Posted on August 18, 2021 by Monica Ahmed -
See our FAQ to understand “What is blue box product packaging?”.
Product packaging added to a product can be added at any stage of the production, distribution and supply of the product. A person adds packaging to a product if they:
- make the packaging available for another person to add the packaging to the product
- cause another person to add the packaging to a product
- combine the product and the packaging
For the portion of the product packaging that a brand holder added to the product, a person is considered a producer:
- if they are the brand holder of the product and are resident in Canada
- if no resident brand holder, they are resident in Ontario and import the product from outside of Ontario
- if no resident importer, they are the retailer that supplied the product directly to consumers in Ontario
- if the retailer who would be the producer is a marketplace seller, the marketplace facilitator is the obligated producer
- if the producer is a business that is a franchise, the franchisor is the obligated producer, if that franchisor has franchisees that are resident in Ontario
For the portion of the product packaging that an importer of the product into Ontario added to the product, a person is considered a producer:
- if they are resident in Ontario and import the product from outside of Ontario
- if no resident importer, they are the retailer that supplied the product directly to consumers in Ontario
- if the retailer who would be the producer is a marketplace seller, the marketplace facilitator is the obligated producer
- if the producer is a business that is a franchise, the franchisor is the obligated producer, if that franchisor has franchisees that are resident in Ontario
For any portion of the packaging that is not described above, the producer is the retailer who supplied the product to consumers in Ontario.
Posted on July 26, 2021 by Michelle Hoover -
As the Regulator responsible for enforcing regulations under the Resource Recovery and Circular Economy Act, 2016, the Registrar uses their discretion for when it is necessary to give registrants more time to collect the information needed for registration and/or reporting.
Posted on June 3, 2021 by Jess Turchet -
Under the Blue Box Regulation, blue box product packaging includes:
- Primary packaging is for the containment, protection, handling, delivery and presentation of a product at the point of sale, including all packaging components, but does not include convenience packaging or transport packaging (e.g., film and cardboard used to package a 24-pack of water bottles and the label on the water bottle).
- Transportation packaging which is provided in addition to primary packaging to facilitate the handling or transportation of one or more products such as a pallet, bale wrap or box, but does not include a shipping container designed for transporting things by road, ship, rail or air.
- Convenience packaging includes service packaging and is used in addition to primary packaging to facilitate end users’ handling or transportation of one or more products. It also includes packaging that is supplied at the point of sale by food-service or other service providers to facilitate the delivery of goods and includes items such as bags and boxes that are supplied to end users at check out, whether or not there is a separate fee for these items.
- Service accessories are products supplied with a food or beverage product and facilitate the consumption of that food or beverage product and are ordinarily disposed of after a single use, whether or not they could be reused (e.g., a straw, cutlery or plate).
- Ancillary elements are integrated into packaging (directly hung or attached to packaging) and are intended to be consumed or disposed of with the primary packaging. Ancillary elements help the consumer use the product. Examples of ancillary packaging include a mascara brush forming part of a container closure, a toy on the top of candy acting as part of the closure, devices for measuring dosage that form part of a detergent container cap, or the pouring spout on a juice or milk carton.
Posted on June 3, 2021 by Jess Turchet -
Under the Blue Box Regulation, paper products include printed and unprinted paper, such as a newspaper, magazine, greeting cards, calendars (promotional or purchased), notebooks and daily planners, promotional material, directory, catalogue or paper used for copying, writing or any other general use.
Hard or soft cover books and hardcover periodicals are not considered paper products.
Posted on June 3, 2021 by Jess Turchet -
Under the Blue Box Regulation, a packaging-like product is:
- ordinarily used for the containment, protection, handling, delivery, presentation or transportation of things
- ordinarily disposed of after a single use
- not used as packaging when it is supplied to the consumer
Packaging-like products include aluminum foil, a metal tray, plastic film, plastic wrap, wrapping paper, a paper bag, beverage cup, plastic bag, cardboard box or envelope, but does not include a product made from flexible plastic that is ordinarily used for the containment, protection, or handling of food, such as cling wrap, sandwich bags, or freezer bags.
If a producer is unsure whether or not their product is a packaging-like product, they can ask themselves the following questions to help determine whether the product is obligated to be reported under the Blue Box Regulation:
- Is the product actually packaging around a separate product?
- If yes, the product is not a packaging-like product. Instead, the product is considered blue box packaging and must be reported as blue box material. If no, continue to the next question.
- Is the product used for the containment, protection, handling, delivery, presentation or transportation of a thing(s)?
- If no, the product is not a packaging-like product. If yes, continue to the next question.
- Is the product typically disposed of after a single use (regardless if some may wash and reuse it)?
- If no, the product is not a packaging-like product. If yes, continue to the next question.
- Is the product made from flexible plastic that is for the containment, protection or handling of food?
- If yes, the product is not a packaging-like product. If no, the product is a packaging-like product and must be reported as blue box material.
If a producer is still unsure whether or not their product is a packaging-like product, they should contact the Compliance and Registry Team at 833-600-0530 or registry@rpra.ca.
Posted on January 19, 2021 by Michelle Hoover -
No. The list of products obligated under the EEE Regulation is different from the list of products included in the OES Program. The OES Program required producers to report the number of units they supplied, while the EEE Regulation requires producers to report the total weight of products.
To help producers calculate the weight of their products, we have included weight conversion factors in our Verification and Audit procedure, which is included as a weight conversion tool on the registration form. Once a producer determines the units of products on which they are obligated to report, they can enter the units into the conversion tool to get a calculated weight to report to the Authority.
For more information, see the Determining Supply Data section of the Registry Procedure: EEE Verification and Audit.
Posted on January 19, 2021 by Michelle Hoover -
No. RPRA is the regulator for the purposes of the new EEE Regulation. Producers and PROs are required to register with RPRA and meet the mandatory performance and reporting requirements under the regulation. RPRA is responsible for overseeing compliance with the regulation and has a range of enforcement tools that include compliance orders, administrative penalties, and prosecutions.
As a regulator, RPRA will not provide collection and management services. Instead, producers will be served by a competitive market comprised of processors, refurbishers, haulers, and PROs. Producers can contract with PROs to meet their obligations under the EEE Regulation, but producers will always remain responsible for meeting those requirements regardless of who they contract with.
Posted on January 19, 2021 by Michelle Hoover -
You may have obligations as an ITT/AV producer. To determine if you are a producer, see the FAQ Am I an ITT/AV producer?
If you are not a producer, then under the EEE Regulation you are not required to report supply data to the Authority or anyone else.
Posted on January 19, 2021 by Michelle Hoover -
As of January 1, 2021, producers are required to establish and operate a collection system for ITT/AV that meets the accessibility requirements in the regulation. Producers must ensure that all ITT/AV collected is managed regardless of what their minimum management requirements are.
Producers have the choice of establishing and operating their own collection and management systems or working with one or more producer responsibility organizations (PROs) registered with the Authority to meet their obligations.
Please contact the Compliance Team at 833-600-0530 or registry@rpra.ca to discuss other requirements under the EEE Regulation.
Posted on January 19, 2021 by Esther Filer -
An ITT/AV producer qualifies for an exemption if their average weight of supply for that calendar year is less than or equal to 5,000 kg.
Average supply weight is determined using the following formula:
Average weight of ITT/AV supply = (Y3 + Y4 + Y5) / 3
Eg. 2025 average weight of supply = (2022 + 2021 + 2020) / 3
ITT/AV producers that meet the exemption criteria are exempt from:
- Registering and reporting to RPRA
- Establishing a collection and management system
- Meeting a management requirement
- Promotion and education requirements
Producers must verify that they continue to meet the exemption annually, since their average weight of supply will change from year to year.
Exempt producers must keep records related to the weight of ITT/AV supplied into Ontario each year and provide them to the RPRA upon request.
Producers are advised to confirm their exemption with the Compliance Team at 833-600-0530 or registry@rpra.ca.
Posted on January 19, 2021 by Michelle Hoover -
Posted on January 19, 2021 by Esther Filer -
A producer’s individual management requirements are determined by formulas found in section 14 of the Regulation, summarized in the table below:
| Performance Year | Supply Report Year | Formula |
| 2025 | 2024 | (2020 supply + 2021 supply + 2022 supply) / 3×65%* |
| 2026 | 2025 | (2021 supply + 2022 supply + 2023 supply) / 3×65% |
| 2027 | 2026 | (2022 supply + 2023 supply + 2024 supply) / 3×65% |
| 2028 | 2027 | (2023 supply + 2024 supply + 2025 supply) / 3×65% |
| 2029 | 2028 | (2024 supply + 2025 supply + 2026 supply) / 3×65% |
| 2030 | 2029 | (2025 supply + 2026 supply + 2027 supply) / 3×70% |
*For reports submitted in 2024, producers should use RPRA’s manual calculator
It is important to note that producers must ensure that all ITT/AV collected is managed regardless of what their minimum management requirement is.
Note: Producers with a management requirement below a certain threshold may be exempt from registering with and reporting to RPRA. See our FAQ ‘How do I determine if I am an exempt ITT/AV producer?’ to learn more.
Posted on January 19, 2021 by Michelle Hoover -
Yes. You are still required to register with the Authority Registry even if you already have an existing account.
