ARTICLE
13 October 2026

Ontario Finalizes Amendments To The Producer Responsibility Regime

BJ
Bennett Jones LLP

Contributor

Bennett Jones is one of Canada's premier business law firms and home to more than 450 lawyers and business advisors in seven offices—Calgary, Toronto, Edmonton, Ottawa, Vancouver, Montréal and New York. With deep experience in complex transactions and litigation matters, the firm is well equipped to advise businesses and investors with Canadian ventures, and connect Canadian businesses and investors with opportunities around the world.
Ontario has finalized significant amendments to its producer responsibility regime, introducing an 80% tire management target, expanding collection networks to 6,500 sites, and removing the $1 million cap on administrative penalties. The changes also establish new financial reporting requirements for producer responsibility organizations across multiple product categories, fundamentally reshaping compliance obligations for producers operating in the province.
Canada Ontario Environment

On September 21, 2026, the Ministry of the Environment, Conservation and Parks finalized amendments to Ontario's producer responsibility regime under the Resource Recovery and Circular Economy Act, 2016. The amendments affect the Tires, Batteries, Electrical and Electronic Equipment (EEE), Hazardous and Special Products (HSP) and Blue Boxregulations, as well as the Administrative Penalties regulation. Key changes include a higher tire management target, an expanded tire collection network, new financial reporting obligations for producer responsibility organizations (PROs) and the removal of the C$1 million cap on administrative penalties.

Tires

The most substantive changes apply to tire producers and their PROs:

  • Higher management target: The management target increases from 65% to 80% of a producer’s average weight of supply for the 2026 performance year and each following year. Tires managed in 2025 remain subject to the regulation as it read on December 31, 2025.
  • Expanded collection network: Beginning January 1, 2027, the required tire collection network increases from approximately 4,300 sites to approximately 6,500 sites. At least 10% of the additional sites must be located in Northern Ontario, as defined in the regulations.
  • Collection site reporting: Producers, or the PROs acting on their behalf, must now submit a Tire Collection Report through the Resource Productivity and Recovery Authority’s Registry (the Registry) by January 1 of each year reporting their tire collection networks. Collection sites may be replaced during the year only in limited circumstances, including where a site closes.
  • Shared sites and managed tires: Beginning in 2027, PROs that share a collection site must enter into a written agreement by January 1 of the applicable year that outlines the obligations of each PRO and how the tires will be managed throughout that year. PROs must also have a written agreement in place before acquiring managed tires or performance credits from another PRO or from a registered hauler, processor or retreader.

PRO Financial Reporting

The amendments introduce financial reporting requirements across the Tires, Batteries, EEE, HSP and Blue Boxregulations. Starting in 2027, PRO annual reports must now disclose total costs incurred by the PRO, including collection and management costs per tonne and the methodology used to determine the fees charged to producers. PROs must also submit a one-time report by December 31, 2026, covering the 2023, 2024 and 2025 calendar years. This financial information will not be made publicly available through the Registry. The Resource Productivity and Recovery Authority has indicated that this information will be used to calculate avoided financial costs when determining administrative penalties.

Administrative Penalties

The amendments remove the C$1 million cap on administrative penalties for contraventions occurring on or after September 21, 2026. Contraventions that occurred before that date remain subject to the previous rules. New penalty items have also been added for tire-related contraventions, including failing to meet the management target and acquiring managed tires without the required written agreement.

Looking Ahead

Producers should engage with their PROs to confirm responsibility for the new reporting and collection obligations. Tire producers and their PROs, in particular, should assess whether their current arrangements can support the 80% management target for 2026 and the expanded collection network required in 2027. With the penalty cap removed, the potential financial consequences of non-compliance are greater.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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