As of June 3, 2025, this page has been updated to announce the launch of the consultation.
From June 3 to July 18, RPRA is consulting on its draft compliance guidance on shared collection sites and the buying and selling of recovered resources.
Review the draft compliance guidance by clicking the links below:
- Minimum Management Requirements Guidance – Clarifies when and how producers or their PROs can meet minimum management requirements and provides guidance around buying and selling “recovered weight” and “performance credits” in a manner that complies with regulatory requirements.
- Collection System Guidance – Clarifies the arrangements that must be in place when a collection site or activity is part of a public collection system that producers rely on to meet accessibility requirements under a regulation, whether the system is shared or not. It also explains how RPRA will verify these arrangements, including when collection sites or activities are shared.
RPRA has been working with expert consultants who have been engaging with industry to develop the proposed compliance guidance. The proposed documents have been reviewed by the Competition Bureau as part of the development process.
The guidance will apply to producers, PROs and service providers operating under the Batteries, Electrical and Electronic Equipment (EEE), Hazardous and Special Products (HSP) and Tires regulations. The guidance will not apply to the operation of the Blue Box program. The finalized guidance will also result in changes to existing RPRA compliance bulletins and registry procedures related to collection systems and performance tonnage for the applicable regulations, as they should be read alongside each other.
The proposed guidance applies beginning with the 2026 performance year.
Consultation process
Stakeholder Consultation (June 3 to July 18, 2025) In progress
Producers, PROs, and service providers under the affected regulations are invited to review the draft documents and send written feedback to consultations@rpra.ca by July 18, 2025.
Registrants may also request a one-on-one meeting to discuss the draft guidance with RPRA’s compliance team by emailing the same address.
After the consultation ends, RPRA will publish the final compliance guidance along with a report summarizing the feedback received and how it was addressed.
Information Gathering – Phase two (May to August 2024) Complete
From May 1 to August 30, 2024, RPRA considered the feedback received during phase one and continued to engage with stakeholders to further understand the impacts to registrant businesses as it refined the proposed compliance guidance for future consultation.
Information Gathering – Phase one (January to April 2024) Complete
From January 23 to April 30, 2024, RPRA gathered feedback from registrants about sharing 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 collection sites and buying and selling performance credits.
Background
RPRA is developing this guidance to address compliance challenges identified by registrants including:
Collection sites
- What is necessary for a site to be considered readily accessible to the public?
- How does a PRO/producer verify a commercial relationship with a collection site based on marketplace arrangements?
- How can sites be shared and what is needed to prove this?
Performance credits
- When can a performance credit be traded?
- Who owns a performance credit?
- How can performance credits be verified to ensure they are not double counted?