Consultation to be launched in 2024 on the development of compliance guidance for sharing collection sites and buying and selling performance credits

The Resource Productivity and Recovery Authority (RPRA) will begin developing in the new year compliance guidance for producers and producer responsibility organizations (PROs) to clarify regulatory requirements related to:  

• Sharing public collection sites to meet accessibility requirements 
• Buying and selling performance credits to meet collection or management requirements 

The guidance is being developed to address compliance challenges identified by registrants.  

RPRA has engaged expert consultants to assist with this work and will consult stakeholders, including direct engagement with impacted stakeholders, starting in early 2024.  

RPRA is aiming to publish the compliance guidance by summer 2024. 

This guidance will aim to address: 

• How to resolve shortfalls in the number of sites required in communities when those shortfalls could be resolved by producers or PROs sharing collection sites. 
• How collection sites can be shared by producers or PROs. 
• Who is responsible when sites are claimed by multiple producers or PROs (for tonnage and for ensuring operating rules are met), and what contribution each PRO or producer makes to operating a system that includes shared sites. 
• Where producers and PROs have surplus or deficient tonnage, how and when to transact tonnage credits in an accountable manner while remaining compliant.  

The compliance guidance will apply to producers and PROs operating under the following regulations: 

• Batteries Regulation (O. Reg. 30/20) 
• Electrical and Electronic Equipment (EEE) Regulation (O. Reg. 522/20) 
• Hazardous and Special Products Regulation (O. Reg 449/21) 
• Tires Regulation (O. Reg. 225/18) 

The guidance will also result in changes to compliance bulletins and registry procedures related to collection systems and performance credits for the above regulations. 

Based on the differences between the above regulations and the Blue Box Regulation (O. Reg. 391/21), the guidance will not apply to the Blue Box Regulation. 

Information about the consultations will be made available via RPRA’s website, monthly newsletters, and direct email. Further details regarding the process will be communicated starting in January 2024. If you have questions, please contact us at registry@rpra.ca.