Audience: Producer

Am I a small, large or exempt HSP producer?

Posted on September 21, 2021 by -

Producers can reference the chart below to determine if they are a small, large or exempt HSP producer.

Producer categories use the average weight of material (in tonnes) supplied in Ontario in the previous calendar year.

Type of HSPExempt (Less than <)Small Producer Large Producer (Equal to or greater than >)
Oil Filters3.5⟷100
Non-refillable Pressurized Containers3⟷100
Antifreeze20⟷300
Oil Containers2⟷55
Solvents3⟷70
Paints and Coatings10⟷1,000
Pesticides1⟷9
Refillable Pressurized ContainersN/A
Mercury-containing Devices
Fertilizers
Propane Containers (refillable)

Note that ‘⟷’ indicates a value greater than ‘Exempt’ but less than ‘Large Producer’ threshold.

Average supply weight is determined using the following formula:

Average weight of HSP supply = (Y1 + Y2 + Y3) / 3 

E.g. 2025 average weight of supply = (2024 + 2023 + 2022) / 3

How do I manage contacts on my Registry account?

Posted on September 16, 2021 by -

Account Admins must add any new, or manage existing, Primary Contacts under the program they wish to give them access to in order for the Primary Contact to be able to submit a report (e.g., permissions to view and complete reports).

To Manage contacts on your Registry account, please see the following steps:

  1. Log into your account
  2. Once you are logged in, click on the drop-down arrow in the top right corner and select Manage Users
  3. Under Actions, click Manage to update preferences of existing users
  4. Click Add New User to add an additional contact to your account
  5. To give reporting access to a Primary Contact, select the program from the drop-down that you would like to grant them access to

What is a rule creator?

Posted on September 15, 2021 by -

The rule and allocation table creation process has been removed from the Blue Box Regulation and is therefore no longer required to create and maintain the system for collecting Blue Box materials across the province, as per regulatory amendments made by the government on April 14, 2022. As such, rule creators are no longer applicable under the regulation. Learn more about the amendments.

To replace these tools, the amended regulation now requires PROs to submit a report that outlines how they will operate the Blue Box collection system on behalf of producers, ensuring that materials are collected from all eligible communities (i.e., communities outside of the Far North) across the province. Learn more about what PROs need to include in the report.

Are there any differences in what needs to be reported between the current Stewardship Ontario program and the new Blue Box Regulation?

Posted on September 15, 2021 by -

Yes, there are some key changes to the data reported to Stewardship Ontario and what needs to be reported under the new regulation, which may affect what a producer is obligated for and should be considered if using data previously reported to Stewardship Ontario:

  • There are fewer reporting categories than under the Stewardship Ontario program
  • Certified compostable packaging and products now must be reported separately, but this category does not have management requirements
  • There are only two deductions permitted under the Blue Box Regulation, and producers must report total supply and then report any weight to be deducted separately
  • Exemptions are based on tonnage supply under each material category instead of a total supply weight threshold of less than 15 tonnes as in Stewardship Ontario’s program

See our FAQ to understand “What deductions are available to producers under the Blue Box Regulation?”; “Are there exemptions for Blue Box producers?“; “Are there any differences in Blue Box producer hierarchies between the current Stewardship Ontario program and the new Blue Box Regulation?”; and “Are there are any differences in obligated Blue Box materials between the current Stewardship Ontario program and the new Blue Box Regulation?”

 

Why do I have to pay the RPRA Registry fee for Blue Box in 2021 if the program doesn’t transition until 2023?

Posted on September 15, 2021 by -

RPRA’s Registry fees cover the costs related to compliance and enforcement and other activities required to administer the regulations under the RRCEA, and building and operating the Registry.

The Registry fees cover expenses in a given year (e.g., 2021 fees cover 2021 expenses). 2021 fees for Blue Box cover the Authority’s costs to undertake activities to implement the regulation in 2021, which include:

  • helping obligated parties understand their requirements
  • ensuring producers register and report their supply data by the deadline in the regulation
  • compliance, enforcement, and communication activities

What producer exemptions are there under the HSP regulation?

Posted on September 15, 2021 by -

An HSP producer qualifies for an exemption if their average weight of supply for the previous calendar year is less than or equal to the weight specified in the chart below:

Exempt (Less than <)
Oil Filters3.5
Non-refillable Pressurized Containers3
Antifreeze20
Oil Containers2
Solvents3
Paints and Coatings10
Pesticides1
Refillable Pressurized ContainersN/A
Mercury-containing Devices
Fertilizers
Propane Containers (refillable)

See our FAQ “Am I a small, large, or exempt HSP producer?” to determine how to calculate if you are an exempt HSP producer.

HSP 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 HSP supplied into Ontario each year and provide them to RPRA upon request.

Producers are advised to confirm their exemption with the Compliance Team at 1-833-600-0530 or registry@rpra.ca.

What deductions are available to producers under the Blue Box Regulation?

Posted on September 15, 2021 by -

There are only two allowable deductions for Blue Box materials. There are for materials that are:

  • collected from an eligible source at the time a related product was installed or delivered (e.g., packaging that is removed from the house by a technician installing a new appliance). This is the “installation deduction”.
  • deposited into a receptacle at a location that is collected from a business or institution where Blue Box collection services are not provided under the regulation. This is the “ineligible source deduction” that was expanded by the regulation amendment in July 2023.

Ineligible source deductions:

Blue Box Producers may deduct materials that are collected from a business or institution where producers are not required to provide Blue Box collection services. Examples include offices, stores and shopping malls, restaurants, community centres, recreation facilities, sports and entertainment venues, universities and colleges, and manufacturing facilities.

Producers cannot deduct the following materials collected through the collection systems established under the Blue Box Regulation:

  • Material that is generated at a facility (including multi-residential buildings, retirement homes, long-term care homes and schools).
  • Material that is collected from a residence through a curbside or depot collection service.
  • Material that is collected from a public space (including an outdoor area in a park, playground or sidewalk, or a public transit station).
  • Material collected under an alternative or supplemental collection system.
  • Beverage containers cannot be deducted.

Materials that are deducted cannot count toward a producer’s management requirement.

Please see the Reporting Guidance Ineligible Source Deductions for the 2024 Blue Box Supply Report for more information on how to determine and use these deductions.

Am I an HSP producer?

Posted on September 15, 2021 by -

You are a hazardous and special products (HSP) producer if you market antifreeze and oil filters (excluding those provided in new vehicles, for which a separate hierarchy applies as outlined below), oil containers, solvents, paints and coatings, pesticides, fertilizers, pressurized containers or refillable propane containers to consumers in Ontario and:

  • You are the brand holder and have residency in Canada;
  • If there is no resident brand holder, you have residency in Ontario and import from outside of Ontario;
  • If there is no resident importer, you have residency in Ontario and market directly to consumers in Ontario (e.g., online sales); or
  • If there is no resident marketer, you do not have residency in Ontario and market directly to consumers in Ontario (e.g., online sales).

You are a hazardous and special products (HSP) producer if you market oil filters and antifreeze provided in new vehicles into Ontario and:

  • You are the manufacturer of the new vehicle and have residency in Canada;
  • If there is no resident vehicle manufacturer, you have residency in Ontario and import the vehicle from outside of Ontario;
  • If there is no resident importer, you have residency in Ontario and market the vehicle directly to consumers in Ontario; or
  • If there is no resident marketer, you do not have residency in Ontario and market the vehicle directly to consumers in Ontario.

You are a hazardous and special products (HSP) producer if you market mercury-containing barometers, thermometers or thermostats into Ontario and:

  • You are the brand holder and have residency in Canada; or
  • You are the brand holder of barometers, thermometers or thermostats marketed to consumers in Ontario that do not contain mercury

You are a hazardous and special products (HSP) producer if you market fertilizers into Ontario and:

  • You are the brand holder and have residency in Canada

Even if you do not meet the above definitions, there may be circumstances where you qualify as a producer. Read the Hazardous and Special Products Regulation for more details or contact the Compliance Team for guidance at registry@rpra.ca or toll-free at 1- (833) 600-0530.

Related FAQs: 

What information do Blue Box producers need to provide when reporting their supply data to RPRA?

Posted on September 15, 2021 by -

Starting in 2022, producers are required to report their supply data annually to RPRA.

Each year, producers will need to provide the previous years’ supply data in each of the seven material categories – beverage container, glass material, flexible plastic, rigid plastic, metal material, paper material, and certified compostable products and packaging material – as well as any deductions.

See our FAQ to understand “What deductions are available to producers under the Blue Box Regulation?”

 

What information do Blue Box producers need to provide when registering with RPRA?

Posted on September 15, 2021 by -

Producers are required to provide the following information when registering with RPRA:

  • Contact information
  • PRO information (if a PRO has been retained at time of reporting), including what services they have retained a PRO for
  • Their 2020 supply data in each of the seven material categories– beverage container, glass material, flexible plastic, metal material, paper material, and certified compostable products and packaging material – as well as any deductions.

Please note that this information must be submitted to RPRA directly.

See our FAQ to understand “What deductions are available to producers under the Blue Box Regulation?”