Hazardous waste and hazardous recyclable materials - April 2020 News Bulletin

What’s new

Expansion of the Canadian Notice and Movement Tracking System (CNMTS)

Our system has expanded! You can now generate, print, and submit movement documents online, as well as submit your confirmations of recycling or disposal as required by the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations (EIHWHRMR).

Many permit holders are using the new functions. If you haven’t already upgraded to the online system, it’s an easy switch that we encourage you to make.

• The system allows you to fill movement documents and print multiple copies as needed
• It instantly flags errors and missing data as you prepare and submit movement documents
• It enables you to identify areas of potential non-compliance for each shipment (e.g. have you forgotten to submit a movement document in accordance with the timeline?)
• Provinces and territories are accepting movement document copies generated from the system
• The online form is consistent with the Transport of Dangerous Goods (TDG) shipping document, so there is no need to fill in two separate documents
• It is much easier and convenient than the six carbon-copy forms

Environment and Climate Change Canada (ECCC) intends to mandate the use of CNMTS and may not provide paper movement documents beyond the spring of 2021.

Be a leader and start using the electronic system.

News Bulletin - April 2020

Further improvements on the horizon

ECCC is participating in an initiative led by Transport Canada called the TDG Regulatory Sandbox on electronic shipping documents. This pilot project will study the feasibility and the safety impacts ofallowing electronic documents for the transportation of dangerous goods. This regulatory sandbox allows selected participants (carriers) to use an electronic shipping document during the transportation of dangerous goods in Canada and across the Canada-US border.

For more information, please contact the TDG Regulatory Sandbox Team at TDGEShipping-ExpeditionETMD@tc.gc.ca.

On your radar

Are you compliant with Canadian and International waste export requirements?

The export of mixed and unsorted or contaminated scrap materials may be subject to the EIHWHRMR.

You should be aware that even if the material you plan to export is not considered hazardous in Canada, such as plastic or paper for recycling, the regulations may still apply. This may be the case if:

• the receiving or transit country controls specific materials (i.e. quality specifications, or contamination standards to be met)
• the material is prohibited for importation by the receiving country
• the material is listed in the Basel Convention as ‘other wastes’ (i.e. waste coming from households)

When wastes or recyclables are considered hazardous by Canada or the receiving country, you are required to obtain a valid export permit and to comply with the applicable regulations. Proceeding without a permit could be unlawful and could result in you having to make all necessary arrangements to return the shipment to Canada or to an alternate destination. The Canadian Environmental Protection Act, 1999 (CEPA, 1999) and its regulations are enforced in accordance with the Compliance and Enforcement Policy for CEPA.

To help you determine if a permit is required, please consult the relevant provisions of the EIHWHRMR (sections 1.1 and 2.1) for waste or recyclable material considered hazardous for export. Also, the Basel Convention Export and Import Control Tool is a searchable database which provides specific information on national definitions of hazardous waste and import restrictions for Basel countries. You have a responsibility to ensure that you know what regulations and controls apply to your exports and to have all of the required documentation prior to exporting wastes or recyclables abroad.

Please take note that further changes are coming in relation to plastic waste. More information will be provided in our next bulletin.

Other regulations that could impact your waste or recyclable material exports

Did you know that certain exports can be subject to the Export of Substances on the Export Control List Regulations? These regulations apply to exports of substances on the Export Control List, as well as waste and material containing them.

Stay tuned for more information in our next bulletin.

Share your thoughts

We would like to hear from you. If you have a success story to share, feedback on your experience with the electronic notification system, or if you are just looking for general information on the federal hazardous waste regulation, contact your regional office:

• Pacific & Yukon: dechets-py-waste@ec.gc.ca
• Prairie & Northern: promconrpn-compropnr@ec.gc.ca
• Ontario: promcon-on-compro@ec.gc.ca
• Quebec: dechets-qc-waste@ec.gc.ca
• Atlantic: promo-atl-compro@ec.gc.ca

For more information, visit the Cross-border Movement of Hazardous Waste and Hazardous Recyclable Material Regulations overview page.