potentially have financial impacts on our business operations:

Tires Regulation:

Remove audit requirements for supply data reporting and replace with an internal verification process which maintains oversight for compliance.
- The definition of “internal verification” needs to be clarified.
Expanding the requirement for producers to provide on-demand collection services to additional sources including municipalities with populations of less than 1,000, territorial districts and First Nation communities.
- How many additional collection locations and required collections does this represent, when compared to the current process.
Updating the existing access and privacy provisions to clarify what information is restricted in relation to individual producers.
- What producer information will be added the non-restricted information list.

Electronic Regulations:

Expand the requirement for producers to provide on-demand collection services to additional sources that have collected at least four tonnes of ITTAV equipment, including all municipalities throughout Ontario regardless of whether they are part of a producer’s collection network as well as businesses and institutions.
- How many additional collection locations and required collections does this represent, when compared to the current process.
Add a new promotion and education requirement related to visible fees to create transparency around who is charging the fee and what it will be used for.
- Details relating to the proposed promotion and education requirements are required.
- Will this be similar to the proposed amendment in the Tire Regulations: “Remove requirement for ongoing general promotion and education to instead allow producers to determine what promotion and education is necessary to meet their collection and management targets”.

John Fox, Policy Advisor, Resource Recovery Policy Branch at John.Fox@ontario.ca

https://ero.ontario.ca/notice/019-4656

Thank you.