Frequently Asked Questions

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• Program: Batteries , Blue Box , Hazardous and Special Products , ITT/AV , Lighting , Tires

  Topic: Producer

  Toggle the submenu Who is a brand holder?

  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.

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• Program: Blue Box

  Topic: Collection systems , Management activities , Producer , Registration , Reporting

  Toggle the submenu If a marketplace facilitator supplies products for which there is a brand holder resident in Canada, who is the obligated producer?

  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.

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• Program: Blue Box

  Topic: Producer , Reporting

  Toggle the submenu If I already reported my Blue Box supply data to Stewardship Ontario through the WeRecycle Portal, do I have to report again to RPRA?

  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.

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• Program: Blue Box

  Topic: Producer , Reporting

  Toggle the submenu How do newspaper producers report their supply of newspapers?

  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?”

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• Program: Blue Box

  Topic: Producer , Reporting

  Toggle the submenu Are cheques an obligated material?

  Yes, cheques are an obligated material and should be reported under the paper material category. If you have questions regarding how to determine whether you are the brand holder and are obligated to report the supply of cheques, please reach out to the Compliance & Registry team at registry@rpra.ca.

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• Program: Lighting

  Topic: Producer , Registration

  Toggle the submenu Am I a lighting producer?

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

  

  To help determine if your company is the obligated producer under the EEE Regulation, consider the following questions:

  1. Is my company the brand holder for the products we supply? If yes, does my company have residency in Canada?
  2. Does my company import any of the products we supply from outside of Ontario? Is there a brand holder resident in Canada for those products that we import?
  3. Does my company market any products directly to consumers in Ontario?

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

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• Program: Hazardous and Special Products

  Topic: Producer

  Toggle the submenu Under the HSP regulation, what are the key changes to producer hierarchies?

  There have been some key changes to the producer hierarchies in the HSP Regulation. This may affect what a producer is obligated for and should be considered if using data previously reported.

  Hierarchy change for producers in all categories:

  • Brand holders that are resident in Canada are obligated (previously was resident in Ontario)

  Hierarchy change for producers of oil filters, oil containers, antifreeze, pesticides, non-refillable pressurized containers, refillable pressurized containers, solvents, paints or coatings:

  • Producer hierarchy’s introduction of marketers with or without residency in Ontario

  See our FAQ to understand “Am I an HSP Producer?”

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• Program: Hazardous and Special Products

  Topic: Producer , Registration

  Toggle the submenu Am I an HSP producer?

  A person is considered a producer under the HSP Regulation if they supply oil filters, oil containers, antifreeze, solvents, paints and coatings, pesticides, fertilizers, pressurized containers or refillable propane containers and:

  • are the brand holder and has residency in Canada
  • import from outside Ontario and has residency in Ontario
  • markets directly to consumers in Ontario (e.g., online sales) and has residency in Ontario
  • markets directly to consumers and does not have residency in Ontario

  A person is considered a producer under the HSP Regulation if they supply mercury-containing barometers, thermometers or thermostats and:

  • are the brand holder and has residency in Canada
  • are the Brand holder of barometers, thermometers or thermostats marketed to consumers in Ontario that do not contain mercury

  A person is considered a producer under the HSP Regulation if they supply fertilizers and:

  • are the brand holder and has residency in Canada

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

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• Program: Blue Box

  Topic: Producer

  Toggle the submenu Are there any differences in Blue Box producer hierarchies between the current Stewardship Ontario program and the new Blue Box Regulation?

  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?”.

   

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• Program: Blue Box

  Topic: Producer , Registration , Reporting

  Toggle the submenu Am I a producer of paper products or packaging-like products?

  See our FAQs to understand “What are paper products?” and “What are packaging-like products?”.

  For paper products and packaging-like products, a person is considered a producer:

  • if they are the brand holder of the paper product or packaging-like product and are resident in Canada
  • if no resident brand holder, they are resident in Ontario and import the paper product or packaging-like product
  • if no resident importer, they are the retailer that supplied the paper product or packaging-like 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

   

  

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