Accordingly, material considered hazardous under the EIHWHRMR will still require an export permit under the Canadian Environmental Protection Act if China is the intended destination for shipment.
With China's impending ban, shipments that proceed without proper permits will be considered unlawful exports.
Exporters will be fully responsible for repatriating the material to Canada or to an alternative destination, and could be subject to prosecution.
Implications contained in this notice may significantly affect foreign exports of materials and domestic program performance. RCO will continue to monitor ongoing developments and apprise members with more information as it becomes available.
We have reached out to Environment Canada to host a joint-webinar for RCO members in early 2018 to clarify Canada's position and actions, and to consider outcomes and alternatives for the Ontario market.