From February 23 to March 25, 2026, RPRA consulted on proposed updates to the cut-off thresholds used to determine whether producers are considered large or small for supply data verification reporting under the Batteries, Information Technology, Telecommunications and Audio-Visual (ITT/AV), and Tires programs.
The following procedures have been updated to include the revised thresholds:
- Batteries Registry Procedure – Verification and Audit
- EEE Verification and Audit Procedure
- Tires Registry Procedure – Audit
Producers were encouraged to submit feedback after reading the proposal to [email protected] by March 25.
Consultation outcomes
RPRA considered all feedback received during the consultation when finalizing the cut-off thresholds. Stakeholder feedback and RPRA’s responses are summarized in the consultation report.
The finalized thresholds remain unchanged from what was outlined in the consultation proposal. This means:
- The cut-off thresholds are now based on the average weight of supply rather than management requirements.
- The thresholds have been updated based on the new methodology.
- The “medium producer” category for tires has been removed. Tire producers will now be classified as either large or small.
- Only large producers are required to submit a verification report. Small producers may be subject to inspections.
RPRA also clarified in the updated procedures that the reporting period for verification purposes is the calendar year.
Battery, ITT/AV and tire producers who meet the “large producer” threshold in the updated procedures must submit a supply data verification report to RPRA by June 30, 2026.
Based on the updated thresholds, only a small percentage of producers qualify as a large producer and must submit a supply data verification report in 2026. RPRA will provide additional outreach to producers whose verification reporting obligations changed because of the updated thresholds.
Producers are still required to submit their annual supply and performance reports to RPRA by the deadlines in the regulations:
- April 30, 2026: deadline for batteries and ITT/AV
- May 31, 2026: deadline for tires
Background
Under, the Batteries, Electrical and Electronic Equipment (EEE), and Tires regulations, producers are required to report supply data annually to RPRA to establish their management requirements for the following year. Supply data must be reported in accordance with RPRA’s registry procedures.
As outlined in RPRA’s registry procedures, large producers (and medium producers for tires) are required to verify their supply data. Small producers are not required to submit a verification report but will be subject to inspections.
Prior to 2025, producers were categorized using cut-off thresholds based on their management requirements (batteries and ITT/AV) or collection targets (tires). In 2025, the Batteries, EEE and Tires regulations were amended, which included updating management requirements and collection targets. Following the amendments, RPRA reviewed the cut-off thresholds in its registry procedures to reduce producer burden and streamline producer categories across programs by using average weight of supply.
RPRA consulted on the revised producer categories before finalizing its registry procedures with the updated thresholds.