Frequently Asked Questions

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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

  Toggle the submenu Who is the obligated producer for blue box packaging on unbranded products?

  Unbranded products are products that do not have any mark, word, name, symbol, design, device or graphical element, or any combination of these, including a registered or unregistered trademark, which identifies a product and distinguishes it from other products.

  The retailer who supplied the product to a consumer in Ontario, either online or at a physical location, is the obligated producer for the supply of Blue Box packaging on that unbranded product.

  For example: A cucumber in plastic film sold at a grocery store that does not have any stickers, labeling or any other information associated with a brand is considered unbranded. As the retailer for that unbranded product, the grocery store is the obligated producer for the packaging supplied with the cucumber.

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• Program: Blue Box

  Topic: Producer

  Toggle the submenu Who is a newspaper producer?

  A newspaper producer is a person who supplies newspapers to consumers in Ontario. For the purpose of the Blue Box Regulation, newspapers include broadsheet, tabloid or free newspaper. For further information, see the FAQ: What is a newspaper?

  Note that a producer of supplemental advertisements or flyers that are supplied with a newspaper would not be considered a newspaper producer as they do not supply the actual broadsheet, tabloid, or free newspaper. This producer cannot use the newspaper exemption percentage to be exempt from Blue Box collection and management requirements. See the FAQ: Are there exemptions for Blue Box producers?

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• Program: Blue Box

  Topic: Producer , Reporting

  Toggle the submenu What must a producer demonstrate to deduct materials that are supplied, used, or consumed and disposed of at a non-eligible source (e.g., an arena, a college or university campus, or a food court)?

  Under the Blue Box Regulation, allowable deductions for producers include Blue Box materials that are deposited into a receptacle at a location that is not an eligible source and where the product related to the Blue Box material was supplied to a consumer and used or consumed.

  This applies to locations such as arenas, college and university campuses and food courts.

  A producer must demonstrate the following with regards to an allowable deduction:

  1. They are the obligated producer for the materials for which they are claiming a deduction, and the weight of those materials was included in their reported supply data.
  2. The materials were supplied onsite to a consumer for personal, family or household purposes.
  3. The same materials that were supplied, were used or consumed onsite and disposed of in a receptacle onsite.

  Blue Box materials that were disposed of in a building’s receptacles but were not supplied and used or consumed within that physical building are not deductible. This deduction applies to all Blue Box materials supplied for personal, family or household, but not those supplied for business purposes. This deduction is not available for beverage containers.

  This does not reduce the obligation of a producer to provide complete and accurate supply data or limit the ability of an Authority inspector to review the data and related records for the purpose of determining compliance.

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

  Topic: Producer , Registration , Registry , Reporting , RPRA Program and Registry Fees

  Toggle the submenu Can a producer choose to work with an external consultant?

  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.

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

  Topic: Producer

  Toggle the submenu Where a producer is exempt, do the obligations for the materials for which they are the producer become the responsibility of the organization that is next in the producer hierarchy?

  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.

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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: Collection systems , Producer

  Toggle the submenu Can Blue Box producers or PROs collect materials that are not marketed to consumers under the Blue Box regulation?

  Yes, a Blue Box producer or PRO (producer responsibility organization) on behalf of a producer, or a service provider on behalf of either party, can voluntarily choose to collect Blue Box materials that are not marketed to consumers.

  Blue Box materials not marketed to consumers cannot be counted towards meeting a producer’s collection or management requirements under the Blue Box Regulation.

  If Blue Box materials that are marketed to consumers are co-collected with Blue Box materials not marketed to consumers, a person must use a methodology or process acceptable to the Authority to account for materials supplied to a consumer or not. Anyone considering this can contact the Compliance Team to discuss at registry@rpra.ca or 833-600-0530.

  For example, if Blue Box materials supplied to a consumer in Ontario are collected along the same collection route as Blue Box materials that were not supplied to a consumer, they must be accounted for separately. When those materials are then sent to a processor, they must also be accounted for separately.

  See the FAQ: Who is a consumer under the Blue Box Regulation?

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• Program: Blue Box

  Topic: Collection systems , Producer

  Toggle the submenu Can Blue Box producers or PROs collect from locations that are not eligible sources?

  Yes, a Blue Box producer, or PRO (producer responsibility organization) on behalf of a producer, or a service provider on behalf of either party, can choose to offer collection services to any location. Blue Box producers are required to provide collection services to all eligible sources, as well as public spaces.

  Blue Box materials collected from locations that are not eligible sources cannot count towards meeting a producer’s management requirement unless they were supplied to a consumer in Ontario. See this FAQ: Who is a consumer under the Blue Box Regulation?

  If a person is co-collecting from locations that are eligible sources and not eligible sources, a person must use a methodology or process acceptable to the Authority to account for materials collected from each type of source. Anyone considering this can contact the Compliance Team to discuss at registry@rpra.ca or 833-600-0530.

  For example, if materials are collected from an eligible source and a location that is not an eligible source along the same collection route, they must be accounted for separately. When those materials are then sent to a processor, they must also be accounted for separately.

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

  Topic: Collection systems , Producer

  Toggle the submenu Can a producer collect products or materials that are not designated under 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 registry@rpra.ca 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.

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