The Tire and Rubber Association of Canada, which represents sixteen major global tire manufacturers operating in Canada, as well as selected tire recyclers and suppliers, is pleased to offer our observations and recommendations to what is a very bold plan by Ontario to introduce individual producer responsibility for end-of-life tire management. Allowing individual market players to make choices on how they discharge their producer obligations may well prove over time to be a better approach, but we would urge caution to move slowly as this is an unproven model for tires. Moreover, the approaches in place in virtually every other province of Canada are working very well and achieve high collection and diversion results.
In our opinion, whether or not this bold new initiative can work in Ontario will be entirely dependent on the rules Government puts in place to achieve a level playing field and to not hinder normal market practices, for unlike many other designated materials, there is a thriving, robust end-of-life tire industry that collects, sorts, reuses and recycles the vast majority of used tires in the marketplace. The new rules must not disrupt this fine balance if it is to be successful.
To that end, the TRAC membership makes its commitment to do its level best to make this bold new idea work in the Ontario marketplace. With that said, here are our comments, observations and recommendations for your consideration. …
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