WEBINAR: Understanding Ontario’s new HSP Regulation with RPRA
Following last week’s “Understanding Your Requirements as a Hazardous and Special Products (HSP) Producer" webinar hosted by the Resource Productivity & Recovery Authority (RPRA), HRAI has acquired a better understanding of Category C (mercury-containing devices) products and producer definitions as outlined in Ontario’s HSP regulation taking effect this October 1, 2021.
The webinar was valuable, with the Authority reviewing specific producer requirements, producer hierarchy interpretation, as well as enforcement activities undertaken if noncompliance is identified.
An important takeaway from the webinar is that producers obligated under the HSP regulation are only those that meet both of the following criteria:
- Is a brand-holder with residency in Canada
- Has supplied mercury-containing thermostats in Canada in the past
RPRA explained that if there were no producers meeting the aforementioned criteria, the responsibility would then apply to producers with residency in Canada supplying thermostats that do not contain mercury in the Ontario market. However in the case of thermostat manufacturers in Canada, there are producers meeting the criteria, and therefore producers that have never manufactured mercury-containing devices are not subject to obligations under the HSP regulation.
For those who missed the webinar, the presentation slides and webinar recording can be found on RPRA’s website, here.
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For any questions, please contact Tiffany Desjardins or Caroline Czajko from HRAI.
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