Frequently Asked Questions

See our FAQ to understand “What is blue box product packaging?”.

Product packaging added to a product can be added at any stage of the production, distribution and supply of the product. A person adds packaging to a product if they:

• make the packaging available for another person to add the packaging to the product
• cause another person to add the packaging to a product
• combine the product and the packaging

For the portion of the product packaging that a brand holder added to the product, a person is considered a producer:

• if they are the brand holder of the product and are resident in Canada
• if no resident brand holder, they are resident in Ontario and import the product from outside of Ontario
• if no resident importer, they are the retailer that supplied the product directly to consumers in Ontario
• if the retailer who would be the producer is a marketplace seller, the marketplace facilitator is the obligated producer
• if the producer is a business that is a franchise, the franchisor is the obligated producer, if that franchisor has franchisees that are resident in Ontario

For the portion of the product packaging that an importer of the product into Ontario added to the product, a person is considered a producer:

• if they are resident in Ontario and import the product from outside of Ontario
• if no resident importer, they are the retailer that supplied the product directly to consumers in Ontario
• if the retailer who would be the producer is a marketplace seller, the marketplace facilitator is the obligated producer
• if the producer is a business that is a franchise, the franchisor is the obligated producer, if that franchisor has franchisees that are resident in Ontario

For any portion of the packaging that is not described above, the producer is the retailer who supplied the product to consumers in Ontario.

A producer’s management requirement is how much Blue Box material they must ensure is collected and processed into recovered resources each year. Management requirements are calculated based on what they supplied into Ontario one year prior and the resource recovery percentage as set in the regulation. A producer’s management requirement is calculated separately for each Blue Box material category (beverage container, glass, flexible plastic, rigid plastic, metal and paper).

Some producer are exempt from having a management requirement based on their supply data, for more information on exemptions see the FAQ Are there exemptions for Blue Box producers? A producer that does not have a management requirement does not have any collection, management or promotion and education obligations.

A producer with a management requirement must also provide collection and promotion and education services in Ontario. Most producers will contract the services of a producer responsibility organization (PRO) to meet their collection, management and promotion and education obligations.

To view your management requirement(s), log into your registry account, download a copy of your Blue Box Supply Report and review the section with your minimum management requirements. Management requirement for a given year are determine by supply data from two years prior. For example, 2023 management requirements were based on 2021 supply data (submitted in producers’ 2022 Supply Report).

Unsure if you are a Blue Box producer? See our FAQs Am I a producer of Blue Box product packaging? And Am I a producer of paper products and packaging-like products?

Under the Blue Box Regulation, there are three types of exemptions that apply to producers:

1. Based on a producer’s gross annual revenue,
2. based on the weight of Blue Box materials supplied into Ontario, and
3. for producers of newspaper

1. Any producer whose gross annual Ontario revenue from products and services is less than $2,000,000 is exempt from all producer requirements under the regulation. In the case where the producer is a franchisor, it is the gross annual revenue of the system that is used to determine if an exemption applies.

Any producer who meets the exemption must keep any records that demonstrate its gross annual Ontario revenue is less than $2,000,000 in a paper or electronic format that can be examined or accessed in Ontario for a period of five years from the date of creation.

See our FAQs to understand what revenues municipalities and registered charities should consider when determining whether or not they are an exempt producer.

2. A producer who is above the revenue-based exemption level may still be exempt from performance requirements (collection, management and promotion and education) if their supply weight is below the exemption levels outlined in the table below.

If a producer’s annual revenue is more than $2,000,000 and supply weight in all material categories is less than the tonnage exemption threshold, the producer is required to register and report.

If a producer’s annual revenue is more than $2,000,000 and supply weight in at least one material category is above the tonnage exemption threshold, the producer is required to meet all obligations (registration, reporting, collection, management, and promotion and education). However, producers are only required to meet their minimum management requirement in material categories where they are above the exemption level.

3. As outlined in the amended Blue Box Regulation (released April 19, 2022), producers of newspapers may be exempt from collection, management, and promotion and education requirements. For the purposes of this exemption, “newspapers” includes newspapers and any protective wrapping and any supplemental advertisements and inserts that are provided along with the newspapers.

For a producer to qualify for this exemption, newspapers must account for more than 70% of their total weight of Blue Box materials supplied to consumers in Ontario in a calendar year. If exempt, the producer is not required to meet collection, management, and promotion and education requirements for all Blue Box materials they supply in Ontario in the following two calendar years.

A producer whose newspaper supply accounts for 70% or less of their total weight of Blue Box materials is subject to collection, management, and promotion and education requirements for all Blue Box materials they supply in Ontario.

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.

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.

For most producers and for all municipalities, little has changed:

1. Rule creators and the rule creation process, including the allocation table, have been removed. Instead, each producer is responsible for providing Blue Box collection to every eligible source in Ontario and creating a province-wide system for collection.
2. Producer Responsibility Organizations (PROs) are now required to submit a report to RPRA on how they will operate the Blue Box system on behalf of producers.
3. Newspaper producers whose newspaper supply accounts for more than 70% of their total Blue Box supply to consumers in Ontario are exempt from collection, management, and promotion and education requirements.

The amendments do not change or impact:

• Producer registration or 2020 supply data reporting to RPRA
• Most producers’ 2021 supply data reporting to RPRA
• The materials collected in the Blue Box system
• The communities that receive collection or the collection requirements
• The transition schedule and its timelines

Each Blue Box producer is required to report the Blue Box packaging they add to a product.

For example: a college or university bookstore plans to ship a book to a consumer in Ontario. The bookstore staff packages the book in a small box with the packing slip and inserts the box into a plastic mailer supplied by the delivery service with the required label affixed.

In this scenario, the college or university is the obligated producer of the small box and packing slip and must report these materials in their supply report, whereas the delivery company is the obligated producer of the plastic mailer and label and must report these materials in their supply report.

Also see:
Am I a producer of Blue Box product packaging?

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.

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.

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.

Yes, a Blue Box producer, or PRO (producer responsibility organization) on behalf of a producer, or a service provider on behalf of either party, can choose to offer collection services to any location. Blue Box producers are required to provide collection services to all eligible sources, as well as public spaces.

Blue Box materials collected from locations that are not eligible sources cannot count towards meeting a producer’s management requirement unless they were supplied to a consumer in Ontario. See this FAQ: Who is a consumer under the Blue Box Regulation?

If a person is co-collecting from locations that are eligible sources and not eligible sources, a person must use a methodology or process acceptable to the Authority to account for materials collected from each type of source. Anyone considering this can contact the Compliance Team to discuss at registry@rpra.ca or 833-600-0530.

For example, if materials are collected from an eligible source and a location that is not an eligible source along the same collection route, they must be accounted for separately. When those materials are then sent to a processor, they must also be accounted for separately.

A newspaper producer is a person who supplies newspapers to consumers in Ontario. For the purpose of the Blue Box Regulation, newspapers include broadsheet, tabloid or free newspaper. For further information, see the FAQ: What is a newspaper?

Note that a producer of supplemental advertisements or flyers that are supplied with a newspaper would not be considered a newspaper producer as they do not supply the actual broadsheet, tabloid, or free newspaper. This producer cannot use the newspaper exemption percentage to be exempt from Blue Box collection and management requirements. See the FAQ: Are there exemptions for Blue Box producers?

Individual Producer Responsibility (IPR) means that producers are responsible and accountable for collecting and managing their products and packaging after consumers have finished using them.

For programs under the Resource Recovery and Circular Economy Act, 2016 (RRCEA), producers are directly responsible and accountable for meeting mandatory collection and recycling requirements for end of life products. With IPR, producers have choice in how they meet their requirements. They can collect and recycle the products themselves, or contract with producer responsibility organizations (PROs) to help them meet their requirements.

There are only two allowable deductions for Blue Box materials. There are for materials that are:

• collected from an eligible source at the time a related product was installed or delivered (e.g., packaging that is removed from the house by a technician installing a new appliance). This is the “installation deduction”.
• deposited into a receptacle at a location that is collected from a business or institution where Blue Box collection services are not provided under the regulation. This is the “ineligible source deduction” that was expanded by the regulation amendment in July 2023.

Ineligible source deductions:

Blue Box Producers may deduct materials that are collected from a business or institution where producers are not required to provide Blue Box collection services. Examples include offices, stores and shopping malls, restaurants, community centres, recreation facilities, sports and entertainment venues, universities and colleges, and manufacturing facilities.

Producers cannot deduct the following materials collected through the collection systems established under the Blue Box Regulation:

• Material that is generated at a facility (including multi-residential buildings, retirement homes, long-term care homes and schools).
• Material that is collected from a residence through a curbside or depot collection service.
• Material that is collected from a public space (including an outdoor area in a park, playground or sidewalk, or a public transit station).
• Material collected under an alternative or supplemental collection system.
• Beverage containers cannot be deducted.

Materials that are deducted cannot count toward a producer’s management requirement.

Please see the Reporting Guidance Ineligible Source Deductions for the 2024 Blue Box Supply Report for more information on how to determine and use these deductions.

The brand holder is the obligated producer.

A marketplace facilitator only becomes obligated for products supplied through its marketplace where the producer would have been a retailer. If the producer is a brand holder or an importer, they remain the obligated producer even when products are distributed by a marketplace facilitator.

A retailer is a business that supplies products to consumers, whether online or at a physical location.

Yes, there have been some key changes to the producer hierarchies which may affect what a producer is obligated for and should be considered if using data previously reported to Stewardship Ontario:

• If a retailer is determined to be the producer based on hierarchies, but they are a marketplace seller, the marketplace facilitator is the obligated producer.
• Brand holders that are resident in Canada are obligated, which varies from the Stewardship Ontario program where brand holders that are resident in Ontario are obligated.

See our FAQ to understand “Who is a marketplace facilitator?”.

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.

Yes, a Blue Box producer or PRO (producer responsibility organization) on behalf of a producer, or a service provider on behalf of either party, can voluntarily choose to collect Blue Box materials that are not marketed to consumers.

Blue Box materials not marketed to consumers cannot be counted towards meeting a producer’s collection or management requirements under the Blue Box Regulation.

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

For example, if Blue Box materials supplied to a consumer in Ontario are collected along the same collection route as Blue Box materials that were not supplied to a consumer, they must be accounted for separately. When those materials are then sent to a processor, they must also be accounted for separately.

See the FAQ: Who is a consumer under the Blue Box Regulation?

Under the Blue Box Regulation, allowable deductions for producers include Blue Box materials that are deposited into a receptacle at a location that is not an eligible source and where the product related to the Blue Box material was supplied to a consumer and used or consumed.

This applies to locations such as arenas, college and university campuses and food courts.

A producer must demonstrate the following with regards to an allowable deduction:

1. They are the obligated producer for the materials for which they are claiming a deduction, and the weight of those materials was included in their reported supply data.
2. The materials were supplied onsite to a consumer for personal, family or household purposes.
3. The same materials that were supplied, were used or consumed onsite and disposed of in a receptacle onsite.

Blue Box materials that were disposed of in a building’s receptacles but were not supplied and used or consumed within that physical building are not deductible. This deduction applies to all Blue Box materials supplied for personal, family or household, but not those supplied for business purposes. This deduction is not available for beverage containers.

This does not reduce the obligation of a producer to provide complete and accurate supply data or limit the ability of an Authority inspector to review the data and related records for the purpose of determining compliance.

No, producers are not required to sign up with a PRO to meet their regulatory requirements. It is a business decision if a producer chooses to work with a PRO, and a producer can choose to meet their obligations without a PRO.

Most producers will choose to contract with a PRO to provide collection, hauling, processing, retreading and/or refurbishing services to achieve their collection and management requirements unless they carry out these activities themselves.

Yes, there are some key changes to the data reported to Stewardship Ontario and what needs to be reported under the new regulation, which may affect what a producer is obligated for and should be considered if using data previously reported to Stewardship Ontario:

• There are fewer reporting categories than under the Stewardship Ontario program
• Certified compostable packaging and products now must be reported separately, but this category does not have management requirements
• There are only two deductions permitted under the Blue Box Regulation, and producers must report total supply and then report any weight to be deducted separately
• Exemptions are based on tonnage supply under each material category instead of a total supply weight threshold of less than 15 tonnes as in Stewardship Ontario’s program

See our FAQ to understand “What deductions are available to producers under the Blue Box Regulation?”; “Are there exemptions for Blue Box producers?“; “Are there any differences in Blue Box producer hierarchies between the current Stewardship Ontario program and the new Blue Box Regulation?”; and “Are there are any differences in obligated Blue Box materials between the current Stewardship Ontario program and the new Blue Box Regulation?”

No, only producers are required to pay RPRA program fees.  The decision to make producers pay fees and cover the Authority’s costs was made to reflect the fact that the Resource Recovery and Circular Economy Act, 2016 (RRCEA) is based on a producer responsibility framework. Although producers may hire service providers to help meet their obligations, the responsibility remains with the producer.

For the purpose of reporting supply data under the Blue Box Regulation, the weight of newspaper, including any protective wrapping and supplemental advertisements and inserts, must be reported in the appropriate material categories. For example, newsprint must be reported in the ‘paper’ category, while any protective plastic wrapping must be reported as ‘flexible plastic’.

Then, producers will be asked to indicate what percentage of their total Blue Box material supply was newspaper, including any protective wrapping and supplemental advertisements and inserts, in that calendar year.

When reporting either their total supply or the percentage of their total supply that is newspaper, a producer should only include the weight of Blue Box materials for which they are the producer. For example, if flyers for which there is a different brand holder resident in Canada are supplied along with a newspaper and those flyers have a different brand holder resident in Canada, their weight should not be reported by the newspaper producer. Instead, it is the brand holder of those flyers who would be required to include the weight of those flyers in their own supply report.

See our FAQ: “What is a newspaper?”

A supplemental collection system is one of three types of collection and management systems that producers can choose to establish or participate in to contribute to their collection, management, and promotion and education requirements under the Blue Box Regulation.

Supplemental collection systems are not required to service all eligible communities south of Ontario’s Far North. Therefore, a producer participating in this type of system is still required to participate in the common collection system to meet their obligation to collect and manage Blue Box materials from all eligible communities, and to provide a promotion and education program.

One or more producers or PROs can establish a supplemental collection system. If a producer or PRO wishes to use a supplemental collection system’s collected materials towards producer minimum management requirements, that system should register with RPRA.

For more information on supplemental collection system registration criteria, please reach out to registry@rpra.ca.

Also see: ‘What is the Blue Box common collection system?’, ‘What is a Blue Box alternative collection system?’

Starting in 2022, producers are required to report their supply data annually to RPRA.

Each year, producers will need to provide the previous years’ supply data in each of the seven material categories – beverage container, glass material, flexible plastic, rigid plastic, metal material, paper material, and certified compostable products and packaging material – as well as any deductions.

See our FAQ to understand “What deductions are available to producers under the Blue Box Regulation?”

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.

For the purposes of supply data reporting, ‘refillable packaging’ is defined as packaging surrounding a supplied product that a consumer can return to the product manufacturer for cleaning and reuse.

A producer who supplies its products in refillable packaging should only report weights (under the appropriate material category) the first time the packaging is supplied to consumers.

For example:

A milk producer that used 1000 new glass bottles to supply its product to consumers in 2022, reported the weight of all 1000 bottles under the beverage container category in their 2023 supply data report.

In 2023, the producer added 500 new glass bottles to its supply, bringing the total of supplied material to 1500 bottles. Their 2024 supply data report should only reflect the weights of the 500 new bottles, not the total currently being used by the producer (1500).

Important: Products supplied in beverage containers should be reported in the ‘beverage container’ category, not the category the container is made of (plastic, metal, glass).

See Compliance Bulletin: What blue box materials need to be reported?

A producer responsibility organization (PRO) is a business established to contract with producers to provide collection, management, and administrative services to help producers meet their regulatory obligations under the Regulation, including:

• Arranging the establishment or operation of collection and management systems (hauling, recycling, reuse, or refurbishment services)
• Establishing or operating a collection or management system
• Preparing and submitting reports

PROs operate in a competitive market and producers can choose the PRO (or PROs) they want to work with. The terms and conditions of each contract with a PRO may vary.

No. The Authority does not administer contracts or provide incentives. Under the Regulations, producers will either work with a producer responsibility organization (PRO) or work directly with collection sites, haulers, refurbisher’s and/or processors to meet their collection and management requirements. Any reimbursement for services provided towards meeting a producers’ collection and management requirements will be determined through commercial contracts.

To discuss any payment, contact your service provider or a PRO. RPRA does not set the terms of the contractual arrangements between PROs and producers.

Sections 54 and 55 of the Blue Box Regulation require municipalities and First Nations to submit the information in the Initial Report and Transition Report to the Authority.

Under the Blue Box Regulation, producers will be fully responsible for the collection and management of Blue Box materials that are supplied into Ontario. To ensure that all communities continue to receive Blue Box collection services, communities will be allocated to producers, or PROs on their behalf, who are obligated to provide collection services. The information that is submitted in the Initial and Transition Reports will be used by PROs to plan for collection in each eligible community.

The Authority will also use the information provided by municipalities and First Nations to ensure that producers are complying with their collection obligations under the Blue Box Regulation.

It is important that municipalities and First Nations complete these reports accurately so that all eligible sources (residences, facilities, and public spaces) in their communities continue to receive Blue Box collection after their community transitions to full producer responsibility.

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.

Yes, producers are legally required to register and report to RPRA. There are some differences between which materials were reported to Stewardship Ontario as a steward and what must now be reported to RPRA as a producer. Differences include:

• newly obligated materials
• brand holder in Canada now obligated (rather than Ontario)
• producer must report total supply, and then report any weight to be deducted separately.

During transition years, stewards must meet their requirements (e.g., paying fees to Stewardship Ontario) under the Blue Box Program Plan and the WDTA. Producers also have requirements under the new Blue Box Regulation and the RRCEA, which includes registering, reporting, paying their program fee to RPRA and establishing collection, management and promotion and education systems for Blue Box materials.

An alternative collection system is one of three types of collection and management systems for Blue Box materials. Producers can choose to establish or participate in an alternative collection system to meet their collection, management, and promotion and education requirements under the Blue Box Regulation.

An alternative collection system can be established by one or more producers or PROs. The system must demonstrate that it can meet all system regulatory requirements as well as the minimum management requirements for participating producer(s). A producer can choose to meet their obligations using an alternative collection system instead of participating in the common collection system.

Types of alternative collection systems may vary and can include depot or return-by-mail systems. Alternative collection systems must service all eligible communities south of Ontario’s Far North.

For more information on alternative collection system registration criteria, please reach out to registry@rpra.ca.

Also see: ‘What is the Blue Box common collection system?’, ‘What is a Blue Box supplemental collection system?’

Producers are required to register with RPRA by October 1, 2021, as outlined in the Blue Box Regulation.

After this date, new businesses are required to register within 30 days of becoming a producer.

Yes, a producer can change PROs at any time. Producers must notify RPRA of any change in PROs within 30 days of the change.

For the purpose of reporting annual supply data under the Blue Box Regulation, the weight of newspaper must be reported in the appropriate material categories. For example, newsprint must be reported in the ‘paper’ category, while any protective plastic wrapping must be reported as ‘flexible plastic’.

Then, producers will be asked to indicate what percentage of their total Blue Box material supply was newspaper, including any protective wrapping and supplemental advertisements and inserts, in that calendar year.

See our FAQs: “What is a newspaper?” and “Who is a newspaper producer?”

No, beverage containers are not eligible for this deduction.

The allowable deduction is permitted for Blue Box materials that are deposited into a “non-eligible source,” meaning a place where consumers dispose of Blue Box materials that are not included in the producer-run collection system.

Under the Blue Box Regulation, beverage containers that are supplied to Ontario consumers for personal, family, household or business purposes are obligated Blue Box materials. The inclusion of “business purposes” is unique to the beverage container material category.

Because supplying a beverage container can mean either supplying for “personal, family and/or household purposes” that will likely be consumed and disposed of in a residential context (e.g., a home, apartment, long-term care facility, etc.) or supplying for “business purposes” that will likely be consumed and disposed of in a commercial or institutional context (e.g., a restaurant, college or gym), there are no “non-eligible sources” for beverage containers. All beverage containers must be reported and collected from all sources, whether they are residential, business, commercial or institutional.

See our FAQ to understand “What deductions are available to producers under the Blue Box Regulation?”

Under the WDTA Blue Box program, municipalities could choose to accept these materials in their programs. This choice varied between municipalities.

Under the producer-run Blue Box program, none of these materials are considered obligated Blue Box materials. The Blue Box Regulation specifically states that hard or soft cover books or products made from flexible plastic that is ordinarily used for the containment, protection and or handling of food, such as cling wrap, sandwich bags or freezer bags are not Blue Box materials. Pots and pans do not meet the definition of Blue Box material under the Regulation.

Producers are not obligated to collect or manage the recovery of these materials.

Producers are required to provide the following information when registering with RPRA:

• Contact information
• PRO information (if a PRO has been retained at time of reporting), including what services they have retained a PRO for
• Their 2020 supply data in each of the seven material categories– beverage container, glass material, flexible plastic, metal material, paper material, and certified compostable products and packaging material – as well as any deductions.

Please note that this information must be submitted to RPRA directly.

See our FAQ to understand “What deductions are available to producers under the Blue Box Regulation?”

A “Public space” means an outdoor area in a park, playground or beside/on a sidewalk, a public transit station or stop under municipal or provincial jurisdiction, including a track-level stop, to which the public is normally provided access.

During transition, producers are required to collect Blue Box material from public space receptacles in eligible communities that were provided collection service under the WDTA program.

The definition of a “public space” in the Blue Box Regulation is broader than the definition used in the Datacall for WDTA municipal funding purposes. For the purpose of collection services during transition, producers must collect from eligible communities’ public space receptacles collected as part of a communities’ Blue Box servicing that was funded under the WDTA Blue Box program (i.e., those along residential routes).

A brand supply list is a list of brands of obligated products that a producer supplies to consumers in Ontario. A producer must provide a brand supply list that makes up their supply data annually to RPRA. Each program has different requirements regarding how a producer must submit a brand supply list. For more information, consult the applicable programs’ walkthrough guide or contact RPRA’s Compliance and Registry Team at 1-833-600-0530 or by emailing registry@rpra.ca.

Unbranded products are products that do not have any mark, word, name, symbol, design, device or graphical element, or any combination of these, including a registered or unregistered trademark, which identifies a product and distinguishes it from other products.

The retailer who supplied the product to a consumer in Ontario, either online or at a physical location, is the obligated producer for the supply of Blue Box packaging on that unbranded product.

For example: A cucumber in plastic film sold at a grocery store that does not have any stickers, labeling or any other information associated with a brand is considered unbranded. As the retailer for that unbranded product, the grocery store is the obligated producer for the packaging supplied with the cucumber.

While the Blue Box Regulation states the requirement for Blue Box producers or PROs to deliver printed promotion and education materials in English and French to eligible sources by mail at least once a year, many Ontario municipalities have stopped providing printed promotion and education materials to their residents in favour of electronic formats.

As long as Blue Box producers or Blue Box PROs continue to provide the same format of promotion and education materials as the Ontario municipality provided prior to the date the municipality transitioned under the Blue Box Regulation (i.e., print or electronic or both), RPRA will consider this as having satisfied the requirement in section 72(1) paragraph 2. The materials must be provided in both English and French.

The common collection system is the Blue Box material collection and management system established by PROs on behalf of producers. Blue Box materials that are picked up through curbside residential collection, for instance, are processed through the common collection system. The system came into effect on July 1, 2023, as outlined in the Blue Box Regulation. The common collection system services all eligible communities south of Ontario’s Far North.

It is one of three types of collection and management systems that producers can choose to use to meet their minimum management requirements. Producers who use the common collection system to meet their obligations will contract with a PRO that is participating in the common collection system.

A high-level overview of the common collection system was provided by PROs Circular Materials and Ryse Solutions Ontario in 2022 in their Initial Blue Box Report.

Also see: ‘What is a Blue Box Alternative collection system?’, ‘What is a Blue Box supplemental collection system?’

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.

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.

Under the Blue Box Regulation, a packaging-like product is:

• ordinarily used for the containment, protection, handling, delivery, presentation or transportation of things
• ordinarily disposed of after a single use
• not used as packaging when it is supplied to the consumer

Packaging-like products include aluminum foil, a metal tray, plastic film, plastic wrap, wrapping paper, a paper bag, beverage cup, plastic bag, cardboard box or envelope, but does not include a product made from flexible plastic that is ordinarily used for the containment, protection, or handling of food, such as cling wrap, sandwich bags, or freezer bags.

If a producer is unsure whether or not their product is a packaging-like product, they can ask themselves the following questions to help determine whether the product is obligated to be reported under the Blue Box Regulation:

1. Is the product actually packaging around a separate product?
   • If yes, the product is not a packaging-like product. Instead, the product is considered blue box packaging and must be reported as blue box material.  If no, continue to the next question.
2. Is the product used for the containment, protection, handling, delivery, presentation or transportation of a thing(s)?
   • If no, the product is not a packaging-like product. If yes, continue to the next question.
3. Is the product typically disposed of after a single use (regardless if some may wash and reuse it)?
   • If no, the product is not a packaging-like product. If yes, continue to the next question.
4. Is the product made from flexible plastic that is for the containment, protection or handling of food?
   • If yes, the product is not a packaging-like product. If no, the product is a packaging-like product and must be reported as blue box material.

If a producer is still unsure whether or not their product is a packaging-like product, they should contact the Compliance and Registry Team at 833-600-0530 or registry@rpra.ca.

RPRA does not vet PROs before listing them on the website. Any business that registers as a PRO will be listed. Producers should do their own due diligence when determining which PRO to work with.

A marketplace facilitator is a person who contracts with a marketplace seller to facilitate the supply of the marketplace seller’s products by:

• Owning or operating an online consumer-facing marketplace or forum in which the marketplace seller’s products are listed or advertised for supply and where offer and acceptance are communicated between a marketplace seller and a buyer (e.g., a website), and
• Providing for the physical distribution of a marketplace seller’s products to the consumer (e.g., storage, preparation, shipping of products).

Under the Blue Box Regulation, if a retailer (online or at a physical location) is determined to be the producer based on hierarchies, but they are a marketplace seller, the marketplace facilitator is the obligated producer. A marketplace seller is a person who contracts with a marketplace facilitator to supply its products.

As an obligated Blue Box producer, you are required to:

• Register with RPRA
• Report supply data to RPRA annually
• Meet mandatory and enforceable requirements for Blue Box collection systems
• Meet mandatory and enforceable requirements for managing collected Blue Box materials, including meeting a management requirement set out in the regulation
• Meet mandatory and enforceable requirements for promotion and education
• Provide third-party audits of actions taken towards meeting your collection and management requirements, and report on those actions to RPRA through annual performance reports

Yes, producers are obligated to provide collection services to new single-family residences that come into existence during the transition period.

Producers are obligated to provide collection services to new facilities that come into existence during the transition period only if that facility would have qualified for collection services under the WDTA Blue Box Program.

For further certainty, the WDTA Blue Box Program includes collection services for multi-family households (including rental, cooperative or condominium residential), senior citizen residences, long-term care facilities and public and private elementary and secondary schools.

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.

If your community is south of the Far North boundary, you can complete the registration form and email it to registry@rpra.ca to express your community’s interest in participating in the producer-run Blue Box program. A Compliance Officer will reach out to you to discuss the reporting and offer process, confirm the information provided in the registration form, and answer any questions you may have.

Communities in this situation are eligible to receive recycling collection services starting January 1, 2026.

No, First Nations are not required to participate. First Nations can choose if the producer-run Blue Box system is the best option for their community. One of RPRA’s roles in overseeing the Blue Box program is to provide as much information as possible to support a community’s informed decision.

If your community is still undecided about whether or not to register, we encourage you to reach out to a Compliance Officer at registry@rpra.ca with your questions or to get more information.

Under the Blue Box Regulation which came into effect on July 1, 2023, eligible locations for collection within the producer-run program include:

• Private residences
• Public and private schools
• Elders’ lodges
• Not-for-profit retirement homes
• Not-for-profit long-term care facilities

Note: Commercial properties are not eligible for collection under the producer-run Blue Box program.

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.

The Authority recognizes the commercially sensitive nature of the information that parties submit to the registry. The Authority is committed to protecting the commercially sensitive information and personal information it receives or creates in the course of conducting its regulatory functions. In recognition of this commitment, the Authority, in addition to the regulatory requirements of confidentiality set out in the Resource Recovery and Circular Economy Act 2016 (section 57), has created an Access and Privacy Code that applies to its day-to-day operations, including the regulatory functions that it carries out.

Obligated material supply, collection, and resource recovery data will only be made public in aggregate form, to protect the confidentiality of commercially sensitive information.

The Authority will publish the names and contact information of all registered businesses – producers, service providers (collectors, haulers, processors, etc.), and producer responsibility organizations. The public will also have access to a list or method to locate any obligated material collection sites, as this information becomes available.

As part of its regulatory mandate, the Registrar will provide information to the public related to compliance and enforcement activities that have been undertaken.

The information that is submitted to the Registry will be used by the Registrar to confirm compliance and to track overall collection and management system performance. It will also be used by the Authority to update its policies and procedures and by the Ministry of Environment, Conservation and Parks for policy development.

There is an exemption in the Blue Box Regulation for producers whose gross annual revenue generated from products and services in Ontario is less than $2 million. The following sources are excluded for the purpose of determining revenue:

• Government tax revenue
• Property taxes
• General assistance funding received under the Ontario Municipal Partnership Fund
• Payments in lieu of taxes
• Canadian or Ontarian government grants available to municipalities with the intent of investing in public infrastructure

There is an exemption in the Blue Box regulation for producers whose gross annual revenue generated from products and services in Ontario less than $2 million. The revenue that counts towards the exemption is revenue from products and services. Charitable donations are not revenue from products and services and therefore does not count towards the exemption. Revenue other than charitable donations that are recorded from registered charities will be considered revenue from products and services.

Under the Blue Box Regulation, allowable deductions for producers include Blue Box materials that are deposited into a receptacle at a location that is not an eligible source and where the product related to the Blue Box material was supplied and used or consumed.

This applies to food court restaurants located in a mall or in the base of an office tower. Blue Box materials that were disposed of in the buildings’ recycling receptacles and were supplied and used or consumed within that physical building are an allowable deduction. Blue Box materials that were disposed of in the buildings’ recycling receptacles but were not supplied and used or consumed within that physical building are not deductible.

This does not reduce the obligation of a producer to provide complete and accurate supply data or limit the ability of an Authority inspector to review the data and related records for the purpose of determining compliance.

With the removal of the rule creation process and allocation table as the tools to create and maintain the Blue Box collection system, the amended regulation now requires producer responsibility organizations (PROs) to submit a report that outlines how they will operate the Blue Box collection system on behalf of producers, ensuring that materials are collected from all eligible communities (i.e., communities outside of the Far North) across the province.

Circular Materials Ontario and Ryse Solutions Ontario PROs submitted a Blue Box PRO initial report to RPRA on July 1, 2022, that provides the following information:

• A description of how they will comply with the collection requirements of the regulation, including any agreements between themselves and any other PRO
• A detailed description of how they will make collected Blue Box materials available for processing, how materials will be processed, and the expected location of receiving facilities in Ontario
• A description of how they will comply with the promotion and education requirements of the regulation

You can read the news release and the initial report here.

Public sector institutions, such as colleges and universities, are suppliers of Blue Box materials to consumers in Ontario. They supply Blue Box materials to consumers on-site (e.g., food service packaging, unprinted paper in photocopiers, etc.) and off-site (e.g., mailings).

For the purposes of supply reporting, colleges, universities, and other public sector institutions must determine the total amount of Blue Box material they supply to consumers in Ontario. One way to gather this data is by canvassing internal departments to obtain annual weights of Blue Box materials supplied to consumers on-site and off-site.

Also see:
FAQ: What deductions are available to producers under the Blue Box Regulation?
Compliance Bulletin: What Blue Box materials need to be reported?

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.

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.

Consumer protection laws in Ontario prohibits the misrepresentation of charges, which means that producers or retailers cannot misrepresent any visible fees as a regulatory charge, tax, RPRA fee or something similar. Consumers who have questions or concerns about a specific transaction or want to report a misrepresentation can contact the Ministry of Public and Business Service Delivery at 1-800-889-9768.

As of March 2023, the promotion and education requirements related to environmental fees have been removed from the Tires, Batteries, Electrical and Electronic Equipment, and Hazardous and Special Products regulations. No changes were made to the Blue Box Regulation as it never contained promotion and education requirements related to these fees.

RPRA’s compliance bulletin Charging Tire Fees to Consumers has since been revoked and RPRA has ceased its enforcement of promotion and education requirements for visible fees across all materials.

First Nation communities interested in receiving producer-run Blue Box services must register with the Authority. To register, communities must submit contact information of the person responsible for waste management in the community using the First Nation community registration form. Once completed, the registration form should be submitted by email to registry@rpra.ca.

Visit our First Nation webpage for more information.

RPRA’s Registry fees cover the costs related to compliance and enforcement and other activities required to administer the regulations under the RRCEA, and building and operating the Registry.

The Registry fees cover expenses in a given year (e.g., 2021 fees cover 2021 expenses). 2021 fees for Blue Box cover the Authority’s costs to undertake activities to implement the regulation in 2021, which include:

• helping obligated parties understand their requirements
• ensuring producers register and report their supply data by the deadline in the regulation
• compliance, enforcement, and communication activities

The rule and allocation table creation process has been removed from the Blue Box Regulation and is therefore no longer required to create and maintain the system for collecting Blue Box materials across the province, as per regulatory amendments made by the government on April 14, 2022. As such, rule creators are no longer applicable under the regulation. Learn more about the amendments.

To replace these tools, the amended regulation now requires PROs to submit a report that outlines how they will operate the Blue Box collection system on behalf of producers, ensuring that materials are collected from all eligible communities (i.e., communities outside of the Far North) across the province. Learn more about what PROs need to include in the report.

Processors need to provide the following information when registering with the Authority:

• Business information (e.g., business name, contact information)
• Processing site location, contact information and Blue Box materials received and processed at each location
• Any producers or PROs the processor has contracted with

Visit our Blue Box Processors webpage for more information.

A newspaper is a regularly (usually daily or weekly) printed document consisting of large, folded, stapled or unstapled, sheets of paper containing news reports, articles, photographs, and advertisements. Newspapers include broadsheet, tabloid, and free newspaper categories.

Newspapers have traditionally been published in print on low-grade paper known as newsprint. However, not all documents printed on newsprint are considered newspapers. For example, flyers printed on newsprint quality paper supplied separately from newspapers are not newspapers for the purpose of supply data reporting under the Blue Box Regulation.

For the purpose of supply reporting, newspapers include any supplemental advertisements and inserts that are provided with/inserted in them (e.g., a flyer or circular that is placed within the folds of a newspaper). Inserts may be composed of any material including, but not limited to, paper. See the FAQ: How do newspaper producers report their supply of newspapers?

Note that magazines are not considered newspapers; a magazine is a periodical publication containing articles and illustrations, typically covering a particular subject or area of interest, and printed on high-quality paper.

In the Blue Box Regulation, certified compostable products and packaging is defined as material that:

• is only capable of being processed by composting, anaerobic digestion or other processes that result in decomposition by bacteria or other living organisms, and
• is certified compostable by an international, national, or industry standard that is listed in this procedure.

All certified compostable products and packaging reported by producers must be certified under one of the following standards:

• CAN/BNQ 0017-088: Specifications for Compostable Plastics
• ISO 17088: Specifications for compostable plastics
• ASTM D6400: Standard Specification for Labeling of Plastics Designed to be Aerobically Composted in Municipal or Industrial Facilities
• ASTM D6868: Standard Specification for Labeling of End Items that Incorporate Plastics and Polymers as Coatings or Additives with Paper and Other Substrates Designed to be Aerobically Composted in Municipal or Industrial Facilities
• EN 13432: Requirements for packaging recoverable through composting and biodegradation – Test scheme and evaluation criteria for the final acceptance of packaging

RPRA will accept a report that substantiates the total Blue Box material weight deductions based on the customer’s recorded response to “Will you eat in or take out?” for all locations. Reports must be retained either in electronic or paper format for five years and be provided upon request for verification by RPRA.

Where an entire community is receiving recycling curbside collection and has access to recycling depots, the requirement is that during transition, that same level of service is still provided. After transition, there is no requirement to maintain depots within these communities.

Starting January 1, 2023, RPRA will collect 13% HST on all fees at the time of fee payment.

This decision is based on a ruling RPRA received from the CRA in which HST must be charged on its fees under the Resource Recovery and Circular Economy Act, 2016 (RRCEA). RPRA has determined that this ruling applies to all RRCEA producer responsibility programs and the Excess Soil and Hazardous Waste programs.

On December 22, 2022, RPRA will reissue invoices that were issued prior to January 1, 2023, amended to indicate that 13% HST was paid. From December 22 onwards, registrants will be able to access the amended invoices in their Registry accounts under a new tab labelled “Invoices”. The amended invoice will show an HST amount as well as the date the amended invoice was reissued.

Important notes:

• On the amended invoices there have been no changes to the Invoice Total and registrants will not be required to pay any additional monies to RPRA for past invoices.
• Registrants may be able to claim input tax credits for the HST collected on RPRA fees, for both the amended invoices and new invoices issued January 1, 2023, onwards. However, RPRA is not in a position to provide tax advice and suggests you consult your internal or external accountants to seek their counsel.
• All new invoices issued effective January 1, 2023, will contain appropriate information identifying the amount of the HST and other relevant details. These invoices will also be displayed under the “Invoices” tab in a registrants’ Registry account.

A First Nation’s transition date represents the earliest date that producers are required to provide the community with either Blue Box service or funding within the Blue Box program. Transition dates cannot be moved or changed.

A First Nation’s community name, reserve name(s) and transition date appearing on the transition schedule means it is an eligible community to receive Blue Box collection service or funding between July 1, 2023, and December 31, 2025. The transition schedule was amended for the last time on February 23, 2024. There will be no more additions to the transition schedule.

Related FAQs:

• ‘When will a First Nation that is registered in the Blue Box program start receiving service or funding?’
• ‘What do I do if my First Nation wants to join the Blue Box program but is not listed on the transition schedule?’

Any public sector institution, including colleges and universities, that offers a self-serve hot drink machine for use by students and employees (i.e., consumers) must report all the Blue Box materials supplied with the machine to serve the hot drinks. This includes branded and unbranded single-use cups, lids, etc.

Any donated or re-supplied paper products or other Blue Box materials that are supplied to consumers through a reuse store or upcycling event should not be included in your supply report.

Eligible Ontario institutions are obligated to manage their waste under several regulations, each of which imposes different obligations and requirements.

Under the Ontario Environmental Protection Act, Industrial, Commercial and Institutional (IC&I) sector organizations have obligations to establish and operate an internal collection system that separates the waste generated on-site into different material categories (i.e., a source-separation program).

The Blue Box Regulation, under the Resource Recovery and Circular Economy Act, obligates producers of Blue Box material to collect, manage, and report on the materials that they supply to consumers both on-site and off-site.

Under the WDTA Blue Box program, some municipalities may have chosen to provide Blue Box collection to facilities that were not residences, such as commercial properties, municipally owned and operated buildings or other institutions.

Under the Blue Box Regulation, only certain types of facilities can receive collection under the producer-run Blue Box program. These facilities are:

1. Multi-residential facilities with six or more dwelling units
2. Retirement homes that are operated by a municipality or an entity that does not operate with the purpose of generating a profit or were included in the WDTA Blue Box program on August 15, 2019. “Retirement home” has the same meaning as in the Retirement Homes Act, 2010.
3. Long-term care homes that are non-profit long-term care homes or were included in the WDTA Blue Box program on August 15, 2019. “Long-term care home” has the same meaning as in the Fixing Long-Term Care Act, 2021. “Non-profit long-term care home” has the same meaning as the regulations under the Fixing Long-Term Care Act, 2021.
4. Buildings that contain public or private elementary or secondary schools. “School” and “private school” have the same meaning as in the Education Act.

Yes, reusable bags made from Blue Box materials ( e.g. plastic, paper) and used as convenience packaging are obligated under the Blue Box Regulation and must be reported annually by producers in their supply report.

Convenience packaging refers to material that is provided with a product for consumers to handle or transport that product, in addition to the product’s primary packaging. This includes items such as bags and boxes that are supplied to consumers at check out.

For additional clarity:

• Reusable bags made primarily from plastic, paper, or any other Blue Box material, or a combination of these materials, are obligated. Reusable bags made from textile fibres such as cotton, hemp, bamboo, etc., are not obligated.
• Recycled content of the material has no impact on whether a reusable bag is obligated. For example, reusable bags containing post-consumer recycled plastic content are obligated.
• A reusable bag is obligated regardless of whether it is supplied to the consumer for free or at a cost. Examples include bags supplied at checkout to consumers at retail locations.

If you haven’t been reporting reusable bags as part of your annual supply data, please contact the Compliance Team immediately at registry@rpra.ca.

Also see our FAQ: ‘What do I do if I misreported my supply data?’

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?”