Ontario finalized a series of amendments at the end of 2024 that impact four producer responsibility regulations, each with the aim of increasing flexibility and simplifying requirements for producers, while ensuring protection for the environment and consumers.
The changes involve four key regulations under the Resource Recovery and Circular Economy Act, 2016 (RRCEA): 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), and the Hazardous and Special Products (HSP) Regulation (O. Reg. 449/21).
The amendments began to come into effect on January 1, 2025, with implementation occurring throughout 2025 and into 2026. Many of the changes that give producers more options to meet their collection network requirements or reduce record keeping and reporting requirements, adjusting or extending performance targets, were implemented on January 1.
Related amendments were also made to the Administrative Penalties Regulation (O. Reg. 558/22) under the RRCEA to update or add contraventions.
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The Resource Productivity and Recovery Authority (RPRA) announced that it will soon provide detailed updates to support producers in understanding the impacts of the amendments.
“These updates will include guidance on how the specific amendments will impact reporting requirements such as supply, performance, and collection activities, and how to comply with the new requirements,” RPRA announced on its website.
Collection Network Flexibility
Changes allow producers more options in how they meet their collection network requirements. For example, producers are permitted to offset required collection sites in one municipality by establishing them in neighboring areas. They could also hold more collection events instead of setting up traditional sites, and all municipal collection sites, including those open seasonally, would count as permanent sites.
Additionally, producers have more time to adjust their networks following population updates and ensure that population density is accurately reflected in the number of required sites. A notable adjustment for the HSP Regulation is the option for producers to meet collection requirements by relying on existing municipal networks rather than setting up new ones.
Reducing Administrative Burden
The changes aim to streamline administrative processes, including the removal of the recycling efficiency rate requirements for certain materials, adjusting exemptions for small producers based on supply tonnage, and easing record-keeping and reporting obligations. These changes are intended to make compliance easier for producers and reduce red tape, according to the Ministry of the Environment, Conservation and Parks.
Regulation-Specific Adjustments
Each regulation has specific changes. For example, the Tires Regulation has a revised management target starting in 2025 and a higher weight threshold for regulated tires, meaning smaller tires would no longer be counted in reporting requirements. The Batteries Regulation extends the deadline for reaching a 50% management target from 2025 to 2030.
Under the EEE Regulation, producers are no longer able to count the weight of refurbished products as double for reporting purposes, simplifying the process.
The Hazardous and Special Products Regulation reclassifies refillable pressurized containers and shifts responsibility for managing antifreeze and oil filters to vehicle brand holders.
Visit the Environmental Registry of Ontario for the full list of amendments.
Related Professional Development Course
Attend the “Understanding Extended Producer Responsibility (EPR)” training course at CANECT 2025 to hear first-hand from the regulators, agencies, producers, and lawyers about the recent EPR program changes across Canada. This new course is being held May 1, 2025 at the CANECT Environmental Compliance and Due Diligence Training Event in Vaughan, Ontario. Visit www.canect.net for more information.
