Québec Takes Notice of HRAI’s Advice and Removes Ductless Equipment from EPR Regulation

HRAI reported last month on ongoing discussions with Québec’s Ministry of the Environment and the Fight Against Climate Change, advocating on behalf of members for the exclusion of ductless equipment from the application of a new regulation that will mandate recovery and reclamation of end-of-life products by manufacturers.

With the support of manufacturer members and stakeholders residing in Québec, HRAI provided the Ministry with expert technical reports and data in support of the argument that installed ductless heat pumps (like other HVAC systems) are an intrinsic part of a building and should be recognized as “an integral part of an immovable to ensure its usefulness or facilitate its use within the meaning of article 901 of the Civil Code of Québec.”

HRAI is pleased to report that the Ministry has now confirmed that, after analyzing all the information received from industry, they have come the conclusion that the characteristics and the end-of-life management issues of ductless appliances are more similar to those of central systems, which are already excluded from the regulation, than they are to other included appliances, such as window-type or portable models. 

This is an important win for the industry and may have implications for regulations in other provinces.

HRAI encourages members to maintain their commitment to reducing or eliminating the quantities of residual materials that enter the waste stream, by ensuring that equipment is managed responsibly at end-of-life.

For more information contact Caroline Czajko or Tiffany Desjardins.

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