Automotive Materials Stewardship has submitted its feedback on the draft Hazardous or Special Products (HSP) Regulation that was released on February 11 for a 45-day consultation period, ending March 28.
The AMS submission to the Ministry of the Environment, Conservation and Parks and the draft regulation can be downloaded from the AMS website.
The submission proposes revisions to the draft HSP Regulation that AMS recommends for maintaining the successful operation of the recycling program for automotive HSP, while also supporting the continued development of a circular economy in Ontario. It includes seven key recommendations related to:
- Fair Allocation of Management Responsibilities
- Collection Site Requirements
- Product Categories
- Management Targets
- Recycling Efficiency Rates
- Continuation of Existing Collection Sites
The submission also includes a detailed Appendix with suggested technical amendments to some sections of the draft regulation.
When final, the HSP Regulation will introduce significant changes to how producers will meet their obligations for their materials. Members are encouraged to familiarize themselves with the new regulatory framework and their producer responsibilities, including:
- The implementation of individual producer responsibility (IPR) replacing the collective responsibility for managing materials that producers have had under the AMS Industry Stewardship Plan since 2017.
- Producers having the option to establish their own recycling system or join a Producer Responsibility Organization (PRO) to carry out their individual responsibilities.
AMS has initiated the work necessary to deliver services as a PRO to assist producers in meeting their new responsibilities once the regulation is filed. We will be contacting existing members soon to discuss the transition and the steps you can take to sign up for our PRO services.