Development of Resource Recovery Performance Audit Procedures for Batteries, ITT/AV, Lighting and HSP

RPRA has retained BDO Canada LLP (BDO) to develop Resource Recovery Performance Audit Procedures for batteries, ITT/AV, lighting, and hazardous and special products (HSP). These procedures will be referenced when producers without a PRO, producers who have identified they will not use their PRO for meeting their performance obligation and PROs reporting for producer clients and on their own activities submit their audit report at the time of Performance Reporting.

The new procedures will first be referenced for the following performance reporting periods:

  • Batteries – beginning in 2024
  • ITT/AV – beginning in 2024
  • Lighting – beginning in 2024
  • HSP – beginning in 2023
    RPRA’s Registrar is delaying the performance audit requirement due to the development of the Hazardous and Special Products Resource Recovery Performance Audit Procedure. Only performance data is required to be submitted by the July 31, 2023 deadline. The performance audit will be required later this year once the procedure is developed. Additional details about when audit reporting is due will be communicated later this year.

Phase One (Beginning March 2023. Feedback due April 14)

While developing these procedures, BDO will be engaging 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 is to gather preliminary insight directly from PROs on the auditability of resource recovery performance.

An opportunity to submit additional feedback is also available outside of the consultation sessions. If you did not participate in an interview or would like to provide additional feedback, please answer the Phase One consultation questions and email your answers to Stakeholders are encouraged to submit their feedback up until April 14, 2023. These insights will be taken into consideration during the development of the initial draft of the procedures.

Phase Two (Beginning Fall of 2023)

A public webinar is anticipated to be held in the Fall of 2023 to review the initial draft of the procedures and gather additional feedback. PROs, along with other stakeholders, will be invited to participate again at that time.

Phase Three

The final draft procedures, which will include feedback received during Phase Two, will be posted for stakeholders to review. Stakeholders will be encouraged to provide additional feedback that RPRA and BDO will consider when finalizing the procedures.


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 procedures developed by RPRA.