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Draft Blue Box Verification and Audit Procedure and Supply Reporting Guideline

Between October 2 and November 16, 2026, RPRA is consulting on two draft documents that provide detailed direction on Blue Box management performance audit reporting and supply reporting:

The finalized procedure and guidelines will be used by Blue Box producers and PROs starting with the 2027 reporting cycle.

Management performance reporting

The draft Blue Box Verification and Audit Procedure provides detailed guidance on how Blue Box producers or PROs on their behalf will conduct an audit of their management systems and report to RPRA. The first performance audit report will be submitted in 2027, and every third year going forward.

The development of the draft performance audit procedure is the second half of a two-phase consultation led by RPRA. Outcomes of the initial consultation phase helped determine key information including calculation points for recovered resources.

During the final phase, consultation participants are being asked to provide feedback on the proposed principals, definitions and procedure for completing performance audit reports. Review the draft Blue Box Verification and Audit Procedure for details.

Changes to supply reporting

RPRA’s proposed changes to its Blue Box supply reporting procedure are intended to reduce reporting errors, improve the effectiveness of RPRA’s compliance and enforcement activities (e.g., identifying free riders) and help create a fair system where all producers pay their required share of fees.

To help ensure the proposed changes are effective without creating unnecessary burden for producers, a streamlined framework is being proposed for small and medium enterprises (SMEs). To reduce administrative complexity for businesses operating across multiple jurisdictions (typically non-SME producers), the proposed changes include the alignment of Ontario’s reporting categories with national standards.

The table below provides a summary of the changes in the draft procedure and how they will impact SME and non-SME producers. For full details, review the draft Blue Box Supply Reporting Guideline.

RequirementSMEs*Non-SME large producers
Gross supply categories6 regulated categories62 harmonized categories
Supplied unit requirementTop 5 supplied unitsMax 50 units (min 5)
Brand list requirementsContinuation of current reporting requirementsDetailed reporting on Brand Lists and non-obligated products sold by the producer
Qualitative reportingSimple formSeparate
Sign-off governanceSingle sign-offDual sign-off
*A SME is an obligated business with fewer than 100 employees in Canada

How do I participate in the consultation?

The consultation will be open until November 16, 2026.

We encourage Blue Box producers, producer responsibility organizations (PROs), processors, industry associations and other interested parties to review the draft procedure and guidelines and submit feedback to [email protected] by the deadline.

Stakeholders should also review the consultation proposal that provides an overview of the draft documents and asks key questions for consideration.

RPRA hosted two webinars on Friday, October 16 to walk through the proposed documents and answer questions from attendees. Recordings and presentations from the webinars can be found below:

Draft Supply Reporting Guideline Webinar

Draft Audit and Verification Procedure Webinar

Note: This consultation follows phase one of the Blue Box Performance Reporting and Audit consultation from late 2024/25. For more information on phase one, visit the consultation webpage.