From March 7 to April 5, 2024, RPRA consulted on the cut-off thresholds for supply data verification reporting that determine if hazardous and special products (HSP) producers of categories A (oil filters, non-refillable pressurized containers) and B (oil containers, antifreeze, solvents, paints and coatings, pesticides, refillable pressurized containers) are large or small. Beginning in 2024, only large category A and B producers are required to submit a supply data verification report to RPRA. Small producers will no longer be required to submit a verification report but will be subject to inspections.
This proposal outlines the proposed thresholds that producers will use to determine if they meet the definition of a large producer and therefore required to submit a supply data verification report in 2024 and onwards.
Producers were encouraged to submit feedback after reading the proposal to consultations@rpra.ca until April 5, 2024.
RPRA will consider all feedback received during the consultation period when revising the existing HSP Supply Data Verification Procedure to include the finalized cut-off thresholds. All feedback will be summarized in a consultation report and posted to this webpage. A communication will be sent to all HSP category A and B producers once the procedure is posted.
Background
Under the Hazardous and Special Products Regulation, producers of category A and B are required to report supply data to RPRA each year. Supply data must be reported in accordance with the HSP Verification and Audit Procedure.
In 2022, RPRA consulted on the principles and methodologies outlined in the HSP Verification and Audit Procedure. In addition to determining that only large producers will be required to submit a verification report beginning in 2024, RPRA made the following decisions based on feedback received:
- All category A and B producers were required to submit a one-time supply data verification report to RPRA in 2023 (the first verification reporting year), and
- To consult on two producer categories (i.e., large and small) after receiving 2023 verified supply data from HSP producers.