OFA recommends that small volume farm equipment manufacturers or retailers be exempt for this proposed regulation.  OFA also believes that farmers who source farm vehicles or farm equipment from outside Ontario should not bear the burden of responsibility to ensure that used tires are appropriately recycled.  OFA recommends that methods of promotion and education should be left to the tire producer’s discretion.  In addition, OFA believes that any added costs, fees, etc. should be clearly and separately noted on a tire invoice or bill of sale.