Ontario recently updated its extended producer responsibility (EPR) framework, increasing tire management targets and ending the $1 million cap on administrative monetary penalties. These changes demand stricter compliance and more detailed financial reporting from producers and producer responsibility organizations (PROs). This update directly impacts businesses supplying regulated products, tire haulers and collection site operators across the province.
What clients need to know:
- The $1 million penalty limit is being removed. For contraventions occurring after Sept. 21, 2026, administrative monetary penalties (AMPs) will no longer be subject to the previous aggregate $1 million cap. Exposure may materially increase where non-compliance generates economic benefits through cost avoidance;
- RPRA to receive more financial information. PROs in all five programs must report information, including collection and management costs, that may help RPRA estimate the economic benefit of non-compliance when setting an AMP. A one-time interim report is due in Dec. 2026 for 2023–2025 data, followed by annual reporting beginning in 2027;
- Tire obligations are increasing now. The tire management target rises from 65 per cent to 80 per cent for 2026 and each following year;
- The tire collection network must expand in 2027. Required collection sites will increase from approximately 4,300 to approximately 6,500, including 220 additional sites in northern Ontario; and
- Agreements, records and network stability matter more. New rules govern shared sites, management arrangements and changes to collection networks.
On Sept. 21, 2026, the Ontario government finalized amendments affecting the province’s tires, batteries, electrical and electronic equipment, hazardous and special products, and Blue Box materials EPR programs.1 The changes strengthen the Resource Productivity and Recovery Authority’s (RPRA) enforcement tools and introduce new requirements for tire producers and producer responsibility organizations (PROs).
Tire rules shift into a higher gear
An 80 per cent management target
Beginning in the 2026 compliance year, the tire management target increases from 65 per cent to 80 per cent.2 This intends to reduce disruptions in tire collection. Producers and their PROs should confirm their collection, processing and contracting arrangements can handle the extra volume.
The amendments also clarify which tires may count toward a producer’s management requirement. To qualify, a registered tire hauler must collect the tires from an Ontario location in the same calendar year they are counted.3 In addition, one of the prescribed management activities must be completed by March 31 of the year following the year in which the managed tires are used to satisfy the management requirement.4
The province did not adopt a proposed expansion of the “call-in” collection requirement. That proposal would have extended the program to any site generating tires and required a guaranteed response time. Instead, the program continues to apply only to specified sites, including municipalities, band councils, and Crown-owned and Crown-operated sites.
Approximately 2,200 additional collection sites
Beginning in 2027, the required collection network will grow from approximately 4,300 to approximately 6,500 sites. PROs must preserve the geographic distribution requirements of the existing network while establishing 2,200 additional sites across Ontario.5 At least 220 must be in northern Ontario.6
Earlier reporting and fewer mid-year changes
Starting in 2027, producers, or their PROs must report the number, location and contact information of each collection site they operate by Jan. 1 of each year. A reported site may be replaced during the year, but it cannot be closed unless a suitable replacement site is provided.7 These limits on mid-year changes are intended to make the tire collection network more stable.
More structure for shared sites and tire credits
The amendments clarify the rules that apply when PROs share collection sites or acquire managed tires for their producer clients. PROs that share a tire collection site must have a written agreement in place by Jan. 1, 2027, and by Jan. 1 of each following year.8 The agreement must explain each PRO’s responsibility for arranging collection from the site and how the collected tires will be managed during that calendar year.9
A PRO that acquires managed tires to help its producer clients meet their management requirements must also do so pursuant to a written agreement. The agreement must explain how the cost of the managed tires will be calculated, how the tires will be tracked and how the arrangement will help satisfy the applicable management requirements.10 PROs and producers should review their existing agreements to confirm that they provide the documentation and audit trail required by the regulation.
Enforcement exposure: No longer capped at $1 million
The amendments remove the previous $1 million cap on AMP orders for contraventions occurring after Sept. 21, 2026. The cap continues to apply to violations that occurred before that date.
The amendments also expand the conduct for which an AMP may be issued. A failure to enter into a required agreement for the acquisition of managed tires carries a base penalty of $75,000 for a corporation and $15,000 for an individual.11
The amendments also require PROs to provide financial information that may help RPRA calculate the economic benefit of non-compliance and determine the related portion of an AMP. PROs must now report information about the costs incurred to help producers meet their obligations, including its collection and management costs, the volume of materials associated with those costs and how it calculates the fees charged to producer clients.12 This includes any fee schedules, product groupings, cost-allocation methods and per-unit charges used by the PRO.
RPRA has previously imposed AMPs, including penalties at the former maximum, for failures to meet minimum management requirements. Although appeals of those penalties were resolved through mediation, RPRA’s enforcement history shows that it is prepared to use AMPs and pursue both financial and operational outcomes.13
How we can help
BLG helps businesses navigate producer responsibility requirements across Canada. We assist companies supplying regulated products for the first time by determining where obligations arise, identifying registration and reporting, collection and management requirements, and coordinating a multi-jurisdictional compliance approach.
For participants in the tire sector, we can assess how the amended Ontario rules affect your specific role, whether as a producer, PRO, collector, hauler, processor, retailer, distributor or service provider and review the contracts and compliance systems connecting those roles. We also help clients prepare for or respond to RPRA inspections, information requests, notices of non-compliance and administrative enforcement, including AMP proceedings and appeals.
