The Ontario Tire Dealers Association is warning members that persistent tire‑collection disruptions may be contributing to the emergence of a black market for tire disposal and is urging caution to avoid regulatory and liability risks.
In a message to members, OTDA said it continues to receive daily reports from members of delayed pickups, growing on‑site stockpiles and collectors being removed from established collection networks. The association is asking members to keep reporting issues at their locations so it can provide accurate, real‑time information to provincial authorities working on solutions.
The association said it remains actively engaged with the Ministry of the Environment, Conservation and Parks, the Resource Productivity and Recovery Authority and other stakeholders as collection challenges continue. OTDA has submitted a detailed response to proposed tire regulation amendments and is advocating for changes that ensure consistent, timely collection and prevent sites from being left without service. Direction from the province is expected in the coming weeks as regulatory updates progress.
At the same time, OTDA said it is receiving reports and documentation indicating that some collection sites are being asked to pay separately for tire removal, signalling the development of what it described as a tire recycling black market. Members have provided invoices and related materials that OTDA said are helping it monitor the situation and assess the scope of the issue.
While payment for tire removal is not necessarily prohibited under the current regulatory framework, OTDA said the growing requirement for sites to directly fund removal raises concerns about system performance and breakdowns in the regulated network. The association noted that tire dealers have already paid recycling fees at the point of purchase through the retail chain, and that additional charges undermine the system’s intent.
“There is concern that improper handling or disposal of tires by haulers operating outside of the regulatory network could create liability for collection sites if materials are traced back to a site due to illegal dumping or improper storage and handling by the hauler,” the notice said. “If anything does not appear legitimate, please contact us before proceeding. Our primary concern is protecting our members.”
For members who have no alternative but to arrange and pay for tire removal outside the established network, OTDA recommended several precautions: Confirm the hauler is a registered business and request proof of RPRA registration where applicable; ensure a complete invoice is provided with full company details; be cautious of handwritten invoices, unusually low pricing or cash‑only arrangements; and ask where tires are being delivered, requesting supporting documentation when possible.
OTDA said it understands the pressures members are facing as disruptions persist and reiterated that its priority is protecting member businesses while continuing to push for systemic fixes. The association said it will keep members informed as discussions with regulators continue and urged dealers to share what they are experiencing on the ground.
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