Compliance Reviews or audits are conducted on a 3 to 4 year rotation with all Members of the Used Oil Associations across Canada.
The contractual document under primary review is the Membership Agreement signed by all Members. Although Alberta’s used oil materials recycling program does not utilize the Membership Agreement concept, they adhere to the same standard review process as the other provincial programs. The Quebec association (SOGHU) must proceed with an audit as stipulated in the Regulation respecting the recovery and reclamation of products by enterprises (EPR).
This standard review or audit process includes sample testing on Environmental Handling Charge (EHC) applicable sales, and based on this sample testing, assessing whether or not the EHC is being remitted on the applicable quantities sold, at the applicable provincial rate and remitted to the appropriate provincial association.
Also under review is the Article that states that a Member acknowledges and agrees that if a Member is selling or supplying Designated Material to another Member of the Corporation in good standing or is selling or supplying Designated Material for use outside of their respective Province, then no assessment or remittance of EHC is required with respect to that sale or supply.
Also, a Member supplying to another Member is to have a document on file acknowledging which Member will be submitting the EHC remittance.
We draw this information to your attention in preparation for when your next Compliance Review is scheduled.