Sarah Webb, President of YESS
Earlier this month, YESS President Sarah Webb had an exchange with a client regarding collection locations and obligations We have shared some of that exchange to help our clients understand how YESS can help them.
Q: Collection sites ± as our PRO how can enable you to complete our collection system on our behalf and ensure our system is complete?
A: YESS is using our established collection network to collect tires on your behalf. We have been working with haulers large and small all over Ontario to be part of our network to meet your needs. Currently we have just under 1,000 collection points in Ontario within the YESS Network.
All collection sites registered with ANY PRO are in the network for the purpose of meeting the RPRA accessibility target. YESS does not have to meet the accessibility target as an individual PRO but all PROs must meet the accessibility target together. It would be impossible for each PRO to meet it individually! We each would have to have more than 8,000 unique collection sites. There just aren’t that many
Q: Can YESS assist us in how we capture our tires supplied in 2019? This will directly impact our future collection targets. Ensuring the reporting is clear and efficient is vitally important.
A: You should be tracking your tires sold into Ontario the same way you did with OTS or using whatever internal sales tracking system that works for you to capture the numbers on an annual basis. You do not need to submit it to us on a monthly basis. We are your compliance resource if you have questions regarding what should be counted or not please call for support. We are happy to come out and work with your company to ensure you are tracking your sales appropriately (auditable) for your future reporting requirements to calculate your 2021 obligation.
We will be providing a full audit summary package later in the year to help you prepare for your first audit sales requirement in 2020/2021.
Q: Will YESS complete our collection and recovery target performance audit? How is this done?
A: YESS, we will complete a full report for you on your collection and recovery target performance at the end of the year and submit it to RPRA if you have delegated in your RPRA account to do so. If you have not or are not sure if you want us to report on your behalf, I strongly recommend contacting RPRA to understand the implications of doing it yourself!
The report is based on the information in TreadMarks that tracks the collection, hauling and processing of all the tires we collect in 2019. We have the TreadMarks system data and all of our vendors audited by a third party to validate the information. This information and the allocation to our Producer clients demonstrates how much we have recovered to meet your recovery obligation.
Q: Will we see monthly reports, so we know how much of our target is being achieved and there are no surprises at reporting time?
A: YESS! We are in progress of creating the dashboard reports that will be sent to each of our Producer clients quarterly to demonstrate our progress on meeting your compliance. The report will provide your diversion completed to date against your 2019 obligation total and your retail collection volumes (if applicable) that contribute to your diversion obligation. We welcome your suggestions of any other information you would like highlighted in this quarterly report.
Q: What else do I have to do in 2019 as a Producer? What is next?
A: You have already done all the heavy lifting!
You have already:
– Registered with RPRA as a Producer
– Reported your 2014, 2015, 2016 sales numbers for your 2019 Obligation
– Selected YESS as your PRO.
You may have, or need to:
-Register in YESS TreadMarks as a Producer – www.yessolutions.ca
– Register in YESS TreadMarks as a collector if applicable ± No YESS QR code – no tire pick-up!
– Visit our website to find a YESS hauler or confirm with your current hauler they are with YESS. (We realize some locations may have commercial relationships with other haulers that are not with YESS, that is okay too! They just won’t count against your obligation, but others will.)
The next big due date is MAY 31, 2019
This is the deadline for you as a producer to report to RPRA your sales volumes for 2017 to be added to your rolling three-year average to calculate your obligation for 2020. This was on the same summary as your 2014-16 data sent from OTS. So, you already have it!
As the information for 2017 came directly from OTS, you do not need to provide an audit for this data in May. It can be submitted as is. (unless you found errors in your submission for 2019 or used a different weight for your tires).
It might seem like you are doing less, but that is true! We are taking on the work! This is part of the simplicity of how we manage our program: we want you to be able to focus on selling tires and not on managing end-of-life tires!
YESS – Our Responsibilities to You
Just as you have taken on the responsibility to meet your annual obligation with RPRA.
YES Environmental Services & Solutions (YESS) also has obligations to meet under the Tire Regulations.
The Resource Productivity & Recovery Authority (RPRA), mandates that Producer Responsibility Organizations (PROs) like YESS must ensure we meet and maintain compliance with the legislation.
Below is a brief synopsis of RPRA’s most current compliance bulletin #7 that outlines for you what YESS is reporting for you and what we have to report as a PRO under the new regulation. For the full bulletin, click here.
PROs reporting on behalf of producers
Tire producers are required to ensure that at least 85 per cent of the tires are collected and recycled, retreaded or reused. As your PRO, YESS is responsible for organizing the collection, recycling or retreading activities and all the documentation on your behalf.
PROs will report the following information for each producer by May 31, 2020
- Number and calculated weight of tires used and collected, sent for retreading, reuse on a vehicle or a new purpose;
- Actual weight of processed tire materials, by material type;
- Date and location of collection events held;
- Details regarding the tire collection and management system.
Self-Reporting by PROs
In addition to reporting on behalf of producers, PROs will be required to report on their own activities each year, beginning in 2020. PROs will be required to account for:
- Total actual weight of processed tires;
- Number and calculated weight of total tires used and collected in Ontario;
- Number and calculated weight of total tires sent for reuse on a vehicle;
- And number and calculated weight of total tires sent for reuse for a new purpose, amongst other considerations.
There are two tire categories for reporting purpose: tires greater than 700 kg (large tires) and tires equal to or less than 700 kg. The deadline for reporting this information will be May 31 of each year, beginning in 2020.
New Invoicing Details from YESS
YESS is moving to harmonize our monthly invoicing. Beginning in March, if you receive invoices from YESS, they will be generated on the 15th of each month.
We will be charging a 10 per cent late fee on the amount owing passed the customary net 30-day deadline, as stated in your agreement.
1. YESS – 75 Producers have selected YESS as their PRO! More individual producers than any other PRO.
2. YESS – Almost 1,000 collection locations are in our tire recycling network!
3. YESS – We are currently working with 5 processor partners (ON, QC, MB, NY) and working on new innovative alternatives and partners for 2020.
4. YESS – We pay our 10+ hauling partners directly for their services to ensure all our vendors are treated and paid fairly.
YESS – You Can Show Tire Recycling Fees on Invoices,
But It Comes with Some Strings!
On January 1, 2019, tire producers became individually responsible for meeting tire collection and resource recovery targets. With this obligation comes the responsibility for Producers to pay the costs associated with the collection and recycling of tires managed by a PRO. YESS, that is us. With Multiple PROs and multiple fee models out there, one fee does not fit all like OTS.
Any decision by a producer or retailer to identify these costs as a separate charge in any advertisement, invoice, receipt or similar record provided to the end consumer is a business decision for that producer or retailer.
1. If a producer or retailer chooses not to show the fee as an additional line item and build it into the price of the good, there are no requirements to validate the fee or use of the funds collected or additional education of the consumer on the program.
2. If a Producer is selling business to business (commercial sales) and not to the end user of the tire, the fee can be broken out as a visible line item with no requirement to provide a RPRA audit or reporting for the use of the fees.
3. If a producer or retailer decides to show these costs as a separate charge to the end user /consumer, the producer or retailer must do so in accordance with the requirements set out in the Tires Regulation
(O. Reg. 225/18).
These requirements include:
- Specific information must be provided to the consumer about the charge on the invoice or receipt. An example of an acceptable statement in relation to a separate resource recovery charge is:
[Name of Producer] is responsible for imposing this charge. It is being used to recover the cost of collecting and recycling the tires you are buying today when they have reached the end of their life and are returned by you.
- The charge must accurately reflect the costs incurred in relation to resource recovery (e.g. associated fees from YESS and RPRA, audit and administrative costs, any other costs incurred to ensure you are compliant with the regulation);
- An annual report and audit must be submitted each year relating to how much was collected as a visible fee and how the charge was used against recycling costs.
- RPRA has engaged an audit firm to help them set the standard for what the reports will be required to contain and what can be used as acceptable backup and third-party validation of the costs used. Once we receive the details from RPRA we will provide you with all the details required to meet this reporting obligation.
Still have questions? We’re here to help. Contact YESS at 1-888-310-YESS (9377) or at firstname.lastname@example.org