UPDATE – ON: Members – make your voice heard on proposed $7,500 recycling fee

As members are aware, on June 8, 2021, the Ontario Ministry of Environment Conservation and Parks posted the final Hazardous and Special Products (HSP) regulation (O. Reg.449/21) under the Resources Recovery and Circular Economy Act.

The CPA continues to press government to exempt all refillable propane cylinders from the new regulatory regime as proposed in the draft regulation posted in February 2021.  To this end, CPA Vice President of Government Relations, Allan Murphy, and Ontario Government Relations Director, Marcelline Riddell, met with minister office staff Jonathan Ricci, stakeholder relations manager and Brock Hamley, deputy policy director on July 13, 2021 to make the case for the exemption, given the sector’s 95% recycling rate.

The minister’s representatives could not adequately explain how the category moved from proposed regulatory exemption to inclusion in the regulation. They did, however, offer a technical briefing on the final regulatory requirements for CPA members in the near future, and committed to scheduling a meeting with the minister on this issue.

Meanwhile, the Resource, Productivity and Recovery Authority, the body now responsible for this product category, is consulting with industry on fees for the new administrative regime. The Authority is proposing refillable propane cylinder producers/first importers pay a $7,500 fee in 2021 to administer and maintain the registry. Obviously, this is not acceptable and we maintain that minimally, and as per other products, a fee of $75 should be the limit since there is nothing justifying such a fee.

In a webinar consultation held July 7 and 8, 2021, the Authority indicated registration fees would be set annually with the fees for 2022 to be determined in late 2021.

The RPRA is soliciting industry feedback on their proposals which may be accessed here.

The CPA will provide input on members’ behalf by the August 3, 2021 deadline. 

Key dates for impacted members are:

• July 31, 2021 – RPRA registration deadline for HSP processors, haulers and disposal facilities.
• October 31, 2021 – RPRA registration deadline for HSP producers.
• October 31, 2021 – HSP collection requirements come into effect.

The CPA will continue to update members on developments to this file.