Subject: ERO 026-0218 –…

Subject: ERO 026-0218 – Support for Proposed RER Timing Amendment

To whom it may concern,

As a producer obligated under Ontario’s Hazardous and Special Products (HSP) regulation, we support the proposed amendment to shift the effective date of the Recycling Efficiency Rate (RER) requirement for oil containers and antifreeze from 2027 to 2028.

Reaching a 95% RER is contingent on having adequate and dependable processing infrastructure in place. The system is currently in transition, including the build-out of new processing capacity, which requires sufficient time for site development, permitting, equipment installation, and commissioning.

Implementing the RER requirement before this infrastructure is fully operational risks misalignment between regulatory timelines and system readiness, potentially creating compliance challenges for producers despite good-faith efforts.

Postponing the RER effective date to 2028 represents a practical and reasonable adjustment that will support successful implementation and the long-term performance of the system.

Sincerely,

Wakefield Canada Inc.
Mageswaran Palany