Frequently Asked Questions
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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.
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.
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 email@example.com 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.
No. Effective February 6, 2023, RPRA will no longer accept requests for extensions to registration or reporting deadlines. Obligated parties should make every effort to ensure they meet all submission deadlines as part of their obligations under their associated regulation.
For more guidance, read the Late Registration or Report Submissions Compliance Bulletin.
Failure of an obligated party to meet a registration or reporting deadline may result in compliance action, including compliance orders, prosecutions or monetary penalties issued in accordance with the Administrative Penalties Guidelines.
In accordance with the Risk Based Compliance Framework, RPRA will communicate to obligated parties, via email, about their reporting requirements in advance of submission deadlines. RPRA will also send deadline reminders and notify missed deadlines to obligated parties prior to taking further compliance action.
For more guidance, read the new Late Registration or Report Submissions Compliance Bulletin.
Registry Resources such as Registry Procedures, Compliance Bulletins, and Reporting Guides can be found on our Lighting Registry Resources webpage.
RPRA has developed a library of resources to support Registry users navigate the online system and meet their regulatory requirements. RPRA consistently adds to this pool of resources based on upcoming requirements, emerging needs, and questions we receive from stakeholders.
View Registry resources for each program:
Registrants can access past invoices in their Registry account under a new tab labelled “Invoices”. See sample screenshot below.
Registrants can access past invoices in their Registry account under a new tab labelled “Invoices”. A banner will be displayed that highlights whether an invoice has been amended to include HST as well as the date the amended invoice was reissued. This will show on all invoices with an invoice date before December 21, 2022. See sample screenshot below.
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.
- 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.