CPA Public Affairs
September 2021

NEW – ON: New penalties proposed for producers of hazardous products

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The CPA will participate in a webinar on October 6, 2021 on a proposed administrative penalties regulation by the Ministry of the Environment, Conservation and Parks (MOECP).

On September 17, 2021, the MOECP posted the proposed regulation under the Resource Recovery and Circular Economy Act, 2016 (RRCEA) to strengthen enforcement tools for regulatory non-compliance. The penalties would apply to producers, manufacturers and importers of tires, batteries, electrical and electronic equipment, blue box materials and hazardous and special products (O. Reg. 449/21) and pertain to collection and end-of-life management of materials supplied in Ontario.

Under the RRCEA, the Resource Productivity and Recovery Authority is responsible for compliance and enforcement of the Act, including oversight of the producer responsibility framework. Despite the Authority's repeated statements in webinars and meetings that they would be using communication and education tools to ensure regulatory compliance with the new HSP regime, the proposed regulation “extends the use of administrative penalties to the Resource Productivity and Recovery Authority (Authority) to allow them to issue penalties to entities that don’t comply with the law”.

In addition, the government is planning to have the Authority post all administrative penalties issued on their public website “to ensure transparency and accountability.” The Authority will also be required to annually report to the minister and the public on the use of revenues from these fines.

The proposed fines are significant. For HSP regulated parties, for example, the proposed fines for a corporation could total $200,000 per infraction and $40,000 for an individual.

CPA members are encouraged to participate in MOECP’s October 6 webinar by emailing

Comment period on the proposed regulation is open until November 1, 2021. The CPA will submit comments on members’ behalf in advance of the deadline. Please provide Ontario Government Relations Director, Marcelline Riddell at with input you would like reflected in this submission by October 15, 2021.

For more information visit the Environmental Registry of Ontario website.



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