Frequently Asked Questions

Large producers for supply data verification

Producers whose average supply meets the large producer threshold in the below chart must submit a verification report for that reporting year.

Example: Producers of oil filters that have an average weight of supply in their 2023 supply report that exceeds 100 tonnes are considered a large producer and must submit a verification report for oil filters in 2024.

Small producers for supply data verification

Producers who are below the threshold are considered small producers. Small producers are only required to submit a verification report but will be subject to inspections.

For the purposes of battery supply reporting verification:

• “Large single-use battery producer” means a battery producer with a minimum management requirement greater than or equal to 50,000 kilograms of single-use batteries in the previous calendar year.
• “Large rechargeable battery producer” means a battery producer with a minimum management requirement greater than or equal to 5,000 kilograms of rechargeable batteries in the previous calendar year.

To view your management requirements, log into your Registry account, download a copy of your previous year’s Supply Report and review the section with your minimum management requirements for your reporting year.

Beginning in 2023, only large producers are required to submit a Supply Data Verification Report. Small producers will no longer be required to submit a verification report but will be subject to inspections. Review the Registry Procedure – Verification and Audit for more information.

You may be required to provide a verification report for the annual tire supply report. You will be required to provide verification if you meet the definition of a medium or large producer. Small producers will not be required to submit a verification report, however a percentage of small producers selected annually by the Registrar will be subject to an inspection. If exceptions are identified during the inspection, a comprehensive review may be carried out. For more information on this, read Tires Registry Procedure – Audit.

As shown in the table below, verification of the ITT/AV supply data reported in 2020 and 2021 is not required. Verification of supply data for ITT/AV will be required starting in 2022 for products supplied in 2020. All subsequent years of supply data are required to be verified when the data is reported.

For more information on the required verification and audit of data, view the Registry Procedure: EEE Verification and Audit.

There is no audit verification requirement for the first two supply data reports submitted to the Authority. Therefore, data submitted for single-use batteries supplied in 2018, 2019, and 2020, as well as rechargeable batteries supplied in 2018 and 2019 will not have to be verified in accordance with the Registry Procedure – Verification and Audit.

As shown in the table below, under section 15 of the Battery Regulation, the first supply data report for which there are audit and verification requirements will be submitted in 2022. This supply data report is for single-use batteries supplied in 2021 and rechargeable batteries supplied in 2020.

No. The list of products obligated under the EEE Regulation is different from the list of products included in the OES Program. The OES Program required producers to report the number of units they supplied, while the EEE Regulation requires producers to report the total weight of products.

To help producers calculate the weight of their products, we have included weight conversion factors in our Verification and Audit procedure, which is included as a weight conversion tool on the registration form.  Once a producer determines the units of products on which they are obligated to report, they can enter the units into the conversion tool to get a calculated weight to report to the Authority.

For more information, see the Determining Supply Data section of the Registry Procedure: EEE Verification and Audit.

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.

As an obligated HSP producer, you are required to:

• register and report annual supply and performance data of obligated materials
• meet mandatory and enforceable requirements for collection and management
• meet mandatory and enforceable requirements for promotion and education
• meet mandatory and enforceable requirements for auditing, verification, and record keeping

These requirements vary based on material type and amount of material the producer supplies.

The diversion rate calculated in the GAP summary is unverified.

Do not publish your GAP diversion rate until Datacall verification and analysis has been completed and the diversion rates have been published by RPRA.

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.

For the purposes of the Blue Box Regulation, a beverage container is a container that:

1. Contains a ready-to-drink beverage product,
   • “Ready-to-drink” means a beverage packaged by the manufacturer for immediate consumption that does not require any preparation. A ready-to-drink beverage is intended to be consumed as purchased and does not require a dispensing device to be consumed.
   • “Beverage” means a consumable liquid for enjoyment or hydration. It does not include an “alcoholic beverage”, or “non-alcoholic beer, wine or spirits” as defined in O. Reg. 391/21.
2. Is made from metal, glass, paper or rigid plastic, or any combination of these materials, and
   • If a beverage container is made only of flexible plastic, it would be obligated as a Blue Box material but would be reported under the material category “Flexible Plastic” rather than the “Beverage Container” material category. The Blue Box Regulation defines flexible plastic as unmoulded plastic. For more information on reporting of packaging and beverage containers that consist of multiple materials, please see the “Component Threshold Rule” in the Blue Box Verification and Audit Procedure Registry Procedure.
3. Is sealed by its manufacturer.
   • A cup provided to a consumer in a restaurant filled with fountain pop is not sealed by the manufacturer and is therefore not considered a beverage container. However, the cup (including the lid and straw) would still be obligated as a Blue Box material in the paper and/or plastic material categories.

For greater clarity, the Registrar does not consider the packaging from the following product types to be a beverage container:

• Infant formula
• Meal replacements, nutritional supplements or dietary supplements
• Regulated health products
• Concentrated beverages intended to be mixed or diluted before consumption, such as frozen juices, cocktail mixers, extracts and flavour enhancers
• Liquids that are not intended to be consumed as purchased such as soup, syrups, cream and other beverage additives, whipping cream, buttermilk, broth
• Beverage containers made of flexible plastics such as milk bags (these are still to be reported as flexible plastics)

Milk products and substitutes (e.g., soy beverage, almond beverage, a rigid plastic container of milk, drinkable yogurt) are beverage containers provided they are packaged in a container as defined above.

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.