Development of Management Performance Audit Procedures for Batteries, ITT/AV, Lighting and HSP

RPRA has finalized the Management Performance Audit procedures for batteries, ITT/AV and lighting (EEE) and hazardous and special products (HSP). The following procedures have been updated to include the finalized performance audit procedure:

• Batteries Registry Procedure – Verification and Audit
• EEE Verification and Audit Procedure
• Hazardous and Special Products Verification and Audit Procedure

The procedures are intended to be used by PROs reporting on behalf of producer clients, for producers that report on their own activities and their respective third-party auditors, to meet their performance audit reporting requirements.

Most producers have retained the services of a PRO to complete this reporting on their behalf. However, it remains the responsibility of a producer to ensure their reports are submitted by the deadline to avoid compliance action.

Consultation outcomes

The procedures were developed through a two-phase consultation in 2023: preliminary engagement with registered PROs from March 7 to April 14, 2023, followed by consultation on the draft procedures from November 15 to December 14, 2023, which included hosting three webinars to walk through the drafts and gather feedback. RPRA retained BDO Canada LLP (BDO) to support with the development of the procedures.

Finalizing the procedures and formally closing the consultation took longer than anticipated because RPRA needed to account for significant regulatory amendments made to all applicable regulations in late 2024 and review and respond to substantive consultation feedback.

RPRA considered all feedback received during the consultation when finalizing the procedures. In response to that feedback, RPRA made changes to the final procedures to support registrants in successfully completing the performance audit. Key changes include:

• elevating audit integrity by transitioning from CSRS 4400-level procedures to the rigorous CSAE 3000 reasonable assurance standard
• consolidating and clarifying program-specific reporting definitions
• continuing to provide detailed suggested audit procedures for CSAE 300 engagement

The consultation report summarizes the feedback received and how RPRA incorporated it into the final procedures.

Next steps for producers and their PROs

The first performance audit reports are due July 31, 2027:

RPRA understands that there may be data limitations when reporting on past performance years. RPRA will work with PROs and their auditors to help meet regulatory requirements and deadlines.

PROs and producers reporting on their own activities should review the applicable procedure and plan their audit with their third-party auditor ahead of the 2027 reporting deadline.

Have questions?

Contact RPRA’s Compliance and Registry Team at [email protected].

Background

Under the Batteries, Electrical and Electronic Equipment (EEE), and Hazardous and Special Products (HSP) Regulations, producers are obligated to collect and manage their obligated material(s) to recover resources and meet their minimum performance requirements through reuse, refurbishing, or recycling.

Producers without a PRO, producers who have identified they will not use their PRO and PROs reporting on their own activities must also submit Performance Audit Reports showing how they met their performance obligation. These audit reports must be verified in accordance with the performance audit procedures developed by RPRA.