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Frequently Asked Questions

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  • There are exemptions under the HSP Regulation for category A and B producers. If an HSP producer meets the exemption threshold for a material type, they are not required to establish a collection system, manage those materials or implement a promotion and education program.

    Producers of refillable pressurized containers that meet the exemption threshold are still required to provide a call-in collection service.

    An HSP producer qualifies for an exemption if their average weight of supply for the previous calendar year is less than or equal to the weight (in tonnes) specified in the chart below:

    Type of HSPExempt (Less than <)
    Oil Filters3.5
    Non-refillable Pressurized Containers3
    Antifreeze20
    Oil Containers2
    Solvents3
    Paints and Coatings10
    Pesticides1
    Refillable Pressurized Containers8
    Mercury-containing DevicesN/A
    Fertilizers
    Propane Containers (refillable)

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

    See our FAQ “Am I a small, large, or exempt HSP producer?” to determine how to calculate if you are an exempt HSP producer.

    HSP producers that meet the exemption criteria are exempt from:

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

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

    Producers are advised to confirm their exemption with the Compliance and Registry Team at 1-833-600-0530 or [email protected].

  • HSP producers that meet the exemption criteria are exempt from certain requirements under the HSP regulation. See our FAQ: How do I determine if I am an exempt HSP producer?.

    Producers can reference the chart below to determine if they are a small, large or exempt HSP producer.

    Producer categories use the average weight of material (in tonnes) supplied in Ontario in the previous calendar year.

    Type of HSPExempt (Less than <)Small Producer Large Producer (Equal to or greater than >)
    Oil Filters3.5⟷100
    Non-refillable Pressurized Containers3⟷100
    Antifreeze20⟷300
    Oil Containers2⟷55
    Solvents3⟷70
    Paints and Coatings10⟷1,000
    Pesticides1⟷9
    Refillable Pressurized Containers8N/AN/A
    Mercury-containing DevicesN/A
    Fertilizers
    Propane Containers (refillable)

    Note that ‘⟷’ indicates a value greater than ‘Exempt’ but less than ‘Large Producer’ threshold.

    Average supply weight is determined using the following formula:

    Average weight of HSP supply = (Y1 + Y2 + Y3) / 3 

    E.g. 2025 average weight of supply = (2024 + 2023 + 2022) / 3

  • 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 of oil filters and non-refillable pressurized containers have individual management requirements which are determined by the formulas found in section 2 of the HSP Regulation multiplied by the number found in section 31 of the regulation.

    Oil filters

    A producer’s minimum management requirement is determined by the formulas summarized in the table below.

    Performance YearSupply Report YearFormula
    20252024[(2024+2023+2022)/3] × 85%
    20262025[(2025+2024+2023)/3] x 85%
    20272027[(2026+2025+2024)/3] x 85%
    20282027[(2027+2026+2025)/3] x 85%

    Non-refillable pressurized containers

    A producer’s minimum management requirement is determined by the formulas summarized below.

    Performance YearSupply Report YearFormula
    20252024[(2024+2023+2022)/3] × 30%
    20262025[(2025+2024+2023)/3] x 30%
    20272027[(2026+2025+2024)/3] x 30%
    20282027[(2027+2026+2025)/3] x 30%

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

    Note: Exempt producers are not required to meet minimum management requirements.

    See our FAQ “How do I determine if I am an exempt HSP producer?” to learn more.

  • Producers are required to establish and operate a collection system that meets the accessibility requirements in the regulation. Producers must ensure that all HSP collected is managed regardless of what their minimum management requirements are.

    For producers to meet their obligations, they have the choice of establishing and operating their own collection and management system or working with one or more producer responsibility organizations (PROs) that are registered with RPRA.
    Large producers have an additional requirement to provide call-in collection services. Learn more.

    Please contact the Compliance Team at 1-833-600-0530 or [email protected] to discuss other requirements under the HSP Regulation.

    See our FAQ to understand “Am I a small, large or exempt HSP producer?“. For more guidance, read the Hazardous and Special Products Collection Systems Compliance Bulletin.

  • The Manage PRO option will appear on the dashboard below your list of supply data reports when your supply data reporting is complete and if you have management requirements. If your supply data reporting is below the supply exemption threshold you will not have management requirements, and therefore not need to assign a PRO to assist with your obligations.

    Also note that Account Admin are the only portal users that can manage your PRO’s responsibility, so this widget is not viewable to primary and secondary users.

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