Frequently Asked Questions
If I am a SORAC member, do I also need to fill out the RECYC-QUÉBEC Information and Notice of Intent form?
Yes, you need to fill it out because it is a regulatory requirement subject to Section 6 of the Regulation. You must communicate your intention to join the SORAC program or to set up your own program and provide the information required in Section 6 of the Regulation. The form can be found at: https://www.recyc-quebec.gouv.qc.ca/sites/default/files/documents/formulaire-renseignements-avis-intention-REP-en.pdf.
December 1st, 2022.
You can join SORAC at any time. However, you will have to declare the sales of targeted products marketed from December 1st, 2022, to the enrolment date and pay the eco-fees applicable during this period. See page 21 of the members guide for more information.
A PRO is a recognition granted by RECYC-QUÉBEC under the Regulation Respecting the Recovery and Reclamation of Products by Enterprises. SORAC is in the process of becoming the PRO for the recovery and reclamation of commercial refrigerating appliances.
If you are a business subject to Regulation Q-2, r. 40.1. of the Act Respecting the Reclamation of Products by Enterprises, you are required to recover and reclaim the concerned products or have them recovered and reclaimed by means of a recovery and reclamation program developed in accordance with Section 5. You do not have to enrol in the SORAC program, but you will need to set up your own recovery and reclamation program and report to RECYC-QUÉBEC.
No, the article 8.1 of the Regulation prohibits this practice as of September 30th, 2022.
The annual membership fee is the only cost to participate in the program. It is the eco-fees collected that will finance the entire process of collecting and recycling the appliances. Membership fees for 2022–2023 are based on the size of the business and range from $500 to $1,000. See page 4 of the members guide for more information.
SORAC's policy is that eco-fees are collected and reported by the company marketing the product directly to the end user located in Quebec. In the event that the company selling the product to the end user is not a member of SORAC, the responsibility lies with the first importer or manufacturer if the latter has an establishment in Quebec.
The eco-fee must be included in the price. However, according to Section 7 of the Regulation, the eco-fee charged for recovery and reclamation of the product must be internalized in the price as soon as it is placed on the market. Making it visible is not mandatory.
It is not mandatory to make the eco-fee visible and it is not prohibited to do so. The decision is up to the member. However, the information must be disclosed as soon as the product is put on the market. For purposes of awareness and consistency, SORAC recommends that the eco-fee be visible. See page 5 of the members’ guide for more information.
Transportation is not your responsibility or your customer’s from the moment the product is at the edge of the company's door or dock. A voluntary collection service in which members can participate for financial compensation is initially available for the collection of devices. For example, when delivering a new device, you can recover the device at the end of its useful life. In a second phase of the program, a phone-based collection service and drop-off points could be introduced.
According to Section 20 of the Regulation, the collection service must be free of charge. It should be noted that pickup and transportation will be free of charge for appliances that are ready to be loaded into the truck, i.e., next to the door. Members that agree to take back an appliance but need to move it from inside the building to outside are free to charge the customer for the “uninstallation or relocation” of the appliance. See page 24 of the members guide for more information.
No, if the device is intended to be sold outside Québec, it is not one of the targeted devices. It will not be recycled in Quebec.
If a customer from outside Quebec comes to buy a product in my store in Quebec, are they exempt from paying eco-fees?
No, it should be declared since the buyer, at the time of sale, is in Quebec and there is no guarantee that the product will not remain in Quebec.
Do we collect the eco-fees if we bill a business outside the province of Quebec but ship the refrigerator to Quebec? In this case, we charge the Quebec sales tax.
Yes, the eco-fees should be collected and reported.
What should I do if a customer tells me that one of my competitors is not charging the eco-fee, giving them an unfair advantage?
You can tell them that your business is acting in accordance with the Regulation and thus helping to minimize environmental impacts by keeping these appliances out of landfills. You can tell them that the way eco-fees are displayed is variable. An eco-fee can be included in the price of a product without being displayed. You can also refer this customer to SORAC for appropriate follow-up. You can also refer to the list of SORAC members posted on the SORAC website.
For equipment orders that will be shipped after December 1st, but already invoiced, do I have to collect the eco-fee at the time of delivery?
For sales made before December 1st 2022, even if the product is delivered after that date, you do not have to collect the eco-fees. They will only apply on sales made after December 1st 2022.April 1st: The partnership agreement with PureSphera takes effect on April 1st. décembre 2022, même si le produit est livré après cette date, vous n’avez pas à percevoir les écofrais. Ceux-ci vont s’appliquer qu’à partir des ventes réalisées le 1April 1st: The partnership agreement with PureSphera takes effect on April 1st. décembre 2022.
When a submission or a sales contract was signed before December 1st but will be delivered and invoiced after December 1st, do we have to charge an eco-fee?
No eco-fees need to be collected if the contract was signed by the customer before December 1st 2022.
No, it does not apply.
If some Quebec-based companies are not SORAC members, but they should, what are our obligations, if any, when we sell products to them from outside the province?
If these companies are located in Quebec and are therefore the first importers of the product, the regulation stipulates that it is their responsibility to collect the eco-fees. If you sell directly to the end user, you are responsible for collecting the eco-fee, even if you are based outside the province.
No, it is not planned at the moment. However, we collect all questions from affected companies as part of the program implementation process and they will be forwarded to the board members. Various adjustments to the program may be made in a second phase of the program.
Can you confirm that products used to store medicines and vaccines are included in the new regulation?
Yes, they are targeted products.
Yes, other components such as foam insulation, electronic components and others must be recycled. In addition, these devices are not considered an integral part of a building because they do not serve a vital function and do not alter the structure of the building if moved or removed.
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