From March 7 to April 5, 2024, RPRA consulted on the cut-off thresholds for supply data verification reporting that determine if hazardous and special products (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 category A and B 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.
Producers were encouraged to submit feedback after reading the consultation proposal to consultations@rpra.ca by April 5, 2024. RPRA considered all relevant feedback received during the consultation period when revising the existing HSP Supply Data Verification Procedure to include the finalized cut-off thresholds.
Consultation outcomes
Decision
RPRA made the decision to use the average weight of supply from the previous calendar year that determines a producers’ collection system requirements, as outlined in the HSP Regulation, to define the cut-off thresholds. 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.
RPRA made this decision 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, 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.
Stakeholder feedback and RPRA’s responses
RPRA appreciates the thoughtful feedback provided throughout the consultation period and considered each submission when revising the HSP Supply Data Verification Procedure with the cut-off thresholds for large and small producers.
Stakeholder feedback and RPRA’s responses are summarized in the consultation report. Review the consultation documents:
Background
Under the Hazardous and Special Products Regulation, producers of category A and B are required to report supply data to RPRA each year. Supply data must be reported in accordance with the HSP Verification and Audit Procedure.
In 2022, RPRA consulted on the principles and methodologies outlined in the HSP Verification and Audit Procedure. In addition to determining that only large producers will be required to submit a verification report beginning in 2024, RPRA made the following decisions based on feedback received:
- All category A and B producers were required to submit a one-time supply data verification report to RPRA in 2023 (the first verification reporting year), and
- To consult on two producer categories (i.e., large and small) after receiving 2023 verified supply data from HSP producers.