Frequently Asked Questions

Yes, a producer, a PRO (producer responsibility organization) on behalf of a producer, or a service provider on behalf of either party, can collect any product or material (including materials or products that are not designated under the Resource Recovery and Circular Economy Act, 2016 (RRCEA)). For example, a battery producer may choose to collect batteries that weigh over 5kg; a tire producer may choose to collect bicycle tires; or a Blue Box producer may choose to collect books.

Products or materials that are not designated under RRCEA regulations cannot be counted towards meeting a producer’s collection or management requirements under RRCEA.

If designated materials are co-collected with materials that are not designated, a person must use a methodology or process acceptable to the Authority to account for those materials. Anyone considering this can contact the Compliance Team to discuss at registry@rpra.ca or 833-600-0530.

For example, if bicycle tires are collected at the same time as automotive tires, they must be accounted for separately both when collected and when sent to a processor.

A lighting producer qualifies for an exemption if their average weight of supply for that calendar year is less than or equal to 700 kg.

Average supply weight is determined using the following formula:

Average weight of lighting supply = (Y3 + Y4 + Y5) / 3 

Eg. 2025 average weight of supply = (2022 + 2021 + 2020) / 3 

Lighting producers that meet the exemption criteria are exempt from:

• Registering with and reporting to RPRA
• Establishing a collection and management system
• Meeting a management requirement
• Promotion and education requirements

Producers must verify that they continue to meet the exemption annually, since their average weight of supply will change from year to year.

Producers that are exempt must keep records of the materials they supplied, as set out in section 30 of the regulation.

Producers are advised to confirm their exemption with the Compliance Team at 833-600-0530 or registry@rpra.ca.

See our FAQs: “How are lighting producers’ minimum management requirements determined?” and “What do I have to do if I am an exempt lighting producer?”

No, where a producer is exempt, the regulatory obligations do not become the responsibility of the organization that is next in the producer hierarchy. The exempt producer remains the “producer” for those materials; they are just exempt from certain requirements under the regulation as set out in the relevant provisions providing for the exemption. This is the case in all RRCEA regulations.

Producers are obligated parties under the Resource Recovery and Circular Economy Act and are ultimately responsible for their data submitted through RPRA’s Registry. Producers can choose to contract with an external consultant to support their data submission, but third parties have limited permissions in the Registry as they are not regulated parties.

A producer can choose to assign a primary or secondary user profile in their Registry account to an external consultant. An external consultant may submit supply data reports and/or pay registry fees on the producer’s behalf.

External consultants cannot submit and/or sign registration, executive attestations, account admin changes or supply data adjustment documentation on behalf of a producer. External consultants cannot be account admins, nor can they manage a PRO within the Registry on behalf of a producer.

A producer’s individual minimum management requirement is determined by the following formulas, found in section 14 of the Electrical and Electronic Equipment (EEE) Regulation, summarized in the following chart:

It is important to note that producers must ensure that all lighting that is collected is managed, regardless of their minimum management requirement.

Note: Producers with a management requirement below a certain threshold may be exempt from registering with and reporting to RPRA. See our FAQ ‘How do I determine if I am an exempt lighting producer?’ to learn more.

In determining whether an obligated producer used best efforts to meet their management requirements, the Compliance Team will consider whether the producer, acting in good faith, took all reasonable steps to meet the requirements outlined in the applicable regulation.

For example, best efforts in the context of management requirements may involve a producer regularly monitoring the volume of material being collected and managed, and implementing plans for increasing those volumes if the requirements are unlikely to be met.

Producers can contact the Compliance Team to ask specific questions about fulfilling their obligations.

A producer can grant access to anyone they would like to authorize in their reporting (i.e. Registry) portal. Producer reporting must be done in the producer account and batch data transfers are not accepted.

An exempt producer is not required to:

• Register and report to RPRA
• Establish a collection and management system
• Meet a management requirement
• Meet promotion and education requirements

Exempt producers must retain records related to the weight of lighting supplied into Ontario each year and provide them to RPRA upon request.

See our FAQ: ‘How do I determine if I am an exempt lighting producer?’

Yes. If you are a producer with retailers or distributors supplying your obligated EEE into Ontario, you can email us at registry@rpra.ca to discuss options on how to report your supply data. There are several options available, including an easy-to-use sales formula and weight conversion factors. See the EEE Verification and Audit procedure for more information.

One option is to have your supply data reported by each of your retailers or distributors on a piecemeal basis. The piecemeal option requires that extra steps be undertaken by you and the Authority. You must contact the Authority in advance if you wish to pursue this option.

Note that even if you have a retailer or distributor providing data on your behalf, it remains the producer’s obligation to ensure that all the required data gets reported and that it is reported accurately to the Authority in accordance with the EEE Regulation. The entry of inaccurate information by someone on your behalf is not a defense to non-compliance.

A person is considered a lighting producer under the Electrical and Electronic Equipment (EEE) Regulation if they supply lighting into Ontario and:

• Are the brand holder for the lighting and have residency in Canada;
• If there is no resident brand holder, have residency in Ontario and import lighting from outside of Ontario;
• If there is no resident importer, have residency in Ontario and market directly to consumers in Ontario (e.g. online sales); or
• If there is no resident marketer, do not have residency in Ontario and market directly to consumers in Ontario (e.g., online sales).

Even if you do not meet the above definition, there may be circumstances where you qualify as a producer. Read the Electrical and Electronic Equipment Regulation for more detail or contact the Compliance and Registry Team for guidance at registry@rpra.ca or (647) 496-0530 or toll-free at (833) 600-0530.

See our FAQ to understand “What is lighting under the EEE Regulation?”, “Who is a brand holder?”

Lighting producers report supply data in kilograms from two years prior (i.e., 2023 supply data is reported in 2025) in their annual supply report.

Producers can use the actual weight of the obligated lighting, or RPRA’s weight conversion factors found in the EEE Verification and Audit Procedure.

For further questions, contact the Compliance Team at registry@rpra.ca or 1-833-600-0530.

Producers are not required to collect and manage their own branded products and materials. Instead, a producer is expected to collect and manage a portion of similar materials in Ontario. The portion of material that a producer collects and manages is known as their minimum management requirement. A minimum management requirement, which is set based on calculations outlined in the applicable Regulation, is the weight of the products or packaging that the producer must ensure is collected and managed. The calculated amount is proportionate to the weight of materials that producer supplied into the province.

For example, a producer who supplied laptops into Ontario does not need to collect and manage their own branded laptops. Instead, they must ensure that they collect and manage an equivalent weight of information technology, telecommunications, and audio-visual equipment (ITT/AV) materials.

Similarly, a producer who supplied cardboard boxes into Ontario does not need to collect and manage those exact cardboard boxes. Rather, they need to ensure that an equivalent weight of paper is collected and managed.

Almost all producers will work with producer responsibility organizations (PROs) for the purposes of meeting their obligations to collect and manage materials. PROs establish collection and management systems across Ontario for different material types. A producer can meet their obligations to collect and manage materials by entering into a contract with a PRO to provide these services on their behalf.

Under the Resource Recovery and Circular Economy Act, the Authority is required to provide an annual report to the Minister that includes information on aggregate producer performance, and a summary of compliance and enforcement activities. Under section 51 of the Act, the Registrar also is required to post every order issued on the Registry.

Free riders are obligated parties that:

• Have not registered or reported to RPRA
• Have not established a collection and management system (if they are so required to), or;
• Are not operating a collection and management system (if they are so required to).

See our FAQs to understand “What is RPRA’s approach to free riders?”, and “What do I do if I think a business is a free rider?”

To note:

• Some producers only have requirements to register and report. Please refer to your specific program page on our website to understand producer obligations.
• Collection and management systems may be accomplished by a producer responsibility organization (PRO) on behalf of a producer through contractual arrangements between the producer and PRO. If a PRO is managing a producer’s collection and management requirements, producers must identify that PRO to RPRA.

Yes. PROs are private enterprises and charge for their services to producers.

Each commercial contract a producer enters with a PRO will have its own set of terms and conditions. It is up to the PRO and producer to determine the terms of their contractual agreement, including fees and payment schedule.

RPRA does not set the terms of the contractual arrangements between PROs and producers.

If a producer misreports their supply data to RPRA, they must contact the Compliance Team immediately by emailing registry@rpra.ca. Please include the following information in the email:

• The rationale for the change in the data
• Any data that supports the need for a correction (e.g., sales documents, audit)
• Any other information to support the change

While it is an offence to submit false or misleading information under the RRCEA, RPRA wants this corrected as quickly as possible to ensure a producer’s minimum management requirement is calculated using accurate supply data.

RPRA can only receive these requests from the primary contact on the company’s Registry account. Your request for an adjustment will be reviewed by a Compliance and Registry Officer.

A brand is any mark, word, name, symbol, design, device or graphical element, or a combination thereof, including a registered or unregistered trademark, which identifies a product and distinguishes it from other products.

A brand holder is a person who owns or licenses a brand or otherwise has rights to market a product under the brand.

Note:

• If there are two or more brand holders, the producer most directly connected to the production of the material is the brand holder.
• If more than one material produced by different brand holders are marketed as a single package, the producer who is more directly connected to the primary product in the package is the brand holder.

Brand holders and producers that supply products and packaging are required by legislation to meet individual mandatory collection and resource recovery requirements and may face compliance and enforcement consequences for failing to do so. The executive attestation ensures that executives responsible for managing the brand holder’s or producer’s business are aware of these requirements and can ensure that appropriate measures are put in place to achieve compliance with the regulations.

If a producer or service provider needs to adjust the performance data reported to RPRA, they must contact the Compliance Team immediately by emailing registry@rpra.ca. Please include the following information in the email:

• The rationale for the change in the data
• Any data that supports the need for a correction (e.g., tonnage purchase or sale contract, audit)
• Any other information to support the change

While it is an offence to submit false or misleading information under the RRCEA, RPRA wants this corrected as quickly as possible to ensure that it has accurate performance data from all registrants.

RPRA can only receive these requests from the primary contact on the company’s Registry account. Your request for an adjustment will be reviewed by a Compliance and Registry Officer.

The recycling locations that appear on the map are reported to RPRA by PROs (or producers managing their own collection networks) as the administrators of the collection systems. The public collection activities that PROs report in their registry account are uploaded to the map in near real-time.

Program fees are charges that producers obligated under the Resource Recovery and Circular Economy Act, 2016, are required to pay to RPRA annually to recover its operational costs, including costs related to building and operating the registry, providing services to registrants, and compliance and enforcement activities.

All current and past fee schedules can be found here.

Yes. Producers and service providers can enter into contractual agreements with multiple PROs.

RPRA’s Where to Recycle map displays locations across Ontario where the public can drop off used materials to be recycled, such as batteries, electronics, household hazardous waste (e.g., paint, antifreeze, pesticides), lighting and tires, for free. Materials collected at these locations are reused, refurbished, recycled, or properly disposed of to help keep them out of landfill, recover valuable resources and protect our environment. Learn more here.

The recycling locations that appear on the map are reported to RPRA by businesses that run the recycling systems in Ontario.

We encourage anybody who believes an entity is a free rider to contact RPRA’s Compliance and Registry Team at 1-833-600-0530 or by emailing registry@rpra.ca with information about that entity. RPRA reviews every free rider allegation that is referred to us.

We do not share information about our inspections or progress on specific free rider cases.

See our FAQ to understand “What is a free rider?” and “What is RPRA’s approach to free riders?”