NGO comments to Ontario Regulations for Recycling of Electrical and Electronic Equipment (EEE) and Batteries under the Resource Recovery and Circular Economy Act (RRCEA)Blog
The Toronto Environmental Alliance (TEA) and HEJSupport support the following principles for this, and all regulations under the RRCEA:
● The top priority of the regulations needs to be to protect human and environmental health.
● We strongly support a move to full producer responsibility with high performance targets and outcomes supported by strict enforcement.
● Thermal treatment, even with energy recovery, should be considered only disposal, and not be considered towards a producer’s management targets.
● Registration, auditing and reporting to validate the final destination of materials, including through downstream processors, is essential.
● Transparency and public access to reports and results is essential for accountability and public confidence.
● Ensure the result is accessible for all Ontarians, understandable, fair and equitable.
● Regulations should incent design that leads to improved recycling, increased durability, and reduced resource consumption.