Definitions of large and small producers for HSP supply data verification reporting now finalized

RPRA has updated its Hazardous and Special Products (HSP) Supply Data Verification Procedure to include cut-off thresholds that determine if HSP producers of categories A (oil filters, non-refillable pressurized containers) and B (oil containers, antifreeze, solvents, paints and coatings, pesticides, refillable pressurized containers) are large or small.

From 2024 onwards, only large producers are required to submit a supply data verification report to RPRA. Small producers will no longer be required to submit a verification report but will be subject to inspections.

From March 7 to April 5, 2024, RPRA consulted on the cut-off thresholds for supply data verification reporting that determine if HSP producers are large or small. RPRA made the decision to use the average weight of supply that determines a producers’ collection system requirements, as outlined in the HSP Regulation, based on the following reasons:

  • Some material categories have fewer producers than others and this method evenly captures the market share in each category,
  • To be consistent with the regulation, which has the following advantages:
    • Reduces administrative burden (e.g., approximately 50 HSP producers are considered large out of a total of 216), and
    • Minimizes confusion of who is defined as a large and small producer.
  • Note: In future years, RPRA will review the average weight of supply for each type of HSP to ensure that large and small producer categorization accurately reflects the HSP supply in Ontario.

Producers whose average supply meets the large producer threshold in the below chart must submit a verification report for that reporting year. Example: Producers of oil filters that have an average weight of supply in their 2023 supply report that exceeds 100 tonnes are considered a large producer and must submit a verification report for oil filters in 2024.

Chart of HSP average weight of supply

Stakeholder feedback and RPRA’s responses are summarized in the consultation report. Read the consultation report here.

Update on upcoming reporting

2024 supply and performance reporting will open soon. RPRA will notify producers via email ahead of reporting opening to provide more information.