Compliance Guidance for Sharing Collection Sites and Buying and Selling Performance Credits 

The following information was updated on July 24, 2024, to include feedback from Phase One.

RPRA is collecting feedback to understand the market impact to develop a proposal for a consultation. The goal is to provide compliance guidance for producers and producer responsibility organizations (PROs) to clarify regulatory requirements related to:    

• Sharing public collection sites to meet accessibility requirements 

• Buying and selling performance credits to meet collection or management requirements  

This guidance is being developed to address compliance challenges identified by registrants including: 

Collection sites 

1. What is necessary for a site to be considered readily accessible to the public?
2. How does a PRO/producer verify a commercial relationship with a collection site based on marketplace arrangements?
3. How can sites be shared and what is needed to prove this? 

Performance Credits 

1. When can a performance credit be traded?
2. Who owns a performance credit?
3. How can performance credits be verified to ensure they are not double counted? 

The compliance guidance will apply to producers and PROs operating under the following regulations:   

• Batteries Regulation   
• Electrical and Electronic Equipment (EEE) Regulation 
• Hazardous and Special Products Regulation 
• Tires Regulation  

The guidance will result in changes to compliance bulletins and registry procedures related to collection systems and performance credits for the above regulations. The guidance will not apply to the operation of the Blue Box program.    

RPRA is working with expert consultants to develop the proposed compliance guidance. During the development process, RPRA and the consultants are gathering feedback from stakeholders impacted by the new guidance, such as PROs and service providers, to inform proposed compliance guidance for consultation. 

Consultation process

Information Gathering – Phase one (January to April 2024)

From January 23 to April 30, 2024, RPRA gathered feedback from registrants about sharing public collection sites and buying and selling performance credits. This included direct engagement with PROs and service providers as key groups involved in these activities.  

RPRA also received written responses from impacted registrants and stakeholders to questions posted to the consultation webpage related to sharing public collection sites and buying and selling performance credits. 

Information Gathering – Phase two (May to August 2024)

From May 1 to August 30, 2024, RPRA will consider the feedback received during phase one and continue to engage with stakeholders to further understand the impacts to registrant businesses as we refine the proposed compliance guidance for future consultation.  

If you have further feedback to share with RPRA related to sharing public collection sites and buying and selling performance credits please email registry@rpra.ca by August 30, 2024.  

Stakeholder Consultation (2025 TBD)

Based on the feedback received during information gathering phases, RPRA will release a proposal for consultation on compliance guidance for sharing collection sites and buying and selling performance credits.   

Following the consultation period, RPRA aims to finalize and publish the compliance guidance along with a consultation report summarizing stakeholder feedback received during the consultation, including how RPRA considered stakeholder feedback when finalizing the guidance documents.