RPRA has retained BDO Canada LLP (BDO) to develop Resource Recovery Performance Audit Procedures for batteries, ITT/AV and lighting, and hazardous and special products (HSP). These procedures will be referenced when producers reporting on their own activities and PROs reporting for producer clients and on their own activities submit their audit report at the time of performance reporting. Even if a producer has a PRO, it is still the producer’s responsibility to make sure their report is submitted by the deadline.
The new procedures will first be referenced during the 2025* reporting period.
*Due to the ongoing development of the procedures, the 2024 performance audit reporting requirement for batteries, ITT/AV and lighting will be delayed until 2025.
Producers and PROs are still required to submit their annual performance report in 2024. Producers and PROs will be notified when the registry opens for reporting.
Note for the hazardous and special products (HSP) program: RPRA will communicate requirements for the HSP performance audits in advance of the registry opening for annual reporting this summer.
Phase one (March 7 to April 14)
During phase one, BDO engaged with PROs to gather information about their company’s operations. All PROs that are registered with RPRA received an invite to attend either a virtual group discussion with other PROs who manage the same material or a 1:1 virtual session with their company, BDO and a member of RPRA’s Compliance Team. The goal of these sessions was to gather preliminary insight directly from PROs on the auditability of resource recovery performance.
An opportunity to submit additional feedback was also available outside of the consultation sessions. PROs were encouraged to answer the phase one consultation questions and email their answers to consultations@rpra.ca by April 14. These insights were taken into consideration during the development of the draft procedures.
Phase two (November 15 to December 14)
Note: in July, the consultation schedule slightly changed (from three phases to two) based on information gathered during phase one.
During this phase, RPRA and BDO consulted on the draft batteries, EEE (ITT/AV and lighting) and HSP procedures, which incorporated feedback received during phase one of the consultation.
Provide feedback
Those directly affected by the procedures, such as PROs, producers reporting on their own activities and their auditors, were encouraged to review the draft procedures and were invited to attend a webinar to provide feedback and ask questions.
View the webinar materials:
- Draft Batteries Resource Recovery Performance Audit Procedure
- Draft EEE Resource Recovery Performance Audit Procedure
- Draft HSP Resource Recovery Performance Audit Procedure
Feedback was submitted by email to consultations@rpra.ca by December 14, 2023. All feedback will be considered when developing the final batteries, EEE and HSP performance audit procedures.
Background
Under the Batteries, Electrical and Electronic Equipment (EEE), and Hazardous and Special Products (HSP) Regulations, producers are obligated to collect and manage their obligated material(s) to recover resources and meet their minimum performance requirements through reuse, refurbishing, or recycling.
Producers without a PRO, producers who have identified they will not use their PRO and PROs reporting on their own activities must also submit Performance Audit Reports showing how they met their performance obligation. These audit reports must be verified in accordance with the performance audit procedures developed by RPRA.