Frequently Asked Questions

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Program: Hazardous and Special Products

Topic: Producer , Registration
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. Contact the Compliance Team at registry@rpra.ca or 833-600-0530 if you have questions.

Related FAQs:

When and how do I register with RPRA as an HSP producer?
Program: Blue Box

Topic: Producer
Under the Blue Box Regulation, there are three types of exemptions that apply to producers:

Based on a producer’s gross annual revenue,

based on the weight of Blue Box materials supplied into Ontario, and

for producers of newspaper

1. Any producer whose gross annual Ontario revenue from products and services is less than $2,000,000 is exempt from all producer requirements under the regulation. In the case where the producer is a franchisor, it is the gross annual revenue of the system that is used to determine if an exemption applies.

Any producer who meets the exemption must keep any records that demonstrate its gross annual Ontario revenue is less than $2,000,000 in a paper or electronic format that can be examined or accessed in Ontario for a period of five years from the date of creation.

See our FAQs to understand what revenues municipalities and registered charities should consider when determining whether or not they are an exempt producer.

2. A producer who is above the revenue-based exemption level may still be exempt from performance requirements (collection, management and promotion and education) if their supply weight is below the exemption levels outlined in the table below.

If a producer’s annual revenue is more than $2,000,000 and supply weight in all material categories is less than the tonnage exemption threshold, the producer is required to register and report.

If a producer’s annual revenue is more than $2,000,000 and supply weight in at least one material category is above the tonnage exemption threshold, the producer is required to meet all obligations (registration, reporting, collection, management, and promotion and education). However, producers are only required to meet their minimum management requirement in material categories where they are above the exemption level.

3. As outlined in the amended Blue Box Regulation (released April 19, 2022), producers of newspapers may be exempt from collection, management, and promotion and education requirements. For the purposes of this exemption, “newspapers” includes newspapers and any protective wrapping and any supplemental advertisements and inserts that are provided along with the newspapers.

For a producer to qualify for this exemption, newspapers must account for more than 70% of their total weight of Blue Box materials supplied to consumers in Ontario in a calendar year. If exempt, the producer is not required to meet collection, management, and promotion and education requirements for all Blue Box materials they supply in Ontario in the following two calendar years.

A producer whose newspaper supply accounts for 70% or less of their total weight of Blue Box materials is subject to collection, management, and promotion and education requirements for all Blue Box materials they supply in Ontario.
Program: Blue Box

Topic: Producer
A marketplace facilitator is a person who contracts with a marketplace seller to facilitate the supply of the marketplace seller’s products by:

Owning or operating an online consumer-facing marketplace or forum in which the marketplace seller’s products are listed or advertised for supply and where offer and acceptance are communicated between a marketplace seller and a buyer (e.g., a website), and

Providing for the physical distribution of a marketplace seller’s products to the consumer (e.g., storage, preparation, shipping of products).

Under the Blue Box Regulation, if a retailer (online or at a physical location) is determined to be the producer based on hierarchies, but they are a marketplace seller, the marketplace facilitator is the obligated producer. A marketplace seller is a person who contracts with a marketplace facilitator to supply its products.
Program: Blue Box

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

Blue Box materials supplied to a business (e.g., the operators of a long-term care home) are not obligated, however, there are no deductions available for materials supplied to a consumer in an IC&I setting (e.g., a resident of a long-term care home).

Any Blue Box materials supplied to consumers in Ontario are obligated. Blue Box materials supplied to the IC&I sector are not obligated (except beverage containers which are obligated regardless of the sector supplied into).
Program: Blue Box

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

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.
Program: Blue Box

Topic: Producer , Registration , Reporting
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 from outside of Ontario

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
Program: Blue Box

Topic: Producer , Registration , Reporting
See our FAQ to understand “What is blue box product packaging?”.

Product packaging added to a product can be added at any stage of the production, distribution and supply of the product. A person adds packaging to a product if they:

make the packaging available for another person to add the packaging to the product

cause another person to add the packaging to a product

combine the product and the packaging

For the portion of the product packaging that a brand holder added to the product, a person is considered a producer:

if they are the brand holder of the product and are resident in Canada

if no resident brand holder, they are resident in Ontario and import the product from outside of Ontario

if no resident importer, they are the retailer that supplied the 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

For the portion of the product packaging that an importer of the product into Ontario added to the product, a person is considered a producer:

if they are resident in Ontario and import the product from outside of Ontario

if no resident importer, they are the retailer that supplied the 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

For any portion of the packaging that is not described above, the producer is the retailer who supplied the product to consumers in Ontario.
Program: Blue Box

Topic: Collection systems , General , PRO , Processor , Producer
Under the Blue Box Regulation, blue box product packaging includes:

Primary packaging is for the containment, protection, handling, delivery and presentation of a product at the point of sale, including all packaging components, but does not include convenience packaging or transport packaging (e.g., film and cardboard used to package a 24-pack of water bottles and the label on the water bottle).

Transportation packaging which is provided in addition to primary packaging to facilitate the handling or transportation of one or more products such as a pallet, bale wrap or box, but does not include a shipping container designed for transporting things by road, ship, rail or air.

Convenience packaging includes service packaging and is used in addition to primary packaging to facilitate end users’ handling or transportation of one or more products. It also includes packaging that is supplied at the point of sale by food-service or other service providers to facilitate the delivery of goods and includes items such as bags and boxes that are supplied to end users at check out, whether or not there is a separate fee for these items.

Service accessories are products supplied with a food or beverage product and facilitate the consumption of that food or beverage product and are ordinarily disposed of after a single use, whether or not they could be reused (e.g., a straw, cutlery or plate).

Ancillary elements are integrated into packaging (directly hung or attached to packaging) and are intended to be consumed or disposed of with the primary packaging. Ancillary elements help the consumer use the product. Examples of ancillary packaging include a mascara brush forming part of a container closure, a toy on the top of candy acting as part of the closure, devices for measuring dosage that form part of a detergent container cap, or the pouring spout on a juice or milk carton.
Program: Blue Box

Topic: Collection systems , General , PRO , Processor , Producer
Under the Blue Box Regulation, a packaging-like product is:

ordinarily used for the containment, protection, handling, delivery, presentation or transportation of things

ordinarily disposed of after a single use

not used as packaging when it is supplied to the consumer

Packaging-like products include aluminum foil, a metal tray, plastic film, plastic wrap, wrapping paper, a paper bag, beverage cup, plastic bag, cardboard box or envelope, but does not include a product made from flexible plastic that is ordinarily used for the containment, protection, or handling of food, such as cling wrap, sandwich bags, or freezer bags.

If a producer is unsure whether or not their product is a packaging-like product, they can ask themselves the following questions to help determine whether the product is obligated to be reported under the Blue Box Regulation:

Is the product actually packaging around a separate product?

If yes, the product is not a packaging-like product. Instead, the product is considered blue box packaging and must be reported as blue box material. If no, continue to the next question.

Is the product used for the containment, protection, handling, delivery, presentation or transportation of a thing(s)?

If no, the product is not a packaging-like product. If yes, continue to the next question.

Is the product typically disposed of after a single use (regardless if some may wash and reuse it)?

If no, the product is not a packaging-like product. If yes, continue to the next question.

Is the product made from flexible plastic that is for the containment, protection or handling of food?

If yes, the product is not a packaging-like product. If no, the product is a packaging-like product and must be reported as blue box material.

If a producer is still unsure whether or not their product is a packaging-like product, they should contact the Compliance and Registry Team at 833-600-0530 or registry@rpra.ca.
Program: Batteries , Blue Box , Hazardous and Special Products , ITT/AV , Lighting , Tires

Topic: Environmental Fees , Producer , Retailer

Consumer protection laws in Ontario prohibits the misrepresentation of charges, which means that producers or retailers cannot misrepresent any visible fees as a regulatory charge, tax, RPRA fee or something similar. Consumers who have questions or concerns about a specific transaction or want to report a misrepresentation can contact the Ministry of Public and Business Service Delivery at 1-800-889-9768.

As of March 2023, the promotion and education requirements related to environmental fees have been removed from the Tires, Batteries, Electrical and Electronic Equipment, and Hazardous and Special Products regulations. No changes were made to the Blue Box Regulation as it never contained promotion and education requirements related to these fees.

RPRA’s compliance bulletin Charging Tire Fees to Consumers has since been revoked and RPRA has ceased its enforcement of promotion and education requirements for visible fees across all materials.