TRAC Bill 151 EBR Submission

The Tire and Rubber Association of Canada (TRAC) commends the Government of Ontario for its visionary plan for a waste free Ontario. And while today a waste-free Ontario may be aspirational, we know it can become a reality because our own sector is very near to becoming 100% waste-free. Getting that final way will require a partnership between industry and government but with a common cause, purpose and resolve we believe we can achieve our mutual objectives.

The current Used Tire Program operated by Ontario Tire Stewardship (OTS) has realized gains for Ontarians and industry stakeholders since its inception in 2009. Ontario has increased from 50% to 100% used tire diversion and begun investing in R&D, recycled rubber manufacturing and consumer education. OTS created sophisticated computer systems, manifest tracking and reporting and technological prowess for end-of-life tire (ELT) management. As intended by the enabling legislation, these gains were paid for by tire producers, brand owners and first importers and supported by a legion of processors, transporters, recycled rubber manufacturers and retailers, tire dealers and consumers.

Bill 151, Waste-Free Ontario Act will create a new ELT management scheme called Individual Producer Responsibility (IPR), in lieu of the OTS. Indeed, OTS will wind up, transition its assets and liabilities. TRAC understands the Government’s policy imperative for repealing the Waste Diversion Act, and we understand OTS cannot exist in its present form. That said, TRAC supports a transition going forward that is careful to preserve the important gains made to date and transfers the existing assets and liabilities in such a way that the industry and Ontario do not lose the successes and investments to-date.

Read Whole Document.