Prior to the change in…

Prior to the change in recovery rates from 85% to 65%, the tire recycling system was functioning just fine. Clarification was only needed around the balancing of "credits", when one PRO / Processor recycled more tires than they were contracted to recycle, and whether or not those "credits" were subject to free market conditions. If this singular issue had been correctly addressed, the system would still be functioning properly. It now seems that these proposed changes are attempting to get the implied recovery rate back near the 85% rate without someone simply owning the mistake in changing it in the first place and fixing their error. Most of the changes to the tire regulations being proposed are unnecessary if the rate was simply changed back to where it was.

Nevertheless, at the heart of the matter at hand, ALL tires sold within Ontario should be required to be recycled within the existing Ontario recycling fee / PRO structure, ALL tires sold in Ontario should be subject to the recovery fee rules, and ALL tires sold within the province should be recycled within the provincial boundaries. We have more than enough recycling capacity within the province for all tires, save for some OTR tires, and with a proposed OTR processing facility coming online in 2027, EVERY tire sold in Ontario CAN and SHOULD be processed in the province. When Ontario processors are importing tires from other jurisdictions to satisfy the demand for tire crumb in Ontario, further supporting Ontario jobs and businesses, how do we justify allowing the export of tires from the province?

Additionally, there is another loophole needing to be closed - semi-truck tires that are retread and then resold in the province should once again be required to pay the recycling fee, as these tires can be retread 3-4 times after the original "new" sale, and they end up passing through the recycling network - dealers, haulers, and many times to the processors - before working their way back into the retread network, and they are credited as a recovery rate of 100%, yet there are no new monies associated with the repeated "credit" of effectively the reselling and recycling the same tire. All retread shops should be subject to submitting the recycling fee when a retread tire is sold in Ontario.

Item 7, as previously stated, is an absolute must. There is no excuse to be exporting Ontario tires for processing beyond our provincial borders. Absolutely none.

Lastly, processors need a voice in the recycling fee rates and structure. The current PRO structure, with the largest PRO masquerading as a non-profit company, yet owned and operated by the biggest producers with the largest obligations, effectively control rates within the province. There has been no meaningful increase in the fees paid to processors in over 10 years, while wages, electricity rates, fuel costs, insurance costs, and equipment pricing has skyrocketed. If Ontario wishes to maintain a healthy and effective recycling infrastructure, processors need a meaningful increase in rates paid for recycling. The Ministry can pretend that it is an open market, but with the world's largest tire manufacturers effectively dictating the recycling rates to the processors through their own PRO, who owns zero processing infrastructure of their own, the playing field is nowhere near level in this regard. There should be a fixed increase in rates paid to processors over a negotiated window of 5-7 years so that the millions of dollars in processing infrastructure can be properly maintained and improved over time. The existing processing base rate should be fixed at no less than $400 / tonne for PLT and MT beginning in 2027 and have fixed increases over the next 5 years.