Frequently Asked Questions

RPRA’s Audit and Risk Team uses a three-stage risk-based framework to verify reporting accuracy, address data gaps, and enforce regulatory compliance.

Whether or not a producer is required to go through all three stages will depend on the outcomes at each stage. Findings from the initial risk assessment will determine whether producers undergo a verification review; the results of the verification review will determine whether producers are subject to an audit.

Details about each stage are outlined below:

1. Risk assessment
   • Selected producers will be asked to complete and submit a Blue Box Supply Assessment Form by a set deadline. Failure to complete the form by the deadline will trigger escalating compliance enforcement actions.
   • If no further risks or data gaps are identified, additional outreach may not be required.
2. Verification review
   • RPRA will commence a formal verification review if a producer’s data requires deeper verification.
   • An assigned Audit and Risk Officer (ARO) will manage the case and work directly with the producer.
   • Producers must supply AROs with all requested documentation, methodology details, and records necessary to validate reported supply data.
3. Audit
   • Verification inspections that uncover multiple high-risk issues or unresolved inconsistencies will be escalated to a formal audit.
   • Producers will receive a formal audit notification letter alongside a list of required records.
   • Audits will include on-site visits by AROs to outline the scope of the audit work, review internal procedures, test source records, and evaluate end-to-end reporting controls.
   • Following the audit, RPRA will issue recommendations and conduct follow-up reviews to verify that requested corrective actions to internal processes and reporting adjustments have been completed.
   • Producers are reminded that failure to submit the required information at any stage in the inspection process may lead to enforcement action.

For more information, see our FAQ: Why was I was selected for a verification inspection of my 2026 to be part of the Blue Box Inspection Campaign supply data?

For the purposes of battery supply reporting verification:

• “Large single-use battery producer” means a battery producer with a three-year rolling average supply weight in respect of a calendar year that is equal to or more than 100,000 kilograms of single-use batteries.
  • Example: For the 2026 supply data report, the three-year rolling average supply weight is calculated as: (weight supplied in 2024 + weight supplied in 2023 + weight supplied in 2022)/3

• “Large rechargeable battery producer” means a battery producer with a three-year rolling average supply weight in respect of a calendar year that is equal to or more than 12,000 kilograms of rechargeable batteries.
  • Example: for the 2026 supply data report, the three-year rolling average supply weight is calculated as: (weight supplied in 2023 + weight supplied in 2022 + weight supplied in 2021)/3

Only large producers are required to submit a supply data verification report. While small producers are not required to submit a verification report, they are still subject to inspections. Review the Batteries Registry Procedure – Verification and Audit for more information.

If you are unsure if your company meets the definition of a large producer, contact RPRA’s Compliance and Registry Team at [email protected] or 833-600-0530.

Each year, producers of categories A (oil filters and non-refillable pressurized containers) and B (oil containers, antifreeze, solvents, paints and coatings, and pesticides) that meet the definition of a ‘large producer’ are required to submit a supply data verification report in accordance with the HSP Verification and Audit Procedure. Small producers are not required to submit a verification report but will be subject to inspections.

See our FAQ: As an HSP producer, am I required to submit an annual supply data verification report?

For the purposes of lighting supply data verification: 

• “Large lighting producer” means a lighting producer with a three-year rolling average supply weight in respect of a calendar year that is equal to or more than 90,000 kilograms.
• • Example: for the 2026 supply data report, the three-year rolling average supply weight is calculated as: (weight supplied in 2023 + weight supplied in 2022 + weight supplied in 2021)/3

Only large producers are required to submit a supply data verification report. While small producers are not required to submit a verification report, they are still subject to inspections. Review the EEE Verification and Audit Procedure for more information. 

If you are unsure if your company meets the definition of a large producer, contact RPRA’s Compliance and Registry Team at [email protected] or 833-600-0530.

For the purposes of tire supply data verification:

• “Large tire producer” means a tire producer with a three-year rolling average supply weight that is more than 500,000 kilograms.
  • Example: for the 2026 supply data report, the three-year rolling average supply weight is calculated as: (weight supplied in 2023 + weight supplied in 2022 + weight supplied in 2021)/3

Only large producers are required to submit a supply data verification report. While small producers are not required to submit a verification report, they are still subject to inspections. Review the Tire Registry Procedure – Audit for more information.  

If you are unsure if your company meets the definition of a large producer, contact RPRA’s Compliance and Registry Team at [email protected] or 833-600-0530. 

Each year, large battery producers are required to submit a supply data verification report in accordance with the Batteries Registry Procedure – Verification and Audit. Small producers are not required to submit a verification report but will be subject to inspections. 

See our FAQ: For annual supply reporting verification, how do I know if I am a small or large battery producer?

Each year, large ITT/AV producers are required to submit a supply data verification report in accordance with the EEE Verification and Audit Procedure. Small producers are not required to submit a verification report but will be subject to inspections.  

See our FAQ: For annual supply reporting verification, how do I know if I am a small or large ITT/AV producer?

Each year, large lighting producers are required to submit a supply data verification report in accordance with the EEE Verification and Audit Procedure. Small producers are not required to submit a verification report but will be subject to inspections. 

See our FAQ: For annual supply reporting verification, how do I know if I am a small or large Iighting producer?

Each year, large tire producers are required to submit a supply data verification report in accordance with the Tires Registry Procedure – Audit. Small producers are not required to submit a verification report but will be subject to inspections.  

See our FAQ: For annual supply reporting verification, how do I know if I am a small or large tire producer?

RPRA’s Compliance and Enforcement Team is undertaking a risk-based review of 2026 Blue Box supply data submitted by producers. The following risk factors were considered when selecting producers for inspection:

• Producers filing deductions: Supply report submissions containing material deductions, where larger deduction volumes or multiple submissions increase regulatory risk.
• Producers claiming compostable exemptions: Supply report submissions claiming exemptions for compostable materials, particularly those involving large volumes or multiple filings.
• Significant year-over-year variance: Producers displaying substantial unexplained changes in reported supply tonnage compared to previous years.
• High-volume producers: Market participants representing significant overall quantities of system tonnage.
• Inconsistent registration history: Producers who have not registered consistently every reporting year.

This inspection process prioritizes data validation and evaluation of historical submissions. The process is meant to enhance reporting accuracy and, where required, enforce regulatory requirements to help ensure that all Blue Box producers are held to a consistently high standard of compliance.

For more information, see our FAQ: What is the process for the 2026 Blue Box supply data inspection campaign?

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 RPRA.

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

Being selected as a subject of an inspection does not automatically mean a producer is out of compliance. While selection relies on RPRA’s risk-based framework, the first step of the process is an initial assessment, not a formal inspection or audit.

However, subsequent verification and audit activities may be undertaken by RPRA to determine whether enforcement action will be taken.

Yes. If you are a producer with retailers or distributors supplying your obligated EEE into Ontario, you can email us at [email protected] 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 RPRA. You must contact RPRA 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 RPRA 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.

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 [email protected] or 1-833-600-0530.

Impacts on producers of antifreeze and/or oil filters provided in new vehicles

Supply reporting

Vehicle brand holders, importers and marketers are now obligated for antifreeze and/or oil filters that are supplied in new vehicles sold in Ontario. 

Subsection 7(2) of the amended HSP Regulation states that these producers must report to RPRA the weights of antifreeze and/or oil filters that were supplied in new vehicles sold in Ontario in 2022, 2023 and 2024. This change to the producer hierarchy may impact supply reports previously submitted to RPRA. It may also require producers to submit a supply data verification report if they meet the definition of a large producer, based on the newly submitted supply data.  Producers who need to submit adjusted supply data as a result of this change to the producer hierarchy should contact RPRA before July 31, 2025. 

Although there may be adjustments to the historical supply data, the collection and management requirements for the 2025 calendar year remain unchanged. 

Management requirements

Beginning January 1, 2026, these vehicle brand holders, importers and marketers of antifreeze and/or oil filters supplied in new vehicles will also be required to fulfill collection and management obligations, including reporting on their performance in meeting their obligations.  

This includes ensuring there are sufficient collection sites in a community based on the size of the producer and that the HSP material is managed within 3 months of being collected. Specifically, oil filter producers must ensure that the weight of the recovered resources from managing oil filters in 2026, and every year thereafter, meets or exceeds their individual management requirement as calculated under subsection 31(3) of the HSP Regulation. 

Impacts on producers of antifreeze and/or oil filters not supplied in new vehicles 

The producer hierarchy for antifreeze and/or oil filters supplied in containers (i.e., not supplied in new vehicles) remains unchanged. 

These producers may have reported tonnage for antifreeze and/or oil filters supplied in new vehicles as part of their supply reports in previous years and, if so, they should contact RPRA before July 31, 2025 to clarify their obligations and make changes to their supply data, as required.