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As you are aware Natural Resources Canada (NRCan) started a process to adopt higher efficiency levels for dry Type Transformers that are harmonized with DOE2016 (USA Department of Energy) efficiency levels currently in effect in the USA. These NRCan regulations were originally intended to come into effect January 1st, 2018. However, this has since been delayed and the earliest possible effective date for the NRCan higher efficiency regulation in Canada is now early 2019.

Due to the jurisdictional separation of federal and provincial governments in Canada, federal and provincial legislation for energy efficiency must be complementary for it to be meaningful. For minimum energy efficiency requirements for dry type transformers the NRCan legislation establishes the requirements for importation into Canada and movement of goods within provincial borders and individual provincial legislation establishes the same requirements within each province.

In anticipation of the NRCan legislation originally intended for January 1 2018, The Ontario Ministry of Energy established legislation to also become effective as of January 1 2018 for Ontario. However, in the absence of the NRCan legislation the Ontario legislation alone is incomplete and can’t be implemented as intended.

Under these circumstances, while goods manufactured and sold in Ontario require compliance with the provincial legislation, goods manufactured and sold elsewhere in Canada need not comply. Furthermore, Ontario manufactured goods along with goods manufactured elsewhere that do not comply with the Ontario legislation can be legally transported back into Ontario. The Ontario legislation also does not address compliance reporting and enforcement requirements as this is covered by the NRCan legislation.

To our knowledge, no other province in Canada has established legislation in this regard to date.

This unintentional conflict in effective dates of this legislation cannot be readily corrected by Federal or Ontario Provincial legislatures as rescinding or expediting legislation is neither possible nor practical. Therefore, we are left with this unintended consequence in Ontario that implies a level of flexibility and suggests waiting for the arrival of the NRCan legislation before compliance can be accommodated and expected in the Province of Ontario.

Rex Power Magnetics supports the shift to these more stringent efficiency requirements and is fully prepared to offer product and pricing that comply with current and future higher efficiency levels. We will continue pricing product that meets current NRCan energy efficiency requirements. We will also provide pricing to customers who choose to acquire product which meets the higher efficiency requirments stipulated by the Ontario legislation before the arrival of the fully complementary NRcan legislation.

We have consulted with both Federal and Provincial authorities and concluded that this is the most appropriate course of action we can recommend to our customers until the new NRCan legislation comes into effect now expected early 2019. Please do not hesitate to contact us for any questions you may have.

Rex Power Magnetics