As of November 2025, this page has been updated to announce the release of RPRA’s finalized compliance guideline and consultation report.
RPRA has finalized a new compliance guideline to support producers and producer responsibility organizations (PROs) in better understanding and meeting their collection system and minimum management requirements under the Batteries, Electrical and Electronic Equipment (EEE) (includes ITT/AV and Lighting), Hazardous and Special Products (HSP) and Tires regulations, as well as service providers who support the operation of these systems.
Read the Collection System and Minimum Management Requirements Guideline
The guideline provides guidance on establishing and operating a public collection system, including sharing collection sites, and how producers and PROs can meet minimum management requirements, including buying and selling “recovered weight” and “performance credits”.
The guideline will apply beginning with the 2026 performance year.
- Consultation process
The guidance was developed with extensive industry input, including two phases of engagement, a public consultation, and review by the Competition Bureau.
RPRA consulted on the draft guidance from June 3 to July 18, 2025. All feedback received was reviewed and, where possible, incorporated into the final guideline to reduce administrative burden and complexity, add clarity, and increase flexibility. RPRA has published a consultation report that summarizes the feedback received and RPRA’s responses.
Previous phases of engagement
Information Gathering – Phase two (May to August 2024)
From May 1 to August 30, 2024, RPRA considered the feedback received during phase one and continued to engage with stakeholders to further understand the impacts to registrant businesses as it refined the proposed compliance guidance for future consultation.
Information Gathering – Phase one (January to April 2024)
From January 23 to April 30, 2024, RPRA gathered feedback from registrants about sharing collection sites and buying and selling performance credits. This included direct engagement with PROs and service providers as key groups involved in these activities.
RPRA also received written responses from impacted registrants and stakeholders to questions posted to the consultation webpage related to sharing collection sites and buying and selling performance credits.
Background
RPRA developed this guidance to address compliance challenges identified by registrants including:
Collection sites
- What is necessary for a site to be considered readily accessible to the public?
- How does a PRO/producer verify a commercial relationship with a collection site based on marketplace arrangements?
- How can sites be shared and what is needed to prove this?
Performance credits
- When can a performance credit be traded?
- Who owns a performance credit?
- How can performance credits be verified to ensure they are not double counted?