Summary of collection system requirements for producers of hazardous and special products
The Ontario government’s recent amendments to the Hazardous and Special Products (HSP) Regulation provide greater flexibility for producers to meet their collection system requirements.
Starting in 2026, producers, or PROs on their behalf, can use existing or new options to meet their collection system obligations, either by establishing a public collection system or take-back service. Large producers of Categories A and B and all producers of Category C and E must also establish and operate a call-in collection service.
RPRA is currently updating its Hazardous and Special Products Collection Systems Compliance Bulletin, as well as its HSP Producers webpage, to align with the amendments and provide more guidance for producers. In the meantime, the information below summarizes the amended collection system requirements.
| Collection system option | Producer(s) that can use the option |
|---|---|
| 1. Public collection system | |
| a) Population-based | All producers of Categories A and B |
| b) Municipal-based (new) | – All producers of non-refillable pressurized containers, pesticides and solvents – Producers who operate public-facing sites for oil filters, oil containers, and antifreeze |
| c) Retail-based | – All producers of oil filters, oil containers, and antifreeze (new) – Small producers of non-refillable pressurized containers, pesticides, solvents and paints and coatings |
| 2. Take-back or mail-in service (new) | All producers of Categories A and B |
| Note: In addition to establishing a public collection system or take-back/mail-in service as outlined in this table, large producers of Categories A and B and all producers of Category C and E must establish and operate a call-in collection service. | |
Public collection system options
Producers can choose from one of the three public collection system options below to meet their collection system requirements. Producers have additional requirements when establishing a public collection system, such as ensuring consumers can drop off their used materials for free. Read more below.
- Population-based: If choosing this option, producers must establish and operate a minimum number of collection sites in every municipality and territorial district, where the number of sites required is based on the population size within the municipality and territorial district
- Municipal-based: If choosing this new option, producers must set up the same number of collection sites and events as the municipalities would have run two years prior (e.g., In 2026, a producer would have to establish and operate the same number of collection sites and events that all municipalities operated in 2024)
- Retail-based: If choosing this option, producers must establish as many collection sites equal to or greater than 75% of the number of retail locations in the municipality or territorial district that supply the producer’s type of HSP, rounded up to the nearest whole number. For example, if there are 10 retail locations in the municipality or district, 75% would equal 7.5 collection sites, rounded up to the nearest whole number for a total of 8 collection sites required
Take-back or mail-in service option
Producers have a new option to collect HSP material by either allowing consumers to bring it back to the producer directly or providing material to the consumer at no charge, such as packaging or shipping materials, so that they can mail it back to the producer.
Producers who choose this option are not required to establish or operate a public collection system; however, they must collect and manage the HSP type they supply into Ontario.
Note: Producers who choose to establish the take-back or mail-in service collection system, or large producers of automotive material who choose the retail based option to meet the number of collection sites required, must collect a minimum amount of material using a performance comparator, which requires the alternative systems to achieve results as good as collection systems based on collection results from three years prior. Information about this performance comparator will be available in the updated Hazardous and Special Products Collection Systems Compliance Bulletin. Producers or PROs on their behalf must notify RPRA if they intend to use either option.
Call-in collection requirement
In addition to establishing a public collection system or take-back/mail-in service, producers must collect on request from the following entities or operations:
- A council of the band
- A municipality that is not located in the Far North
- A territorial district that is not located in the Far North
- A depot where HSP is collected that is owned or operated by the Crown in right of Ontario and not located in the Far North
For more information on the Far North, please see our FAQ.
This applies only to the producers that meet the criteria outlined in the table below.
| Category | Call-in requirement | Collection timeline |
|---|---|---|
| Category A and B | – Applies only to large producers – Triggered when >100 kg has been collected | – 3 months (Ontario, outside Far North) – 1 year (if located on a reserve in the Far North) |
| Category C and E | – Applies to all producers, regardless of size – No weight threshold |
Note: Producers, or PROs on their behalf, are responsible for the management of all products that fall under that type of HSP when providing the collection service, regardless of the brand of the product.
Requirements for establishing a public collection system
Producers must ensure that consumers can drop off HSP material free of charge at each site that is part of their collection system and satisfy the following requirements:
- If the HSP collection site is operated by a municipality or territorial district, the site must accept, at a minimum, all types of HSP in the same category
- If the HSP collection site is not owned by a municipality or local services board, it must accept HSP during normal business hours throughout the performance year
- Municipal and First Nation collection sites are permitted to operate seasonally or for a limited number of days per week
- The HSP collection site must accept, at a minimum, up to 25 kg per day of each type of HSP accepted at the site from any person