On April 2, 2026, the Ontario Ministry of Environment, Conservation and Parks (MECP) proposed several amendments to the Extended Producer Responsibility (EPR) regulations. The EPR is part of the Circular Economy, which makes producers responsible for their products at the end of their life. The EPR regulations are implemented under the Resource Recovery and Circular Economy Act, 2016 (RRCEA).
Specifically, the MECP is seeking feedback on proposed changes to the following regulations:
- The Tires Regulation (Reg. 225/18)
- The Hazardous and Special Products (HSP) Regulation (Reg. 449/21)
- The Administrative Penalties (AP) Regulation (Reg. 558/22)
The EPR regulations are implemented under the Resource Recovery and Circular Economy Act, 2016 (RRCEA).
Amendments to Extended Producer Responsibility
As provided in the Environmental Registry of Ontario:
Proposed changes to the Tires Regulation
Expand call-in requirements to all sites – Add a provision requiring Producer Responsibility Organizations (PRO) to collect tires from any site that requests pickup and has 50 or more tires, and add a guaranteed response time during peak tire change times.
Add new management requirement – Require that collected tires be managed within three months of pickup from any site.
Proposed changes to the HSP Regulation
Revise recycling efficiency rate (RER) requirements – Delay the RER requirements for antifreeze and oil containers to 2028, and seek feedback on revising the RER for mercury-containing products.
Administrative change to clarify collection site requirements – Revise the regulation to clarify that at least one site is required in the original municipality for upper-tier offsetting, but not for adjacent offsetting. This does not change current requirements but adds clarity to the regulation.
Proposed change to the AP Regulation
Remove $1 million cap – Remove the cap on the maximum AP amount that can be issued for continuing and non-continuing contraventions.
The consultation period for the proposed amendments is open until May 2, 2026.
For a legal perspective on these changes, see the blogs by Aird Berlis and McMillan.
Previous Enforcement under EPR
In 2024, we reported on the first environmental enforcement action under the Blue Box Regulation and the EPR.
According to RPRA, the 2024 enforcement against Casper Sleep Inc. was charged (1) with failing to establish and operate a collection system for Blue Box materials in 2023 as required under s. 19 of O. Reg. 391/21 and (2) for failing to implement a promotion and education program in 2023, as required under s. 69 of the Blue Box Regulation.
Casper Sleep Inc. paid more than $340,000 in penalties.
Environmental Assistance
Environmental regulations are dynamic and require our attention, which is why we provide our monthly environmental newsletters. If you are not already receiving our newsletter, you can sign up below. For assistance with environmental compliance, contact Christopher Paré, P.Geo., or Ehasan Momeni, P.Eng., at 519-948-7300, Ext. 114 or Ext. 123, respectively.
Alan Hahn drafted this blog. Alan has an undergraduate degree in Environmental Studies and completed a graduate program in Environmental Management. He has worked in environmental management for more than 45 years. He has written hundreds of blogs and articles. His published work includes HazMat Magazine, BizX Magazine, Michigan Lawyers Weekly, GreenStone Partners, Manure Manager Magazine, and Progressive Dairy.
Christopher Paré, P.Geo, reviewed this blog. Chris is a senior geoscientist and manager of Dragun’s Windsor, Ontario, office. Chris has more than 30 years of experience on projects ranging from environmental site assessments (Phase One/Two ESA), excess soils, remedial investigations, soil and groundwater remediation, Permits to Take Water, Records of Site Conditions, vapour intrusion, and site decommissioning. Chris is a frequent speaker, author, and expert witness. See Chris’ bio.
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